Overview
- Headquarters
- Lexington, KY
- Total Firm Assets
- $114 million
- Average High-Net-Worth Client Portfolio Size
- $1.7 million
Fee Structure
Primary Fee Schedule (ADV PART 2A - FIRM BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.50% |
| $500,001 | $1,000,000 | 1.25% |
| $1,000,001 | $3,000,000 | 1.00% |
| $3,000,001 | and above | 0.80% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $13,750 | 1.38% |
| $5 million | $49,750 | 1.00% |
| $10 million | $89,750 | 0.90% |
| $50 million | $409,750 | 0.82% |
| $100 million | $809,750 | 0.81% |
Clients
- High-Net-Worth Share of Firm Assets
- 70.93%
- Number of High-Net-Worth Clients
- 47
- Total Client Accounts
- 991
- Discretionary Accounts
- 991
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting, Investment Advisor Selection
Regulatory Filings
- SEC CRD Number
- 314832
Additional Brochure: ADV PART 2A - FIRM BROCHURE (2026-08-28)
View Document Text
ABRI LLC
WWW.ABRI.IO
333 E SHORT ST., #210
LEXINGTON, KY 40507
(859) 636-6140
hello@abri.io
FORM ADV PART 2A
FIRM BROCHURE
AUGUST 27, 2026
This brochure provides information about the qualifications and business practices of
ABRI LLC. If you have any questions about the contents of this brochure, please contact
us at (859)636-6140. 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.
ABRI LLC is a registered investment adviser. Registration of an investment adviser does
not imply any level of skill or training.
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information about ABRI LLC
is available on
Additional
the SEC’s website
www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known
as a CRD number. ABRI LLC’s CRD number is 314832.
ITEM 2 - MATERIAL CHANGES
We have the following material changes to report since our last annual update on February
2, 2026:
Jesse Case is now the firm’s Chief Compliance Officer.
-
- We now offer Ongoing Wealth Management and Specialty Services. Additional
information about the service and the fees can be found in Items 4 & 5 below.
Stand-alone
- Ongoing Financial Planning is no longer offered as a separate service; financial
planning is delivered through Ongoing Wealth Management or a One-Time
Financial Planning Project.
We have no additional material changes to report.
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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 ............................................................................................................................................ 4
ITEM 5 – FEES AND COMPENSATION ................................................................................................................................ 8
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .................................................... 12
ITEM 7 – TYPES OF CLIENTS ............................................................................................................................................... 12
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....................................... 12
ITEM 9 – DISCIPLINARY INFORMATION .......................................................................................................................... 15
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................................................... 15
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTION AND PERSONAL
TRADING .................................................................................................................................................................................... 15
ITEM 12 – BROKERAGE PRACTICES ................................................................................................................................. 16
ITEM 13 – REVIEW OF ACCOUNTS .................................................................................................................................... 17
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ................................................................................ 18
ITEM 15 – CUSTODY .............................................................................................................................................................. 18
ITEM 16 – INVESTMENT DISCRETION .............................................................................................................................. 18
ITEM 17 – VOTING CLIENT SECURITIES .......................................................................................................................... 19
ITEM 18 – FINANCIAL INFORMATION ............................................................................................................................... 19
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ITEM 4 – ADVISORY BUSINESS
OWNERSHIP/ADVISORY HISTORY
ABRI LLC (“we” and “our”) is a Kentucky Limited Liability Company formed in May 2021.
We registered as an investment adviser in August 2021. Subsequently, we registered with
the Securities and Exchange Commission (“SEC”) in March 2026. Zackary Wallace is the
Managing Member and Jesse Case is the firm’s Chief Compliance Officer.
ADVISORY SERVICES OFFERED
ADVISORY SERVICES OFFERED TO INDIVIDUALS
FINANCIAL PLANNING
We provide financial planning that involves a review of your financial situation, goals, and
risk tolerance. Through a series of personal interviews and/or the use of questionnaires,
we will collect pertinent data identifying goals, objectives, financial problems, and
potential solutions. With this information, we tailor your financial plan and the advice we
give to you. Financial planning is delivered through our Ongoing Wealth Management
service or a One-Time Financial Planning Project, as described below. Our business owner
and personal financial planning services include the following topics:
Financial Planning– We provide a detailed audit on current planning in place. We
provide a multi-step approach to goal setting and resource evaluation with
modeling on feasibility. We have a clear process that moves from discovery, to
evaluation, to education, to implementation, to tracking and monitoring.
Income Strategies– We advise on asset allocation and investment income
accumulation techniques. Our evaluations are made on existing investments in
terms of their economic and tax characteristics as well as their suitability for
meeting client’s objectives. Tax consequences and their implications are identified
and evaluated.
Employee Benefit Support – We analyze your health insurance options, what
makes the most sense, asset allocation on the 401k, disability insurance review.
Insurance Policy Review– We conduct a review based on the combination of
insurance types that best meet your specific needs, e.g. life, health disability, long-
term care, and others as appropriate.
Estate and Trust Planning – We give advice with respect to property ownership,
distribution strategies, estate tax reduction, and tax payment techniques.
Discussions may involve gifts, trusts and the disposition of business interests. Tax
consequences and their implications are also identified/evaluated. We are not
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Attorneys but can help coordinate conversations with legal experts in regard to
your planning and goals.
Cash Flow Management– We advise on cash accounts, financial obligations, and
cash management. Tax consequences and their implications are also identified and
evaluated.
Education Planning, Repayment and Funding – We assist with researching
alternative strategies regarding the full or partial funding of college or other post-
secondary education experiences. Tax consequences and their implications are also
identified and evaluated.
Private Equity, Venture Capital & Real Estate Syndicate Audits – We assist with
your due diligence process conducted on private equity, venture capital and real
estate audits. Tax consequences and their implications are also identified and
evaluated.
Retirement and Distribution Planning – We advise on the accumulation and
distribution phases of retirement accounts. Evaluations are made of existing
investments in terms of their economic and tax characteristics as well as their
suitability for meeting client’s distribution objectives. Tax consequences and their
implications are also identified and evaluated.
We also assist with federal and state tax preparation and filing. This is an additional service
available under our Specialty Services or, for eligible Ongoing Wealth Management
households, through a CPA retained by us. The service includes:
Tax Audits, Forecasting, Preparation and Filing – We will provide ongoing services with a
selected accountant for an additional fee which will be included in our calculation and paid
to the accountant, or we can coordinate with an outside Accountant. The services will
cover the following areas: tax planning and forecasting; annual and quarterly tax
preparation and filing; and ongoing support related to tax matters. We will establish a
clear tax and accounting plan, assist you with implementation and documentation, and
provide ongoing updates, monitoring, and adjustments as needed; we will also provide
proactive guidance to ensure accurate compliance and alignment with your financial
objectives.
ONGOING WEALTH MANAGEMENT
We offer ongoing wealth management where we provide on-going services that include:
a written financial plan with ongoing recommendations across tax, legal, investment, and
insurance matters (provided on a non-discretionary basis); investment management on a
discretionary basis as further described below; estate planning documents drafted by
attorneys retained by Adviser; an annual tax review; and strategy meetings at a frequency
that varies by household assets under management. Households with $1,000,000 or more
in assets under management with us may elect to have their tax return filed by a CPA
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retained by us. Fees of attorneys and CPAs retained by us to provide these services are
included in our fee under the Ongoing Wealth Management engagement unless otherwise
expressly noted in your agreement.
INVESTMENT MANAGEMENT
Investment management services are offered to our individual clients in addition to our
ongoing wealth management services or as a separate service. This involves the ongoing
management of your investment accounts. We work with you to understand your
investment objectives, time frame and risk tolerance. With this information, we create a
customized portfolio using a combination of our proprietary model portfolios. We will
request discretionary authority from you in order to select the securities and execute
transactions without prior permission from you. We base our recommendations on a
variety of factors including, but not limited to, performance, allocation, risk, fees, tax
efficiency of different investment strategies, as well as your input and preferences
regarding the strategies.
OTHER ADVISORY SERVICES
ONE-TIME FINANCIAL PLANNING PROJECT
We offer One-time fixed fee Financial Planning Projects where we will also cover all or
some of the above topics described under financial planning services. The engagement
includes three (3) structured client meetings; a written financial plan; and tax, legal,
investment, and insurance recommendations. Upon delivery of the plan, this engagement
is concluded. At your request, further reviews may be carried out in another contractual
agreement.
FINANCIAL CONSULTING
Financial consulting hourly engagements are offered for those who would like us to only
focus on a single topic or multiple topics as identified in our meetings with you. The
chosen topics will be written in the financial consulting agreement. Typically, we meet
with you to discuss your questions, conduct research on the chosen topics and present
the findings to you through a second meeting. You will not receive a written financial plan.
Upon completion of the delivery of the recommendations, the engagement is concluded.
At your request, further reviews may be carried out in another contractual engagement.
Please Note: When we provide financial planning services and you implement the financial
plan through one of our representatives, the representative will receive compensation in
the form of a commission or fee. This creates a conflict of interest between the
representative and you. Therefore, when providing financial planning services, we would
like you to note: (a) a conflict exists between the representative’s interests and your
interests, (b) you are under no obligation to act upon the recommendation, and (c) if you
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elect to act on any of the recommendations, you are under no obligation to effect the
transaction through the representative. If the financial plan recommends insurance
products and you implement the recommendation of such products through our
representative, the representative shall receive compensation in the form of a commission
or fee. Please see Item 10.D – Other Industry Affiliations for details regarding conflicts of
interests associated with the sale of insurance products.
RETIREMENT PLAN CONSULTING
For our retirement plan consulting services, we will recommend a third-party investment
adviser to assist you with the management of your 401(k) plan(s). Prior to the
recommendation, we will begin with a planning meeting and work with you to determine
which third-party investment adviser may be appropriate. If you wish to proceed with the
recommendation, we will enter a relationship with the third-party investment adviser.
Under this agreement, we are granted the authority to act as a 3(21) fiduciary. We will
provide the following ERISA non-fiduciary services: Education Services to Plan
Committee; Participant Education Services; Plan Search Support; Review of Fiduciary
Liability Insurance Coverage; Monitoring of Qualified Fiduciary; or Participant Advice.
When requested by you, we may also provide any of the following ERISA non-
discretionary fiduciary services: create an Investment Policy Statement; provide
Investment Recommendations & Performance Monitoring; or Selection of Qualified
Default Investment Alternatives. Please note that our ERISA fiduciary services are limited
to ERISA Section 3(21) and we do not provide ERISA Section 3(38) fiduciary services. You
will receive a separate disclosure document from the third-party investment adviser
outlining the details of the services rendered and fee schedules at the time of the referral.
Currently there are no existing arrangements with a third-party investment adviser.
SPECIALTY SERVICES
We also offer services which may include bookkeeping; payroll; estate and legal support;
tax return preparation and filing; and divorce financial analysis (CDFA®) and litigation
support. We will provide the selected services on a non-discretionary basis. Each specialty
service is scoped and quoted separately at the time of engagement and may be structured
on a monthly, hourly, or one-time basis as set forth in your agreement or a separate scope
of work or engagement letter. Divorce financial analysis and litigation support services are
provided under a separate agreement and may include financial affidavit preparation and
review; marital vs. separate property analysis and asset/debt inventory; settlement
scenario modeling and division-of-asset analysis; tax impact analysis of proposed
settlement structures; retirement and pension division analysis (including QDRO
coordination with counsel); lifestyle, spending, and post-divorce cash flow analysis;
spousal maintenance and child support scenario analysis (financial modeling only);
mediation and settlement conference support; expert witness services, including
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deposition and court testimony; business valuation coordination and review (valuations
are performed by third-party specialists); and post-divorce transition planning. These
services are financial in nature and do not include legal advice, investment management,
discretionary trading, or the implementation of securities or insurance transactions.
TAILORED SERVICES
The goals and objectives for each client are documented before any investing takes place.
Clients may impose restrictions on investing in certain securities or types of securities.
WRAP PROGRAM
We do not sponsor a wrap fee program.
CLIENT ASSETS MANAGED
As of January 8, 2026, we manage $114,386,423 assets on a discretionary basis and $0 in
client assets on a non-discretionary basis.
ITEM 5 – FEES AND COMPENSATION
ONGOING WEALTH MANAGEMENT
We offer ongoing wealth management services either at an annual rate based on assets under
management or at monthly flat rate as shown below in the flat fee alternative and investment
management fee table. New Ongoing Wealth Management clients pay a one-time onboarding
planning fee of $3,000 at the start of the engagement. This fee is waived for clients who previously
completed a One-Time Financial Planning Project with Adviser. The fee can be paid via direct
deduction from the client’s custodial account, ACH or via credit/debit card and may be negotiable.
ONGOING WEALTH MANAGEMENT FLAT-FEE ALTERNATIVE
In some cases, a Client’s needs require services beyond what is typically included at their AUM
level — for example, additional planning depth, more frequent meetings, multi-entity coordination,
or other added complexity. In those cases, Adviser may charge a flat fee in lieu of, or in addition
to, the standard AUM-based fee. The monthly flat fee ranges between approximately $1,000 and
$10,000. The flat fee is set in the engagement letter or an amendment and reflects the agreed
scope of services.
INVESTMENT MANAGEMENT
Our annual management fee for stand-alone investment management is based on the
following fee schedule:
Annual Fee %
Assets Under
Management
$0-$500,000
1.50%
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$500,001 - $1,000,000
1.25%
$1,000,001 - $3,000,000
1.00%
$3,000,000+
.80%
Investment management fees are calculated and billed monthly in arrears and based on
the average daily market value of the assets held in the account over the month’s billing
period. Fees are calculated using a tiered, blended (marginal) methodology: each tier’s rate
applies only to the portion of household assets under management that falls within that
tier, and the fee is calculated on total household assets under management with us.
Unmanaged or static client assets are not included in the management fee calculation. The
initial management fee will be prorated based upon the number of days the account was
open during the month. You will be asked to provide written authorization permitting us
to be paid our advisory fees directly from your accounts held by the custodian. You will
be provided with a monthly statement reflecting the deduction of the advisory fee from
the Custodian detailing the amount of the advisory fee. Fee example: fees for a given day
with assets under management of $100,000 is $4.11 ($100,000 multiplied by 1.50% divided
by 365 calendar days equals $4.11); the daily fee is then multiplied by 30 business days in a
month ($4.11 multiplied by 30 equals a total monthly fee of $123.30). The total fee is then
deducted on a monthly basis.
The negotiated rate will be stated in the investment management agreement.
INVESTMENT MANAGEMENT FLAT-FEE ALTERNATIVE
In some cases, a Client’s needs require services beyond what is typically included at their AUM
level — for example, additional planning depth, more frequent meetings, multi-entity coordination,
or other added complexity. In those cases, Adviser may charge a flat fee in lieu of, or in addition
to, the standard AUM-based fee. The monthly flat fee ranges between $1,000 and $10,000.The
flat fee is set in the engagement letter or an amendment and reflects the agreed scope of services.
ONE-TIME FINANCIAL PLANNING PROJECT & FINANCIAL CONSULTING HOURLY ENGAGEMENTS
One-time financial planning projects will be charged a planning fee ranging from $3,000
to $35,000 depending on the complexity of the individual’s circumstances and number of
topics covered by the plan. The fee is collected at engagement.
Financial consulting hourly engagements are provided at an hourly rate of $500. At the
beginning of the engagement, we will provide you with a written estimate of the number
of hours we believe the services will take. We will track the time we spend collecting your
information, analyzing and researching the chosen topics, and time presenting the findings
to you.
Fees for our one-time financial consulting projects and financial consulting hourly
engagement may be paid via ACH, debit or credit card and collected at engagement.
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When fees for any of our services are paid by credit or debit card, a 3% processing
surcharge applies and is itemized separately on the invoice. Additionally, you may incur
certain charges imposed by custodians, brokers, and other third parties such as fees
charged by ticket charges, managers, custodial fees, deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and
taxes on brokerage accounts and securities transactions. Mutual funds and exchange
traded funds also charge internal management fees, which are disclosed in a fund’s
prospectus. Such charges, fees and commissions are exclusive of, and in addition to, our
fee and we will not receive any portion of these commissions, fees, and costs. For more
information about our brokerage practice, please see Item 12.A.
RETIREMENT PLAN CONSULTING
When providing retirement plan consulting services, we act as a solicitor for the
recommended third-party investment adviser, and we do not charge a separate fee for the
services. Instead, we enter into an agreement with the third-party investment adviser and
share in a portion of the third-party investment adviser’s management fee. Our portion
can be up to 50% of the third-party investment adviser’s management fee. The exact
amount will be disclosed in the third-party investment adviser’s Solicitor Disclosure
Document. Additionally, when the management fee is withdrawn (quarterly or monthly, in
advance or in arrears) it will vary with each third-party investment adviser. These details
will be disclosed in the third-party investment adviser’s ADV Part 2A, client agreement
and the third-party investment adviser’s Solicitor Disclosure Document; these documents
will be given to the client at solicitation. If applicable, the third-party adviser will deliver
an invoice to the client (Please see Item 13 under Reports for additional details regarding
fee invoices).
SPECIALTY SERVICES
Our specialty services are charged on a monthly, hourly or one-time basis. Our monthly
rate ranges between $50 and $5,000. Our maximum hourly rate is $500/hr. Final pricing
and scope for any service will be set and agreed upon in the agreement. Certain specialty
services (such as estate and legal support and tax return services) are subject to a 12-
month minimum term. For divorce financial analysis (CDFA) and litigation support
engagements, time is billed in quarter-hour (0.25) increments and certain services are
subject to minimum billing blocks (for example, two hours for mediation and settlement
conference attendance and four hours for depositions, court appearances, and expert
testimony); an initial retainer is due at engagement and is applied against fees and costs
as they are incurred, you will be asked to replenish the retainer as it is drawn down, and
any unused retainer balance will be refunded following the conclusion or termination of
the engagement. Some specialty services may also have a one-time set up fee with a
minimum of $500. The final set up fee is set in the agreement based on the scope of the
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engagement. The fees for this service are due upon receipt of invoice and can be paid via
ACH, check, credit or debit card, or deduction from a custodial account where available.
Fees for expert testimony, depositions, and court appearances are payable in advance of
the scheduled appearance, and invoices not paid within thirty (30) days may be assessed
a late charge of 1.5% per month on the unpaid balance. In addition to our fees, you are
responsible for reasonable out-of-pocket costs incurred in connection with specialty
service engagements — such as third-party valuation or actuarial fees (if authorized in
advance), court or filing fees, mileage, travel expenses, and delivery, copying, and postage
charges — and for software subscription expenses related to bookkeeping and payroll
services (such as QuickBooks or Gusto) unless otherwise negotiated.
TERMINATION OF SERVICES
You may terminate any service for any reason at any time and, within the first five business
days after signing the contract, without any cost or penalty. Thereafter, the contract may
be terminated at any time by giving ten (10) days’ written notice. To cancel the agreement,
you must notify us in writing to ABRI LLC, 333 E Short St., #210, Lexington, KY 40507.
Upon receipt of written notice of termination for our investment management, fees will
be prorated for the number of days the account was managed, and an invoice will be sent
to you. The invoice will be due within 30 days of receipt. For Ongoing Wealth
Management, if cancelled, you will not be charged a planning fee for the month
terminated; completed portions of any documents, plans, or work product will not be
delivered. If you terminate a One-Time Financial Planning Project or financial consulting
engagement prior to delivery, you will not be charged a planning fee, and completed
portions of any documents or work product will not be delivered. For Specialty Services,
refund and termination terms are as set forth in the applicable agreement, scope of work,
or engagement letter; divorce financial analysis and litigation support engagements
conclude upon delivery of the contracted services, and you will receive a prorated refund
of any unearned fees, including any unused retainer balance.
COMPARABLE SERVICES DISCLOSURE
You should note that lower fees for comparable services may be available from other
sources.
OTHER SECURITIES COMPENSATION
As established in Item 10.D – Other Industry Affiliations, earning commissions for the sale
of insurance products creates a conflict of interest for the firm. The commissions give a
financial incentive to recommend and sell you the insurance products. We attempt to
mitigate the conflict of interest to the best of our ability by placing your interests ahead
of our own and through the implementation of policies and procedures that address the
conflict.
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RETIREMENT ROLLOVER CONFLICTS OF INTEREST
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 of interest 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.
ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE
MANAGEMENT
We do not charge performance-based fees (fees based on a share of capital gains on or
capital appreciation of the assets of a client) or provide side by side management.
ITEM 7 – TYPES OF CLIENTS
We offer our services to individuals, high net worth individuals, pension and profit-sharing
plans, charitable organizations, corporations and other business entities. We do not
require a minimum account size.
ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES
AND RISK OF LOSS
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
With respect to our investment management services, we utilize individualized asset
allocation, Strategic Asset Allocation and Modern Portfolio Theory as our investment
strategies for your account(s).
The asset classes typically
Asset allocation is an investment strategy that aims to balance risk and reward by
apportioning a portfolio’s assets according to an individual’s goals, risk tolerance and
investment horizon.
include equities, fixed-income,
international, and cash and equivalents. The risk associated with asset allocation is that
each class had different levels of risk and return, so each will behave differently overtime.
There is no guarantee that diversification amount asset classes will grow a portfolio.
Strategic asset allocation is a portfolio strategy that involves setting target allocations for
various assets classes and rebalancing periodically. The portfolio is rebalanced to the
original allocations when they deviate significantly from the initial settings due to differing
returns from the various assets. The target allocations depend on several factors, such as
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the investor’s risk tolerance, time horizon and investment objectives, and may change over
time as these parameters change.
Modern portfolio theory proposes that by investing in a predetermined asset mix derived
from the efficient frontier (designed to achieve a specific client objective within a certain
risk tolerance) and rebalancing with discipline, the portfolio is diversified across the various
asset classes to mitigate unnecessary risk. This also provides for a portfolio that can
operate without reliance on market timing and security selection; however, as with all
equity investments, positive returns are not guaranteed. In conjunction with investing in
a diversified portfolio, each portfolio is constructed to meet specific parameters set for in
the individual client’s investment policy statement and/or other documents. These
parameters can include – but are not limited to – tax efficiency, concentrated stock
positions and management history. Once again, the risk associated with a diversified
portfolio is that each class had different levels of risk and return, so each will behave
differently over time and, despite being diversified, there is no guarantee that an account
will grow.
INVESTMENT RISKS
All investment programs have certain risks that are borne by the client and investing in
securities involves risk of loss that clients should be prepared to bear. Our goal is to
reduce the risk of loss, but not at the expense of portfolio growth. Recommended
investment strategies seek to balance risks and rewards to achieve investment objectives.
To manage risk, we rebalance model portfolios on an “as needed” basis to bring the asset
allocations back to their intended balances. The client should feel free to ask questions
about risks that he or she does not understand; we would be pleased to discuss them.
RECOMMENDED SECURITIES
We may use several types of securities in your portfolios including, but not limited to,
mutual funds, exchange traded funds (ETFs), stocks, bonds and cash. Risks associated with
these types of securities include:
Mutual Funds, Stocks & Bonds
Mutual funds, stocks and bonds come with many of the same risks that include:
Credit Risk: This is the risk that an issuer of a bond could suffer an adverse change
in financial condition that results in a payment default, security downgrade, or
inability to meet a financial obligation.
Market Risk: The risk that you will lose some or all of your principal. As markets
fluctuate, there is always a possibility that the mutual funds you hold might be
caught in decline.
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Inflation Risk: This is the risk that inflation will undermine the performance of an
investment and/or the future purchasing power of a client's assets.
Interest Rate Risk: The chance that bond prices overall will decline because of rising
interest rates.
Liquidity Risk: This is the risk that we may not be able to sell a bond in a timely
manager at a desired price.
Stock Market Risk: The change that stock prices overall will decline. Stock markets
tend to move in cycles, with periods of rising stock prices and periods of falling
stock prices.
Manager Risk: The chance that the proportions allocated to the various securities
will cause the client’s account to underperform relevant to benchmarks or other
accounts with a similar investment objective.
Exchange Traded Funds (ETFs)
ETFs investments include risks like mutual funds, stocks and bonds above. There are also
risks involved with investing in ETFs including the risk principal (i.e. possible loss of
money). The share prices may trade above or below the purchase price. An additional risk
associated with an ETF includes:
ETF Liquidity Risk: Not all ETFs have a large asset base or high trading volume. As
a result, certain ETFs could have large bid-ask spreads and low volume trading.
These could result in issues when closing out a position. This pricing inefficiency
could cost you more money and even incur greater losses if the position cannot be
closed out in a timely manner.
Stocks (Additional Risk):
Investment Style Risk: Different investment styles tend to shift in and out of favor,
depending on market conditions and investor sentiment. Growth stocks tend to be
more volatile than value stocks and their prices usually fluctuate more dramatically
than the overall stock market. A stock with growth characteristics can have sharp
price declines due to decreases in current or expected earnings and may lack
dividends that can help cushion its share price in a declining market.
Principal Risk: There is no guarantee that a stock will go up in value. A stock’s price
fluctuates, which means a client could lose money by investing in an equity security.
Mutual Funds (Additional Risk):
Mutual Fund Manager: the chance that the proportions allocated to the various
mutual funds will cause the client’s account to underperform relevant to
benchmarks or other accounts with similar investment objectives.
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ITEM 9 – DISCIPLINARY INFORMATION
Registered investment advisers are required to disclose all material facts regarding any
legal or disciplinary events that would be material to your evaluation of each supervised
person providing investment advice. Neither us nor our management persons have
information applicable to this Item.
ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND
AFFILIATIONS
BROKER DEALER AFFILIATION
Neither us nor our management persons are affiliated with a broker-dealer.
FUTURES/COMMODITIES FIRM AFFILIATION
Neither us nor our management persons are affiliated with a futures commodities
broker.
OTHER INDUSTRY AFFILIATIONS
Our owner, Mr. Wallace, is the owner of Paperclip, LLC, a licensed insurance agency. Mr.
Wallace and associates that are licensed as insurance agents may recommend the sale of
insurance products to you through Paperclip, LLC. This other business activity pays them
commissions that are separate from the fees described in Item 5, above. This is considered
a conflict of interest as the commissions give them a financial incentive to recommend and
sell you the insurance products. They will attempt to mitigate any conflicts of interest to
the best of their ability by placing your interests ahead of their own and through the
implementation of policies and procedures that address the conflict. Additionally, you are
informed that you always have the right to choose whether to act on the recommendation
and you have the right to purchase recommended insurance through any licensed
insurance agent or agency.
RECOMMENDATION OF THIRD-PARTY INVESTMENT ADVISER
We recommend the services of Third-Party Advisers. This information can be found under
Items 4 and 5. We will ensure that a Third-Party Adviser is properly registered or exempt
from registration in your state of residence before recommending that Third-Party Adviser
to you.
ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN
CLIENT TRANSACTION AND PERSONAL TRADING
DESCRIPTION
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Our Code of Ethics establishes ideals for ethical conduct based upon fundamental
principles of openness, integrity, honesty, and trust. We will provide a copy of our Code
of Ethics to any client or prospective client upon request.
Our Code of Ethics covers all supervised persons, and it describes our high standard of
business conduct and fiduciary duty to our clients. The Code of Ethics includes, among
other things, provisions relating to the confidentiality of client information, a prohibition
on insider trading, a prohibition on rumor mongering, restrictions on the acceptance of
significant gifts and the reporting of certain gifts and business entertainment items, and
personal securities trading procedures. All supervised persons must acknowledge the
terms of the Code of Ethics annually or as amended.
MATERIAL INTEREST IN SECURITIES
We do not have a material interest in any securities.
INVESTING IN OR RECOMMENDING THE SAME SECURITIES
Our owner may buy or sell for his own account the same securities that he purchases or
recommends for purchase in client accounts. A conflict of interest exists because he can
trade ahead of client trades. We mitigate any conflict of interest in two ways. First, our
Code of Ethics requires employees to report personal securities transactions on at least a
quarterly basis and provide us with a detailed summary of certain holdings (both initially
upon commencement of employment and quarterly thereafter) in which employees have
a direct or indirect beneficial interest. The reports are reviewed to ensure we do not trade
ahead of client accounts. Second, we require client transactions be placed ahead of our
associates’ personal trades or our associates can place personal trades as part of a block
trade (Please see Item 12.B for details on our block trading practices). The records of all
associates’ personal and client trading activities are reviewed and made available to
regulators to review on the premises.
ITEM 12 – BROKERAGE PRACTICES
We do not maintain custody of your assets. Your assets must be maintained in an account
at a “qualified custodian”, which is generally a broker-dealer or bank. We recommend that
you use Altruist Financial, LLC (“Altruist”). We maintain our relationship with Altruist
whereby Altruist provides certain benefits to us, including a fully digital account opening
process, a variety of available investments, and integration with software tools that can
benefit us and our clients.
RESEARCH AND SOFT DOLLARS
“Soft dollars” are defined as a form of payment investment firms can use to pay for goods
and services such as news subscriptions or research. When an investment firm gives its
business to a particular brokerage firm, the brokerage firm in return can agree to use some
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of its revenue to pay for these types of services. Please see Item 12 above and Item 14
for economic benefits received by Altruist.
BROKERAGE FOR CLIENT REFERRALS
We do not receive client referrals or any other incentive from any broker-dealer or
custodian.
DIRECTED BROKERAGE
We do not allow you to direct brokerage to a broker-dealer or custodian other than those
recommended by us. This practice may cost you more money.
TRADE AGGREGATION
We may aggregate transactions in equity and fixed income securities for a client with other
clients to improve the quality of execution. When transactions are aggregated, the actual
prices applicable to the aggregated transactions will be averaged, and each client account
will be deemed to have purchased or sold its proportionate share of the securities involved
at the average price obtained. We may determine not to aggregate transactions, for
example, based on the size of the trades, the number of client accounts, the timing of the
trades, the liquidity of the securities or the discretionary or non-discretionary nature of
the trades. If we do not aggregate orders, some clients purchasing securities around the
same time may receive a less favorable price than other clients. This means that the
practice of not aggregating may cost clients more money.
ITEM 13 – REVIEW OF ACCOUNTS
PERIODIC REVIEWS
All individuals will receive at least annual check ins either by phone or email. Your ABRI
Adviser will meet with you annually to review your financial plan either by phone or via
webinar and update any changes to your plan. When we manage your portfolio(s) we
conduct a monthly review to determine if rebalancing is necessary.
OTHER REVIEWS
Additional reviews are conducted periodically depending on market conditions, economic
or political events, or by changes in a client’s financial situation (such as retirement,
termination of employment, physical move or inheritance).
REPORTS
Financial planning services include a written plan (financial consulting engagements
include presented findings and recommendations but not a written financial plan); we do
not provide any additional reports. When we manage your portfolio(s), you will receive at
least quarterly account statements from the account’s custodian.
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For Washington clients, each time we charge an advisory fee, we will provide an invoice
to you that contains the fee(s), the formula used to calculate the fee(s), the fee calculation
itself, the time period covered by the fee(s) and if applicable, the amount of assets under
management the fee is based on and the name of the custodian(s). If we charge
performance compensation, the invoice will also include your cumulative net investment
gain (or loss) and the amount of cumulative net investment gain over which you will
receive performance compensation. We urge you to carefully review and compare these
invoices with the statements received from the account’s custodian.
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
OTHER COMPENSATION
We do not receive any other compensation from a Third-Party Adviser for services
provided to our clients other than what is described under Items 4 and 5, above.
CLIENT REFERRALS
We do don’t pay for client referrals or use solicitors.
ITEM 15 – CUSTODY
All client funds, securities, and accounts are held by a third-party custodian, Altruist
Financial, LLC. We do not assume custody or take possession of your funds and securities.
However, you will be asked to authorize us to instruct the custodian to deduct our
management fee from your account. This written authorization will apply to our
management fee only. This is considered a limited form of custody. You may terminate
this authorization at any time by contacting us. You will receive at least quarterly account
statements from the custodian that holds and maintains your assets. Additionally, when
deducting management fees for clients that reside in California; each time a fee is
deducted from your account, we will send the qualified custodian an invoice or statement
of the amount of the fee to be deducted from your account. We will also send you an
invoice or statement itemizing the fee. Itemization includes the formula used to calculate
the fee, the value of the assets under management on which the fee is based, and the time
period covered by the fee. We urge you to carefully review and compare these account
statements with invoices and/or reports you receive from us.
ITEM 16 – INVESTMENT DISCRETION
We provide discretionary investment management services. To grant us discretionary
power over your account, you must sign the investment management agreement. Our
investment management agreement contains a limited power of attorney that allows us
to select the securities, the amount, and the time of purchase or sale in your account. It
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also allows us to place each trade without your prior approval. In addition to our
investment management agreement, your custodian may request that you sign the
custodian’s limited power of attorney with you prior to their execution. In all cases,
however, our discretion will be exercised in a manner consistent with he stated investment
objectives for your account and any other investment policies, limitations, or restrictions.
ITEM 17 – VOTING CLIENT SECURITIES
We do not vote proxy votes for any client. All proxy materials are mailed or emailed
directly to the client from the custodian. Any proxy materials received by us will be
forwarded to clients for response and voting. In the event the client has a question about
a proxy solicitation, the client should feel free to contact us.
ITEM 18 – FINANCIAL INFORMATION
BALANCE SHEET
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 provide a balance sheet.
FINANCIAL CONDITION
We are required in this Item to provide you with certain financial information or
disclosures about our financial condition if we have a financial commitment that impairs
our ability to service you. We do not have a financial commitment that impairs our ability
to service you.
BANKRUPTCY
We have not been the subject of a bankruptcy proceeding
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