Abri LLC

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 MAY 14, 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. Additional information about ABRI LLC is available on 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. Page 1 ADV Part 2A – 5/14/2026  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 have no additional material changes to report. Page 2 ADV Part 2A – 5/14/2026  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 .............................................................................................................................. 4 ITEM 5 – FEES AND COMPENSATION ..................................................................................................................... 7 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .................................................................... 9 ITEM 7 – TYPES OF CLIENTS ............................................................................................................................... 10 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS .......................................................... 10 ITEM 9 – DISCIPLINARY INFORMATION ................................................................................................................. 12 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ...................................................................... 12 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTION AND PERSONAL TRADING .................. 13 ITEM 12 – BROKERAGE PRACTICES ...................................................................................................................... 13 ITEM 13 – REVIEW OF ACCOUNTS ...................................................................................................................... 14 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................................................... 15 ITEM 15 – CUSTODY ........................................................................................................................................ 15 ITEM 16 – INVESTMENT DISCRETION ................................................................................................................... 15 ITEM 17 – VOTING CLIENT SECURITIES ................................................................................................................ 16 ITEM 18 – FINANCIAL INFORMATION ................................................................................................................... 16 Page 3 ADV Part 2A – 5/14/2026  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 We provide financial planning on an ongoing basis 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. Our business owner and personal financial planning services include the following topics and an estimated maximum allotted hours for each service that may vary depending on your individual circumstances:   Financial Planning (16 hours per year) – 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 (8 hours per year) – 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 (4 hours per year) – We analyze your health insurance options, what makes the most sense, asset allocation on the 401k, disability insurance review. Insurance Policy Review (4 hours per year) – 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 (8 hours per year) – 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 Attorneys but can help coordinate conversations with legal experts in regard to your planning and goals.  Cash Flow Management (8 hours per year) – We advise on cash accounts, financial obligations, and cash management. Tax consequences and their implications are also identified and evaluated. Page 4 ADV Part 2A – 5/14/2026   Education Planning, Repayment and Funding (4 hours per year) – 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 (4 hours per year) – 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 (16 hours per year) – 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. education, of professionals and  Divorce Financial Planning (one time service) – We assist in divorce process and planning education, document and family balance sheet organization, income planning, alimony budgeting, QDRO child coordination support/maintenance. The estimated number of hours allotted for each service above may vary depending on your individual circumstances. We also assist with federal and state tax preparation and filing. This is an additional service to our basic ongoing financial planning services. The service includes:  (10) Tax Forecasting & Preparation, Bookkeeping, Payroll – 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; transaction-level bookkeeping; reconciliation of accounts; payroll set up, processing, and compliance; and ongoing support related to tax and account 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. Portfolio management services are offered to our individual clients in addition to our basic ongoing financial planning 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. Page 5 ADV Part 2A – 5/14/2026  OTHER ADVISORY SERVICES 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 where you may receive a written financial plan. Upon delivery of the plan, this engagement is concluded. At your request, further reviews may be carried out in another contractual agreement. 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 int eh 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. 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 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 Page 6 ADV Part 2A – 5/14/2026  and fee schedules at the time of the referral. Currently there are no existing arrangements with a third-party investment adviser. 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 ADVISORY SERVICES OFFERED TO INDIVIDUALS Ongoing financial planning services are charged a monthly rate for continuous planning and strategy updates. The monthly rate ranges between $300 to $5000 per month depending on the complexity and chosen topics described above. The fees are collected at the end of each month and based on the time spent for the chosen topics covered during the year then charged to you in monthly increments (number of hours multiplied by the hourly rate (i.e., $500) divided by 12 months). Fees are negotiable and may be higher or lower depending on the complexity of planning or additional services required but will be agreed upon in advance at engagement. We will review your financial planning contract annually and if the service topics change or our estimation of the time required to perform the requested services change, we will adjust the fee as necessary and enter a new annual contract for the subsequent year(s). Any unearned fees for work not performed during the year, you will receive a prorated refund. Fees may be paid via ACH, debit or credit card, or from an account managed by us. If there are no financial planning services provided to you during the month, we will notify you that we provided no services, and you will not be charged during that month. Our annual management fee for stand-alone portfolio management is based on the following fee schedule: Assets Under Management Annual Fee % $0-$500,000 1.50% $500,000-$1,000,000 1.25% $1,000,000-$3,000,000 1.00% Page 7 ADV Part 2A – 5/14/2026  $3,000,000+ .80% Portfolio 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. 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. When we include portfolio management services to our ongoing financial planning management, we charge a discounted annual fee based on a percentage of assets under management in your accounts in addition to our financial planning fee. The annual management fee is 0.60% and is negotiable. One-time financial planning projects will be charged a planning fee ranging from $2,000 to $25,000 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 the delivery of the plan or service. 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 Page 8 ADV Part 2A – 5/14/2026  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). 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 portfolio 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 Base financial planning and financial consulting services, if cancelled you will not be charged a planning fee for work performed; as a result, completed portions of any documents will not be delivered. 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. 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. Page 9 ADV Part 2A – 5/14/2026  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 portfolio management services, we utilize individualized asset allocation, Strategic Asset Allocation and Modern Portfolio Theory as our investment strategies for your account(s). 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. The asset classes typically 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 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, Page 10 ADV Part 2A – 5/14/2026  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.  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 Page 11 ADV Part 2A – 5/14/2026  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. 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 ABRI FI 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 ABRI FI 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 Page 12 ADV Part 2A – 5/14/2026  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 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 Page 13 ADV Part 2A – 5/14/2026  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 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). Page 14 ADV Part 2A – 5/14/2026  REPORTS Financial planning services include a written 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. 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 Page 15 ADV Part 2A – 5/14/2026  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 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 $500 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. Page 16 ADV Part 2A – 5/14/2026