ACP INVESTMENT MANAGEMENT

Item 1: Cover Page ADV Part 2A of Form ADV Investment Adviser Brochure ACP Investment Management 75-170 Hualalai Rd, Suite C209 Kailua-Kona, HI 96740 April 2026 This Form ADV Part 2A (“Brochure”) provides information about Advisor Compliance Partners, LLC doing business as ACP Investment Management and its business for the use of clients and prospective clients. If you have any questions about the contents of this Brochure, please contact our Chief Compliance Officer at (877) 775-7475 or andre@advisorcp.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority and does not imply any certain level of skill or training. Additional information about our firm is available on the SEC’s website at: www.adviserinfo.sec.gov.  Item 2. Material Changes ACP Investment Management is required to advise clients and prospective clients of any material changes to our Firm Brochure (“brochure”) from our last annual update. Our first annual update was this year in January 2026. We have the following material changes from our initial filing in October 2025:  Item 5: Fees and Compensation. We updated this item to clarify that your fee and how that fee is calculated is determined by your investment advisory representative Our fee calculations will be calculated as a single flat fee or calculated based on a tiered fee schedule. Your fee and how it is calculated will always be detailed in the signed written agreement between you and ACP. Clients will receive an annual summary of any material changes to this and subsequent brochures no later than 120 days after our fiscal year end of December 31. At that time, we will offer a copy of our most current brochure. We will also promptly provide ongoing disclosure information about material changes, as necessary. Item 3. Table of Contents Item 1: Cover Page .........................................................................................................................................1 Item 2. Material Changes ...............................................................................................................................2 Item 3. Table of Contents ...............................................................................................................................2 Item 4. Advisory Business ..............................................................................................................................3 Item 5. Fees & Compensation ........................................................................................................................7 Item 6. Performance-Based Fees & Side-By-Side Management ..................................................................10 Item 7. Types of Clients & Account Requirements ......................................................................................10 Item 8. Methods of Analysis, Investment Strategies & Risk of Loss ............................................................11 Item 9. Disciplinary Information ..................................................................................................................18 Item 10. Other Financial Industry Activities & Affiliations ...........................................................................18 Item 11. Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading ...................19 Item 12. Brokerage Practices .......................................................................................................................19 Item 13. Review of Accounts........................................................................................................................23 Item 14. Client Referrals & Other Compensation ........................................................................................23 Item 15. Custody ..........................................................................................................................................24 Item 16. Investment Discretion ...................................................................................................................24 Item 17. Voting Client Securities ..................................................................................................................24 Item 18. Financial Information .....................................................................................................................24 Page | 2  Item 4. Advisory Business Firm Description Advisor Compliance Partners, LLC doing business as ACP Investment Management (‘we,” “us,” “our,” or “ACP”), a Wyoming limited liability company, was formed in August 2025. ACP is owned equally by two LLCs: ACP Equity LLC, which is owned 100% by Adam Reugh, and EAL Holdings LLC, which is owned 100% by André Lister. Types of Advisory Services We offer investment management, hourly consulting, financial planning and consultations, and pension consulting services. Individual IARs offer investment advice to clients utilizing some or all of these services. Asset Management As part of our asset management services, we create a portfolio for each client, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and/or other public and private securities or investments. The client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable for the client’s circumstances. Once the appropriate portfolio has been determined, we continually monitor the portfolio and, if necessary, rebalance the portfolio based upon the client’s individual needs, stated goals and objectives. Clients may place reasonable restrictions on the types of investments to be held in the portfolio. In designing an investment portfolio for a client, we may work with a third-party money manager, also an investment adviser, who is independent of ACP. When we work with third-party money managers, we utilize that money manager’s experience and strategies, helping to develop a suitable portfolio for each client. We conduct initial and ongoing due diligence on any money manager utilized. We also have discretionary authority to add and remove money managers within your investment portfolio. Strategic Wealth Management (SWM) through LPL We offer a comprehensive, open-architecture, fee-based investment platform, through LPL Financial LLC’s (“LPL”) Strategic Wealth Management (SWM), to clients. Through this platform, clients can consolidate multiple investments into one account and receive one statement. There is no minimum account size required for utilizing the SWM platform. In the SWM program we use for our clients, clients pay their own transaction costs. More detailed information about the benefits and costs of SWM can be found in Item 5 below. Wrap Fee Programs Sponsored by LPL Some of our IARs are also registered with LPL, an unaffiliated registered investment adviser and broker- dealer. We offer advisory services through certain programs sponsored by LPL under a wrap fee program. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of Page | 3  interest presented by the programs, please see the LPL Form ADV 2A, LPL wrap fee brochure for the specific program, and applicable client agreement. Any LPL-sponsored advisory program becomes effective only when an authorized representative of ACP has accepted the applicable paperwork and client agreement in writing. For all of the LPL-sponsored advisory programs that we offer, LPL serves as program sponsor, investment adviser and broker-dealer. ACP also acts as investment adviser for these programs and will share in the management fees and may share in other fees associated with these accounts. When using LPL wrap programs, ACP retains discretionary authority to select individual investments within the programs but does not have discretionary authority to select new programs or to terminate existing programs. Selection of a new wrap program would require new paperwork and client authorization. Financial Planning and Other Consulting Services We offer consulting services, including financial planning. Financial planning services are based on an analysis of the client’s current financial circumstances, goals and objectives. Typically, financial planning and consulting services involve a process of information gathering by the IAR, analysis of the client’s needs or goals, then preparation of a financial plan or other written report. Financial planning services or hourly consulting services generally include analysis or discussion in one or more of the following areas:  Charitable Planning  Education Planning  Mortgage/Debt Analysis  Insurance Analysis  Lines of Credit Evaluation  Business and Personal Financial Planning Clients enter into an agreement for financial planning and other consulting services. These services vary depending on each client’s needs but may include any of the above-listed services. We do not offer legal advice or accounting advice, and we refer clients to an accountant, attorney or other specialist as necessary for non-advisory-related services. Generally, financial planning services are based on an analysis of the client’s current financial circumstances, goals and objectives. This involves a process of information gathering by the IAR, then preparation of a financial plan or other written report. Specifically, comprehensive financial planning will address one or more of the six key areas of financial planning:  Financial Position  Protection Planning  Investment Planning  Corporate and Personal Income Tax Planning  Retirement Planning  Estate Planning We will provide a written summary for our comprehensive financial planning services. Page | 4  Our financial planning and consulting services typically include general recommendations for a course of activity, or specific actions to be taken by the clients. For example, recommendations may be made that the clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. Financials plans or consultations are typically completed within six months of a client signing a contract with us. Implementation of the recommendations will be at the discretion of the client. We offer more limited planning or consulting services on an hourly basis. Examples of these services include annual updates to financial plans, consulting on an individual issue, or acting as a third-party reviewer. Such hourly services do not typically conclude with a written summary and the process is much less formal than our comprehensive services. Implementation of any of our planning or consulting recommendations at the client’s discretion. Clients are also free to implement recommendations away from our firm, through a broker, agent, or advisory representative that is not affiliated with ACP. Retirement Plan Consulting We provide consulting and advisory services for employer-sponsored retirement plans that are designed to assist plan sponsors of employee benefit plans (“Sponsor”). These services are offered to the Sponsors on a one-time or ongoing basis. Generally, such pension consulting services consist of assisting the Sponsor in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the Sponsor dictate, areas of advising could include, but are not limited to, investment options, plan structure and participant education. Where we offer plan participants the option of using our Participant Advisory Services for discretionary investment management services, we’ll enter into a separate agreement with that participant, describing our services and fees for that service. We also ask that the participant provide information that will help us understand their investment objectives. In providing this service, we are deemed to be a fiduciary and investment manager as defined in ERISA Section 3(38). All pension consulting services will comply with the applicable state law(s) regulating pension consulting services. This applies to client accounts that are pension or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and we accept appointments to provide our services to such accounts, we acknowledge our fiduciary role within the meaning of Section 3(21) of ERISA, but only with respect to the provision of services described in the Services section of the Investment Fiduciary & Retirement Plan Consulting Agreement (“RPAC”). When providing any ERISA fiduciary services, we will solely be making recommendations to the Sponsor and the Sponsor retains full discretionary authority and/or control over the assets. When entering into an RPAC agreement, the Plan Sponsor may select from a number of different services described below. With the exception of Participant Advisory Services, ACP will be acting in a non- discretionary capacity and will solely be making recommendations to the Plan Sponsor. ACP will not perform recordkeeping or brokerage services to the Plan. Neither ACP nor the IAR will assume the duties Page | 5  of a trustee or a Plan Administrator, as defined in ERISA Sec. 3(16). Services offered under an RPAC agreement are described below. Retirement Plan Services: Plan-Level  Recommendations to establish or revise the Plan’s Investment Policy Statement (“IPS”),  Recommendations to select and monitor the Designated Investment Alternatives (“DIAs”),  Recommendations to select and monitor Qualified Default Investment Alternatives (“QDIAs”)  Recommendation to select and monitor other investment managers Retirement Plan Services: Participant Level   IAR will meet with Plan Participants periodically, or upon reasonable request, to collect information necessary to provide individual participants with investment advice and related services regarding the investment options available under the Plan. IAR will manage the Participant’s account on a discretionary basis. Retirement Plan Consulting Services  Administrative Support  Assist Plan Sponsor in reviewing objectives and options through the Plan o Review of Plan committee structure and administrative policies & procedures o Recommend participant education and communications policies under ERISA 404(c) o Assist with development/maintenance of fiduciary audit file and document retention policies o Deliver fiduciary training and/or education periodically or upon reasonable request. o Coordinate and reconcile participant disclosures under 404(a)(5) o Develop requirements for responding to participant requests  Oversight of Relationship with Service Provider o Assist with process to select, monitor and replace service providers o Assist with review of Covered Service Providers (CSP) disclosures under ERISA 408(b)(2) and fee benchmarking o Provide reports and/or information designed to assist with monitoring CSPs o Review ERISA Spending Accounts or Plan Expense Recapture Accounts o Assist with preparation and review of Request for Proposals (RFPs) and/or Request for Information (RFIs) o Coordinate and assist with CSP replacement and conversion  Investments o Periodic review of investment policy in context of Plan objectives o Assist Plan committee with monitoring investment performance o Provide analysis of investment managers and model portfolios o Review and recommend Designated Investment Managers and/or third-party advice providers as necessary o Educate Plan committee members, as needed, regarding replacement of DIA(s) and/or QDIA(s)  Participant Services o Facilitate group enrollment meetings o Coordinate employee education regarding Plan investments and fees Page | 6  o Assist Plan participants in understanding Plan benefits, retirement readiness and impact of increasing deferrals. Important Information for Retirement Investors When we recommend that you roll over retirement assets or transfer existing retirement assets (such as a 401(k) or an IRA) to our management, we have a conflict of interest. This is because we will generally earn additional revenue when we manage more assets. In making the recommendation, however, we do so only after determining that the recommendation is in your best interest. Further, in making any recommendation to transfer or rollover retirement assets, we do so as a “fiduciary,” as that term is defined in ERISA or the Internal Revenue Code, or both. We also acknowledge we are a fiduciary under ERISA or the Internal Revenue Code with respect to our ongoing investment advisory recommendations and discretionary asset management services, as described in the advisory agreement we execute with you. To the extent we provide non-fiduciary services to you, those will be described in the advisory agreement. Participation in Wrap Fee Programs While we do not sponsor wrap fee programs, we recommend LPL wrap fee programs. This is discussed above in the sections above titled LPL Sponsored Wrap Fee Programs. Assets Under Management As of December 31, 2025, we had assets under management of $131,872,386, all managed on a discretionary basis. Item 5. Fees & Compensation We charge on-going fees based on a percentage of assets under management, on an hourly basis, or on a flat fee basis. Depending on the wishes and needs of the client, we may provide different investment advisory services and charge the client in multiple ways. Based on the maximum fees described below, your fees will be determined by the IAR you work with; All fees are subject to negotiation at the sole discretion of your IAR. The circumstances and details of each of these options are described below. Asset Management Services Our fees are billed on a pro-rata annualized basis quarterly in advance based on the value of your account on the last day of the previous quarter. Our maximum annual fee is 2.0%. How your fee is calculated will vary depending on what your IAR has determined and agreed with you. Our fee calculations will be calculated as a single flat fee or calculated on a tiered fee schedule. Your fee and how it is calculated will always be detailed in the signed written agreement between you and ACP. Your IAR will use the following fee schedule as a guideline to determine the annual fee you will pay. Assets Under Management $0 to $500,000 $500,001 to $1,000,000 $1,000,001 to $3,000,000 $3,000,001 to $10,000,000 Above $10,000,000 Annual Fee 2.00% 1.75% 1.50% 1.00% 0.50% Fees are automatically deducted from your account and paid to us by your qualified custodian. Page | 7  When we receive new assets or new accounts, fees for portfolio management services will be prorated accordingly for that quarter’s billing cycle. Financial Planning and Consulting Services We charge on an hourly or flat fee basis for Financial Planning and Consulting services. We charge no more than $500 per hour. Our hourly fee varies depending on the IAR who performs the services, the complexity of the services provided, and the typical market rate. Flat fees vary greatly and could range from a minimum of $500 to a maximum of $20,000. The total estimated fee, as well as the ultimate fee that we charge you, is determined by both the time estimated to adequately prepare the plan and the complexity of the scope of our engagement with you. Our financial planning and consulting services may be charged in advance, but are more often charged once services are completed. Advance may be requested for a particularly complex plan or consulting engagement. We will not collect more than $1,200 in advance of the service provided, unless services are completed within six months of our receipt of the fees. Should we collect fees more than hours ultimately expended, or otherwise not completed the project, we will return any unearned amounts collected. The total fee or balance due will be billed directly to you and due to us within thirty (30) days of your financial plan being completed or consultation rendered to you. Retirement Plan Consulting Fiduciary Services – Plan Level: Due to the wide variance in complexity and scope of our work with Retirement Plan sponsors, as well as the requirements of Plan service providers, the method of billing and amount of fees charged for these services is negotiable. We offer two different billing options for Plan Sponsors at the Plan Level:  Pay an asset-based fee of a percentage of the Plan assets, payable quarterly.  Pay an annual flat fee, payable quarterly or in one lump sum on a specific date agreed to between Sponsor and ACP. By default, our billing frequency is quarterly in arrears, but the Plan Sponsor can choose advance fee billing with any unearned fees to be refunded. The Plan Sponsor may choose whether to pay the fees from plan assets or from the Sponsor directly. Also, depending on a Plan’s third-party payor support, we offer an option for direct billing. Fees for Retirement Plan Consulting services are fully negotiable between the ACP IAR and the Plan Sponsor, but at no time will they be greater than 1% of total plan assets. Fiduciary Services – Participant Level We may provide advice to plan participants through a separate agreement outside of the plan sponsor’s agreement. The advisory fees charged to the participant will be negotiated depending on whether the assets being managed are on a non-discretionary basis through the plan sponsor’s custodian or if they are self-directed assets held away from the plan sponsor’s custodian and managed on a discretionary basis. Page | 8  Termination of Services Clients may terminate our services at any time by providing written notice to us. Our services will also terminate if the client revokes our trading authority through their custodian or if they transfer assets away from our management. Once our services are terminated, we are no longer managing the account, and fees will no longer be earned. Any paid but unearned fees will be promptly refunded to the client. The unearned portion of fees will be determined by the number of days left in the quarter as a percentage of the total number of days in a quarter. Other Fees All fees paid to ACP are separate and distinct from the fees and expenses charged by third parties. In addition to our advisory fees, clients are responsible for other fees and expenses in their account including mutual fund fees, brokerage commissions, stock transfer fees, retirement account fees, and other similar charges incurred in connection with your custodian holding your account and executing transactions in your account. Mutual fund fees will generally include a management fee and other expenses. If the fund also imposes a sales charge, a client could pay an initial or deferred sales charge. Please refer to the section below on Brokerage Practices for further discussion on broker-dealer/custodial costs. If we execute transactions away from your chosen broker-dealer/custodian, we will attempt to negotiate commissions equal to or less than what you would pay had we executed such transactions at your custodian. We may instead capture cost savings in execution price rather than the transaction cost directly. We will only execute transactions at another broker-dealer/custodian if we believe it in your best interest and in line with our best execution obligations. Outside Compensation Some of our IARs are also registered representatives with LPL Financial LLC, a member of FINRA and SIPC, is a full-service securities broker-dealer and investment adviser. When our IARs act as registered representatives, compensation is generated through the sale of securities or other investment products, including distribution or service (“trail”) fees from the sale of mutual funds. Dual registration as representatives of a broker-dealer and an investment advisor presents a conflict of interest and gives the representative an incentive to recommend investment products based on the compensation received, rather than on the client’s needs. We do not permit our IARs to earn commissions or trails on transactions or assets held in advisory accounts. However, if a client establishes both an advisory account (advised by ACP) and a brokerage account (where the IAR also functions as a registered representative and could receive transaction-based compensation, as well as 12b-1 fees), the client and the IAR will establish the types of transactions that will be made in each account. ACP, its IARs and its affiliates do not receive 12b- 1 fees. Transactions in LPL sponsored wrap fee program accounts are effected through LPL as the executing broker-dealer. We receive advisory compensation as a result of a client’s participation in an LPL wrap fee program. Depending on, among other things, the size of the account, changes in its value over time, the ability to negotiate fees or commissions, and the number of transactions, the amount of this compensation may be more or less than what we would receive if the client participated in other programs, whether through LPL or another vendor, or paid separately for investment advice, brokerage and other services. Page | 9  Our management and our IARs may also be licensed insurance agents through various insurance companies or own their own independent insurance agencies, unaffiliated with ACP. In such a capacity, they may offer insurance products and will receive normal and customary commissions as a result of such purchases. We want you to be aware that the practice of accepting commissions for the sale of securities or other investment products presents a conflict of interest and gives an incentive to our IARs to recommend investment products based on the compensation received, rather than on your needs. We try to address these conflicts by clearly explaining this conflict to clients and, specifically, when recommending mutual funds with a “load,” or commission, that “no-load” funds are also available through our firm for investment advisory clients. You are not required to purchase investment products we recommend to you. You are also able to purchase investment products we recommend to you through another broker or agent that is not affiliated with us. ACP has taken steps to minimize the conflict of interest associated with commissionable mutual funds a dually-registered representative could offer, including by providing our IARs with tools, training and guidance on this issue, as well as by conducting periodic reviews of client holdings in mutual fund investments to ensure the appropriateness of mutual fund share class selections and whether alternative mutual fund share class selections are available that might be more appropriate given the client’s particularized investment objectives and any other appropriate considerations relevant to mutual fund share class selection. ACP has no affiliation with LPL either through ownership or control; however, as a participant in LPL’s hybrid investment adviser program, they provide us with certain benefits and resources. Some of these benefits include access to its custodial services, compliance assistance, training, administrative and back- office support, investment programs, and third-party managers. Item 6. Performance-Based Fees & Side-By-Side Management We do not charge advisory fees based on a share of the capital appreciation of funds or securities in client’s accounts and this Item is not applicable to our business. Item 7. Types of Clients & Account Requirements We provide services to the following types of clients: Individual and high net worth individuals   Pension and profit-sharing plans  Pooled investment vehicles  Charitable organizations  Corporations ACP does not have a minimum account size. However, some of the LPL-sponsored programs we recommend have minimums. The brochure for the specific program will detail such minimums. Page | 10  Item 8. Methods of Analysis, Investment Strategies & Risk of Loss Methods of Analysis and Investment Strategies Our IARs work independently from one another and employ varying philosophies, strategies, and tools in their investment analysis and due diligence processes. Any of our IARs could utilize the following methods of analysis and strategies:  Fundamental  Technical  Quantitative  Qualitative Our IARs apply generally accepted investment theories so that investment choices for clients align with the client’s investment needs and objectives and are made with the goal to reasonably diversify client assets to help minimize the risk of large losses and to provide the potential for varying degrees of long- term appreciation and capital preservation. We generally use a mix of equity and fixed income exposures to meet the risk-based categories identified in the client’s risk profile. IARs will diversify, reallocate and rebalance the investments and associated risk levels over time in accordance with generally accepted investment theories and consistent with the client’s risk profile. IARs may make recommendations for changes to the underlying investments and/or the asset allocation percentages of any Model Portfolios as well. In the implementation of their analysis, our IARs use some or all of the following strategies at any given time:  Long Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year.  Short Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short-term price fluctuations. Short-term gains in taxable accounts are subject to federal income tax at higher rates than long-term gains. This difference in tax treatment is a disadvantage of short- term trades for taxable clients.  Trading – IARs may use short-term trades (in general, selling securities within 30 days of purchasing the same securities) when managing your account(s). An IAR may sell a security soon after purchasing it on occasions when they determine that there is a reasonable basis for the sale and it is suitable given a client’s stated investment objectives and tolerance for risk. Short-term gains in taxable accounts are subject to federal income tax at higher rates than long-term gains, while losses realized on securities held 30 days or less are generally not tax deductible. These differences in tax treatment are disadvantages of short-term trades for taxable clients. There is also risk in that high-velocity trading creates substantial transactions costs that in aggregate could negatively impact account performance.  Short Sales – securities transactions in which an investor sells securities he or she borrowed in anticipation of a price decline. The investor is then required to return an equal number of shares at some point in the future. A short seller will profit if the stock goes down in price. The risk associated with a short sale is the potential of unlimited loss should the underlying value of the short position increase in value instead of the anticipated decline. Another risk is buy-in risk. Once Page | 11  borrowed, the shares are subject to buy-in at any time, which could force the client to cover the short position at a disadvantageous time or price. Short sales require the use of margin, which may increase cost and risk. Additional costs include interest on the value of borrowed securities. Risks also include additional margin calls in response to market fluctuations or at the discretion of the custodian.  Margin Transactions – a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. This allows the client to purchase more stock than they would otherwise be able to, based on the account’s available cash, and would allow the IAR to purchase stock without selling other holdings, which is therefore a higher risk strategy. Securities purchased on margin are subject to liquidation, additional margin calls, and interest on the funds borrowed. Should the value of the securities decline, clients may be forced to deposit additional margin with limited notice, or to liquidate their securities at substantial losses.  Option Purchases and Option Writing – Purchasing a long option gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price before the expiration date of the option. When an investor writes (or sells) an option, he or she is obligated to deliver to the buyer of the option a specified number of shares (or the calculated money difference) if the buyer exercises the option. ACP does not generally permit uncovered option writing in advisory accounts. The seller receives a premium in exchange for writing the option. Options are wasting assets and expire at pre-determined dates. Commission charges for options transactions may be higher than the charges assessed for other assets, such as individual equities. Risk of Loss All investing involves risks that clients must be prepared to bear. While losses can and will occur, we generally recommend a broad and diversified allocation of mutual funds and ETFs, thereby reducing specific risks associated with a concentrated or undiversified portfolio. Below are some of the risks present with investing generally, as well as some key risks of different types of investments. In general, investing in securities with concentrated exposures to (i) particular asset class(es) and/or (ii) a particular sector and/or (iii) one or a select few markets involves greater risk than investing in investments that have greater diversification. Alternative Strategies: We may occasionally recommend mutual funds or ETFs that invest primarily in alternative investments and/or strategies. Investing in these products is not suitable for all investors and involves special risks, such as those associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. There are special risks associated with funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. Asset Allocation Risk: The primary risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the proportions of different asset types will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Page | 12  Call Risk: Bonds or other fixed income securities, as well as some structured notes, that are callable carry an additional risk because they may be called prior to maturity depending on current interest rates. Calls increase the likelihood of reinvestment risk. Concentrated Stock Risk: Investors may hold a large amount of their overall wealth in one security. This creates additional volatility as single stocks generally have more volatility than a basket of stocks. Investors may hold concentrated stock positions for a number of reasons such as regulatory restrictions or tax implications. Regardless of the reason, concentrating wealth into one position creates additional volatility both positively and negatively. Counterparty Risk: This is the risk that the other party to a contract will not fulfill its contractual obligations. Clients investing in debt instruments and in structured products are typically exposed to greater counterparty risk than investors in liquid equities, for example. Credit Risk: This is the risk that an issuer will default in the payment of principal and/or interest on a security. The price of a bond depends on the issuer’s credit rating, or perceived ability to pay its debt obligations. Consequently, increases in an issuer’s credit risk may negatively impact the value of a bond or structured note investment. This is a risk of all fixed-income investments, as well as structured notes we recommend. Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange-rate risk. Cybersecurity Risk: Cloud-based data platforms connected to the internet which contain personal identifiable information may be acquired through online threats by outsiders and may be used to fraudulently transfer or steal assets. We utilize strong internal controls around cybersecurity and conduct due diligence with prospective and existing vendors; however, the potential for cybersecurity incidents is real in today's cyber environment even with effective controls in place. Diversification Risk: The chance an investment’s performance may be hurt disproportionately by the poor performance of an investment’s holdings – the use of indexed funds is not guaranteed to track an intended market and may carry additional product risks. Environmental, Social, Governance (“ESG”) Risk: Corporate governance practices, the risks of environmental damage or disasters (whether connected to an issuer’s own practices or independent of them, such as extreme weather events), and the risks of social factors, such as racial and gender discrimination, are wide-ranging and increasingly understood to affect investment decisions and results. We do not generally invest with an eye toward ESG factors on their own merit, but rather because these factors can affect the financial performance of in turn, the performance of those companies’ securities. We may companies and, include ESG factors we believe are important in evaluating companies, based on the industry, the company itself, and emerging consensus on areas that generally merit attention. ESG factors are in many ways subjective. We may not identify all applicable ESG concerns, and our subjective judgment of the most important factors may be incorrect. Further, in evaluating these issues, we must often rely on corporate self-reporting, which is inherently biased. Third-parting ratings and reports are increasingly available, though they are, to varying degrees, subject to the same limitations with respect to subjective judgment and reliance on corporate self-reporting. Page | 13  Equity Risk: Prices of common stock react to the economic conditions of the company that issued the security; industry and market conditions; as well as other factors, and may fluctuate widely. Investments related to the value of stocks may rise and fall based on an issuer’s actual and anticipated earnings, changes in management, the potential for takeovers and acquisitions, and other economic factors. Similarly, the value of other equity-related securities, including preferred stock, warrants and options may also vary widely. Market conditions may affect certain types of stocks (such as large-cap or technology-related) to a greater extent than other types of stocks. If the stock market declines, the value of a portfolio will also likely decline and, although stock values can rebound, there is no assurance that values will return to previous levels. Exchange-Traded Funds: Exchange-traded funds (“ETFs”) are funds bought and sold on a securities exchange that attempt to track the performance of a specific index (such as the S&P 500), a commodity, or a basket of assets (such as a set of technology-focused, country-specific, or other sector-specific stocks). The risks of owning an ETF generally reflect the risks of owning the underlying securities they are designed to track, although lack of liquidity in an ETF could result in its being more volatile than the underlying securities. ETFs have management fees that increase their costs. ETFs are also subject to other risks, including: the risk that their prices may not correlate perfectly with changes in the underlying index (tracking error); the risk that the ETF will trade at prices that differ, sometimes materially, from the ETF’s net asset value; and illiquidity risk, especially for narrowly-focused ETFs, including the risk of possible trading halts due. Exchange Traded Notes (ETN’s): An ETN is a bond issued by a financial institution. That company promises to pay ETN holders the return on some index over a certain period of time and return the principal of the investment at maturity. However, if something happens to that company (such as bankruptcy) and it's unable to make good on its promise to pay, ETN holders could be left with a worthless investment or an investment that is worth much less (just like anyone who had lent the company money). Specifically:  Credit risk: ETNs rely on the creditworthiness of their issuers, just like unsecured bonds. If the issuer defaults, an ETN’s investors may receive only pennies on the dollar or nothing at all, and investors should remember that credit risk can change quickly.  Liquidity risk: The trading activity of ETNs varies widely. For ETNs with very low trading  activity, bid-ask spreads can be exceptionally wide. Issuance risk (aka volatile premiums): The supply of ETNs are controlled entirely by their issuers. If the issuer decided to stop issuing new shares of the ETN, it's possible the demand for the ETN could exceed the supply available and the note's price could increase by much more than its indicated value. If they were to again re-issue new shares, the ETN's price could dive dramatically.  Closure risk: There are multiple ways for an issuer to effectively close an ETN. An issuer may call the note (also known as “accelerated redemption”) by returning the value of the note less fees. However, not all ETNs have terms which allow for accelerated redemption. The alternative is for issuers to delist the note from national exchanges and suspend new issuance. When this happens, ETN investors are left with two choices. They can either hold the note until it matures, which could be years away, or trade the ETN in the over-the- counter (OTC) market where spreads can be even wider than on national exchanges. Page | 14  Extraordinary Events: Global terrorist activity and armed conflicts may negatively affect general economic conditions, including sales, profits and productions, and may materially affect prices and/or impair our trading facilities and infrastructure or the trading facilities and infrastructure of our custodians, counterparties or the exchanges or markets on which we (they) trade. Fixed Income Risk: Prices of fixed income instruments (e.g., bonds) can exhibit some volatility and change daily. Investments in fixed income instruments present numerous risks, including credit, interest rate, reinvestment and prepayment risk, all of which affect the price of the instruments. For instance, a rise in interest rates will generally cause the price of bonds to go down. If the security is held to maturity and the issuer does not default, the client should receive the face amount of the bond at the maturity date, as well as stated interest payments while the bond is held. In this case, the change in price prior to maturity may not affect the client. If the client needs to sell prior to maturity, however, the investor will likely experience a loss. Where a client’s fixed income exposure is to bond funds or fixed-income ETFs, the fund or ETF does not itself “mature,” although different issues held by the fund/ETF will mature and will experience price fluctuations. Investors are therefore highly dependent on the manager’s ability to accurately anticipate the impact of rate changes and to appropriately manage the portfolio to achieve both adequate returns and reasonable risk. Increases in the prevailing interest rates could have a material negative impact on the value of current fixed income holdings. In addition, the value of fixed income instruments may decline in response to events affecting the issuer, its credit rating or any underlying assets backing the instruments. Foreign Market Risk: The securities markets of many foreign countries, including emerging countries, have substantially less trading volume than the securities markets of the United States, and securities of some foreign companies are less liquid and more volatile than securities of comparable United States companies. As a result, foreign securities markets may be subject to greater influence by adverse events generally affecting the market, by large investors’ trading significant blocks of securities, or by large dispositions of securities, than as it is in the United States. Further, many foreign governments are less stable than that of the United States. There can be no assurance that any significant, sustained instability would not increase the risks of investing in the securities markets of certain countries. Hedge Fund and Other Private Fund Investment Risks: Some private funds are exempt from SEC registration and only available to institutions and “accredited” or “qualified” investors. Such investors are assumed to be sophisticated purchasers who have no need for liquidity and who are able to withstand the loss of some or all of their investment. Alternative Investment hedge fund or other private fund strategies are intended to further diversify investor holdings and are not considered a stand-alone investment program. Limitations on withdrawal rights and non- tradability of interests create higher liquidity risk and these investments should be viewed as long- term investments. Investors should not consider investing in private funds with less than a multiple-year time horizon. There may be no established market for interests, nor is it possible for one to develop as a result of legal restrictions. Partnership and fee expenses may be a higher percent of net assets than would be the case in other investment entities; performance or incentive fees may also be assessed in addition to management and administrative fees. Page | 15  Inflation Risk: When inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. This affects all investments, but longer-term fixed income securities are particularly susceptible. Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. This risk is especially significant for existing holdings. Longer-term fixed income securities are particularly susceptible to this risk. Legacy Holdings Risk: Securities that are brought to ACP which are not subsequently sold and fully diversified carry the potential for greater concentration and specific issuer risk in the portfolio that may result in more volatile results and a higher risk of loss than a fully diversified portfolio. Leverage Risk: Although firm does not typically employ leverage in the implementation of its investment strategies, leverage may be used for particular clients who have specific needs or more aggressive risk tolerance. More generally, some exchange-traded and closed-end funds, as well as some structured products, employ leverage. Leverage increases returns to investors if the investment strategy earns a greater return on leveraged investments than the strategy’s cost of such leverage. However, the use of leverage exposes investors to additional levels of risk and loss that could be substantial. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Certain instruments may have no readily available market or third-party pricing. Structured notes usually have a limited secondary market and are often relatively illiquid. Reduced liquidity may have an adverse impact on market price and the ability to sell particular securities when necessary to meet cash needs or in response to a specific economic event, such as the deterioration of creditworthiness of an issuer. Reduced liquidity in the secondary market for certain securities may also make it more difficult to obtain market quotations based on actual trades for the purpose of valuing the security. Clients should invest in structured notes, private securities, and other illiquid (or relatively illiquid) assets only to the extent they have adequate other liquid assets available to fund current and ongoing cash requirements. Market Risk: The price of any security, including ETFs, equities, bonds or mutual funds may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events. Mutual Funds: These are professionally-managed investments that pool money from multiple investors to purchase securities. Mutual funds may be broad-based (e.g., focused on the market overall, or focused on large-capitalization companies), or they can be more narrow in scope, such as those focused on the technology industry or the securities of specific country. The risks of mutual funds are generally connected to the risks of the underlying securities they hold. Mutual funds do not trade on an exchange but are priced daily based on the net asset value of the securities held in the fund. Investors buy or sell fund shares based on that end-of-day price. Page | 16  Private Equity and Venture Capital Risk: Because of the nature of the limited partnership structure partnership investments should be considered long term and illiquid. There are typically no secondary markets in which these types of investments trade. Therefore, if the value of the underlying assets should decline, the value of partnership shares would also decline and unlike other types of securities, an investor may find it hard to quickly sell shares in an illiquid market. Please refer to the fund offering documents and Private Placement Memorandums for specific information on the strategies, risks, and qualifications for investing in a particular private investment. Real Estate Risk: Real Estate Investment Trusts (“REITs”), although not a direct investment in real estate, are subject to the risks associated with investing in real estate. The value of these securities will rise and fall in response to many factors including economic conditions, the demand for rental property, and changes in interest rates. Regulatory Risk: The legal, tax, and regulatory environment worldwide in the financial industry is evolving, and changes in regulations affecting the financial industry, including the firm and the issues of financial instruments held in client accounts, may have a material adverse effect on our ability to pursue the investment strategies described in this brochure or the value of the instruments held in client accounts. There has been an increase in scrutiny of the financial industry by governmental agencies and self-regulatory organizations. Various national governments have expressed concern regarding the disruptive effects of speculative trading and the need to regulate the financial markets in general. New laws and regulations or actions taken by regulators that restrict our ability to pursue our investment strategies or conduct business with broker-dealers and other advisors or counterparties with whom we work could adversely affect client accounts. Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to bonds, notes, and similar securities. Sector Risk: the chance that significant problems will affect a particular sector, or that returns from that sector will trail returns from the overall market; and style risk (for example growth investing risk and mid-cap company risk). Small- and Mid-Cap Company Risk: Investments in small- and mid-cap companies may be riskier than investments in larger, more established companies. The securities of these companies may trade less frequently and in smaller volumes than securities of larger companies. Small- and mid- cap companies may be more vulnerable to economic, market, and industry changes. Speculation Risk: Commodities, some alternative investments, real estate, and other markets are populated by traders whose primary interest is in making short-term profits by speculating whether the price of a commodity or security will go up or go down. The speculative actions of these traders may increase market volatility that could drive down the prices of commodities or securities. Structured Instrument Risk: The price of structured instruments may be more volatile than other debt securities. Although structured instruments may be sold in the form of a corporate debt obligation, they may not have some of the protection against counterparty default that may be Page | 17  available with publicly traded debt securities. Issuers generally are not obligated to provide a secondary market for structured products that they issue; most universally do so in order to facilitate ongoing issuance. Generally, the issuer of a given structured note is the only available market maker. Even with exchange-listed structured notes there generally is limited market- making. Consequently, the issue is not the lack of a secondary market but rather the transparency and price, quality, and the credit worthiness of the underlying issuer of the product. The securities may not be principal protected, or only partially principal protected; there may be the possibility you will receive less at maturity than you originally invested. Systemic Risk: these are risks inherent to the entire market or market segment. Systemic risk is also known as “undiversifiable risk,” and affects the overall market, not just a particular stock or industry. This type of risk is both unpredictable and impossible to completely avoid. Item 9. Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm, or the integrity of our management. We have no information to disclose applicable to this Item. Item 10. Other Financial Industry Activities & Affiliations Neither ACP nor any of our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Neither ACP nor any of our management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading adviser, or an associated person of the foregoing entities. As discussed in Item 5 above, some of our IARs are registered representatives of LPL. When an IAR transacts securities business as a registered representative, the IAR will receive normal and customary commissions as a result of those securities transactions. This presents a conflict of interest to the extent that management and the IAR recommend that a client invest in a security which results in a commission being paid to him/her. Please refer to Item 12 for a discussion of the benefits registered representatives may receive from LPL and the conflicts of interest associated with receipt of such benefits. In addition, as a result of this relationship, LPL may have access to certain confidential information (e.g., financial information, investment objectives, transactions and holdings) about ACP’s clients, even if the client does not establish any account through LPL. If you would like a copy of the LPL privacy policy, please contact the CCO. Some of our IARs are insurance producers appointed with various insurance companies and some IARs are insurance producers running their own insurance agency. This presents a conflict of interest to the extent that the insurance producer has an incentive to recommend advisory clients purchase insurance products to earn a commission. However, our IARs will only recommend an insurance product when they believe the cost and value of the product are in the client’s best interest. Clients are under no obligation to act upon any recommendation or effect any transactions through the IAR/registered representative/agent if they decide to follow the recommendations made. Page | 18  Item 11. Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading To fulfill our responsibilities as a fiduciary, we have adopted a Code of Ethics (the “Code”). The Code incorporates the following general principles that all employees are expected to uphold: (1) putting the clients’ interest first at all times; (2) conducting all personal securities transactions in such a manner to be consistent with the Code and to avoid any actual or potential conflict of interest or any abuse of an employee’s position of trust and responsibility; (3) not taking inappropriate advantage of their position; (4) treating all client information as confidential, and (5) maintaining independence in the investment decision-making process. In addition to guidelines with regard to personal trading, the Code also addresses and governs the giving and receiving of gifts and entertainment, service on outside boards of directors and other outside business activities. Our personnel must periodically certify their compliance with the Code. Investments by ACP or its employees, for their own accounts, in securities that are also held in client accounts could give the impression of interfering with our fiduciary duty of making decisions which are in the best interests of clients and could otherwise have a disadvantageous effect on the values, prices or trading strategies of client portfolios. Our personal trading policy has been developed to help address this conflict. We have established the following restrictions as they relate to our participation or interest in client transactions and personal transactions of supervised persons:  No supervised persons of our firm may purchase, sell or hold any security in a client’s account in a manner calculated to create personal benefit to that supervised person. If a supervised person stands to materially benefit from an investment decision for a client, the supervised person must disclose the full nature of the interest and personal benefit.  A supervised person cannot trade ahead of an advisory client when he or she is buying or selling the same securities for themselves personally This is only a summary of our complete Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request and at no cost. Please contact us at the telephone number or email address listed on the first page of this Brochure to receive a copy of our Code of Ethics. Item 12. Brokerage Practices Recommendation of a Broker / Custodian; Factors Considered in our Recommendations ACP does not maintain custody of your assets, although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account to pay our fees or to direct funds to third parties you authorize (see Item 15—Custody, below). In all cases, client assets must be held with a “qualified custodian,” generally a broker-dealer or a bank. We generally recommend one of two broker-dealer/qualified custodians for our clients: LPL or Charles Schwab & Co., Inc. (“Schwab”). We refer to such broker-dealer/custodians as “custodians” throughout this section because the firms we recommend act in both capacities. When recommending a custodian, Page | 19  we look at various factors, including the reasonableness of compensation. The factors we consider for the different custodians are described below. We are independently owned and operated and are not affiliated with LPL or Schwab. Your custodian will hold your assets in a brokerage account and buy and sell securities as we instruct them to. While we recommend you use a specific custodian, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. We don’t open the account for you, though we assist you with the process and handle the administrative aspects. When considering whether the terms the custodian provides are overall most advantageous to you when compared with other available providers and their services, we consider a range of factors, including:  Combination of transaction execution services and asset custody services, generally without a separate fee for custody  Capability to execute, clear, and settle trades  Capability to facilitate transfers and payments to and from accounts  Breadth of available investment products  Availability of investment research and tools that assist us in making investment decisions  Quality of services  Competitiveness of the price of those services and willingness to negotiate prices  Reputation, financial strength, security and stability  Prior service to us and our clients  Services delivered or paid for by Schwab  Availability of other products and services that benefit us, as discussed below Brokerage and Custody Costs Neither LPL nor Schwab generally does not charge clients separate fees for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your brokerage account. The custodian is also compensated by earning interest on the uninvested cash in in your account and/or on any margin balance maintained in your accounts, and from other ancillary services. While most of Schwab’s trades do not incur commissions or transaction fees, there are exceptions. Schwab discloses its fees and costs to clients, and we take those costs into account when executing transactions on your behalf. LPL charges transaction fees, which we have negotiated as a hybrid adviser with them utilizing their institutional advisory platform. LPL discloses its fees and costs to clients, which may change from time to time, and we take those costs into account when executing transactions on your behalf. Your custodian offers certain mutual funds and ETFs for no transaction fee. Such transaction confirmations will show “no commission.” Typically, the custodian (but not ACP) earns additional remuneration from such services as recordkeeping, administration, and platform fees, for the funds and ETFs on their no- transaction fee lists. This additional revenue to the custodian will tend to increase the internal expenses of the fund or ETF. ACP selects investments based on our assessment of a number of factors, including Page | 20  liquidity, asset exposure, reasonable fees, effective management, and low execution cost. Where we choose a no-transaction fee fund or ETF, it is because it has met our criteria in all applicable categories. Custodians charge you a flat dollar amount as “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, to minimize your trading costs, we have a single custodian execute most trades for your account. Products and Services Available to ACP Through our relationships with the custodians we recommend, we gain access to their institutional trading and operations services, which are not typically available to retail clients. Those services may include research, brokerage, custody, access to mutual funds and other investments that are otherwise available only to institutional clients or would require significantly higher minimum initial investments. The custodian may also make available to ACP other products and services that benefit us but may not benefit our clients’ accounts. These include technology that provide access to client account data, facilitation of trade execution, research, pricing information and other market data, facilitation of payment of ACP’s advisory fees from its clients’ accounts, and assistance with back-office support, recordkeeping and client reporting. These custodians may also offer other services intended to help us manage and further develop our business enterprise. Such services may include:  Educational conferences and events  Technology, compliance, legal, and business consulting  Publications and conferences on practice management and business succession  Access to employee benefits providers, human capital consultants and insurance providers A custodian may also provide various incentives to our IARs, including marketing provided by vendors paid for by the broker-dealer, waiver of ticket charges, and/or availability of systems which may be contingent on the quantity of business directed to a particular custodian. A custodian’s fees may be discounted or waived for some of these services, or a third party may pay the fee. For certain IARs, the availability of the foregoing products and services is not contingent upon ACP committing to one custodian any specific amount of business (assets in custody or trading). However, certain IARs don’t have to pay for services or receive other benefits described above so long as they maintain client assets at a stated level. The availability of these services from a custodian benefits ACP’s IARs because they do not have to produce or purchase them. Any commitment level may give the IAR an incentive to recommend that clients maintain their accounts with one custodian over another based on the IAR’s interest in receiving that firm’s services that benefit their business rather than based on client interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. Although there are potential conflicts of interest with our recommendation of a particular broker- dealer/custodian, we believe that our recommendation is in the best interests of our clients. This belief is based on the scope, quality and price of the services of the broker-dealer/custodian and not those services that benefit only ACP or our IARs. Page | 21  Special Circumstances We may assist some of our clients with opening and maintaining brokerage accounts for which we have ongoing reporting and monitoring responsibility only; we do not exercise brokerage or investment discretion over these accounts (“non-discretionary accounts”). Although the client maintains sole trading decision-making authority, ACP may place specific transactions as an accommodation for these clients at their request. Directed Brokerage Because we typically execute your investment transactions through the custodian holding your assets, we are effectively requiring that you “direct” your brokerage to your custodian, absent other specific instructions as discussed below. Because we are not choosing broker-dealers on a trade-by-trade basis, we may not be able to achieve the most favorable executions for clients, and this may ultimately cost clients more money. Not all investment advisers require directed brokerage. Although not a normal business practice for ACP, we may permit clients to direct us to use broker-dealers other than the custodian. If we agree to accommodate your request to do this, we will likely have little or no ability to negotiate commissions or influence execution price, and you will also not benefit from any trade aggregation we may implement for other clients. This may result in greater costs to you. We do not use, recommend, or direct activity to brokers in exchange for client referrals. Aggregated or Block Transactions We routinely aggregate client transactions with those of other client accounts at the same custodian. This results in client trades being executed and billed at the same price. As applicable, the flat commission rate we have negotiated will be applied to each account participating in the transaction. When we choose to place a block transaction, we issue instructions to purchase a particular number of shares or face amount of a security (usually an exchange traded fund or mutual fund) and all participating clients, and their pro-rated shares of the block are known at the time of the transaction. We generally trade in liquid securities and partial allocations are not a concern under normal market conditions. However, should we not receive the full amount of the requested, or if multiple executions are required, the following apply:   If the full amount we requested is not obtained (and we determine to stop trading), we will pro- rate the purchased shares equally across all participating accounts. However, if employee transactions are included in the block and only a partial fill is completed, employee transactions are excluded (per our Code) until all client trades are completed. If multiple fills occur to complete the full block, then all purchases are averaged to price and each participating client receives their full allocation at that average price. Research and Other Soft Dollar Benefits We do not have any traditional “soft dollar” arrangements in place, in which we agree to direct a certain amount of commission dollars to a specific custodian in exchange for research or other services. Rather, the services described in this Item 12 are made available to us simply because we maintain client accounts on the custodian platform. Many of these services generally may be used to service all or a substantial number of ACP’s accounts, including accounts not maintained at custodian. Page | 22  The availability to ACP of the foregoing products and services is not contingent upon ACP committing to custodian any specific amount of business (assets in custody or trading commissions). In some cases, clients could pay more for custody and execution through the custodian we recommend than through others. We review the capacities and costs of our custodian regularly to ensure that our clients are receiving quality executions and competitive pricing, as well as more intangible service benefits. ACP reviews its choice of custodians on an annual basis to reaffirm the health of each entity, the quality of executions and the additional services provided by the custodian. We believe our selection of LPL and Schwab as recommended custodian(s) and broker(s) is in the best interest of our clients because of the scope, quality, and price of their services. Best Execution As indicated above, we typically require that clients open brokerage/custodial accounts at custodians not affiliated with us, LPL or Schwab. We are not compensated directly for recommending custodians to clients, though we may receive indirect economic benefits from those custodians as outlined above. The criteria for recommending a custodian include reasonableness of commissions and other costs of trading, ability to facilitate trades, securities lending needs, access to client records, computer trading support and other operational considerations. These factors will be reviewed from time to time to ensure that the best interests of our clients are upheld. In seeking “best execution” for clients, the key factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, considering the full range of services, including execution capability, technological processes used for submitted trades and other valuation services. Item 13. Review of Accounts For our asset management clients, the IAR continuously reviews client portfolios to ensure the investments are consistent with the investment objectives, philosophy, strategy, and methodologies. Financial planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. Retirement Plan Consulting clients receive reviews of their pension plans for the duration of the pension consulting service. We also provide ongoing services to pension consulting clients where we meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Item 14. Client Referrals & Other Compensation We recommend broker-dealer/custodians to clients, LPL and Schwab. LPL is the broker-dealer with whom some of our IARs are dually registered. As a result of the individual association of our IARs with LPL, that IAR may be required or given incentive to utilize the brokerage/custodial services of LPL for investment advisory accounts. See Item 12 above for details about our recommendation of LPL. LPL may also provide other compensation to its dually registered persons, including but not limited to, bonus payments and forgivable loans dependent upon certain asset level thresholds. The receipt of any such compensation creates a financial incentive for your representative to recommend LPL as custodian Page | 23  for the assets in your advisory account. We encourage you to discuss any such conflicts of interest with your representative before deciding to custody your assets at LPL. We do not have any arrangements in place to compensate third parties for client referrals. Item 15. Custody All client funds and securities are maintained with a qualified custodian; we don’t take physical possession of client assets. You will receive account statements and transaction confirmation notices directly from the custodian at least quarterly, which you should carefully review. We urge you to carefully compare the custodian’s account statements with the periodic data you receive from us and to notify us promptly of any discrepancies. We have the ability to deduct our advisory fees directly from your accounts based on your written authorization to do so, and this ability is technically considered “custody” but doesn’t require separate reporting or a surprise audit of ACP. In addition, in some cases clients execute standing letters of authorization (“SLOAs”), which are written directives from the client authorizing us to initiate payments from their custodial accounts to client-specified third parties. Although SLOAs are client-initiated and client-authorized, our ability to facilitate the payments covered by the SLOAs is considered “custody” under SEC guidance and requires us to report that we have custody over these account assets on our ADV 1A. To the extent the SLOAs comply with certain conditions, however, including that clients have the right to terminate the SLOA, and that the qualified custodian will confirm the status of the SLOA annually directly with the client, ACP is not subject to a surprise custody audit. Item 16. Investment Discretion As indicated in Item 4 of this brochure, we provide discretionary investment management services. Our discretionary authority is pursuant to a written agreement. Item 17. Voting Client Securities ACP does not have any authority to and does not vote proxies on behalf of any advisory clients. You retain responsibility for receiving and voting proxies for any and all securities maintained in your accounts. If you request, we will provide information or our professional insight into various matters related to your proxies. Third-party managers we recommend may retain the authority to vote proxies in accounts they manage for you, subject to their stated policies. Item 18. Financial Information ACP does not have any financial commitment that impairs our ability to meet contractual and fiduciary commitments to our clients. In addition, neither ACP nor its management persons have been the subject of a bankruptcy proceeding. Page | 24