AERIE ADVISORY GROUP LLC

Aerie Advisory Group LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Aerie Advisory Group LLC. If you have any questions about the contents of this brochure, please contact us at (253) 857-1616 or by email at: rbrent@aerieadvisory.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Aerie Advisory Group LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Aerie Advisory Group LLC’s CRD number is: 333610. 3025 Harborview Drive Gig Harbor, WA 98335 (253) 857-1616 rbrent@aerieadvisory.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 04/29/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Aerie Advisory Group LLC on 03/10/2025 are described below. Material changes relate to Aerie Advisory Group LLC’s policies, practices or conflicts of interests. • Aerie Advisory Group LLC has updated its assets under management. (Item 4.E) • Aerie Advisory Group LLC has updated its phone number. (Cover page) • Aerie Advisory Group LLC has updated disclosures related to a supervised person’s outside business activity and ownership interest in a private company, as well as related conflicts of interest. (Items 10 and 11) ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................5 Item 7: Types of Clients ..........................................................................................................................................6 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................6 Item 9: Disciplinary Information ...........................................................................................................................9 Item 10: Other Financial Industry Activities and Affiliations .........................................................................10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............11 Item 12: Brokerage Practices ................................................................................................................................13 Item 13: Review of Accounts ................................................................................................................................14 Item 14: Client Referrals and Other Compensation ..........................................................................................15 Item 15: Custody ....................................................................................................................................................16 Item 16: Investment Discretion ............................................................................................................................16 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................16 Item 18: Financial Information .............................................................................................................................17 iii  Item 4: Advisory Business A. Description of the Advisory Firm Aerie Advisory Group LLC (hereinafter “AAG”) is a Limited Liability Company organized in the State of Washington. The firm was formed in November 2019, and the principal owner is Aerie Advisory Group Trust. B. Types of Advisory Services Portfolio Management Services AAG offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. AAG creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring AAG evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. AAG will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. AAG seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of AAG’s economic, investment or other financial interests. To meet its fiduciary obligations, AAG attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, AAG’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is AAG’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. AAG may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, AAG will always ensure those other advisers are properly licensed or registered as an investment adviser. AAG conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. AAG then makes investments with a third-party investment 2  adviser by referring the client to the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third party adviser on behalf of AAG's client. AAG may also allocate among one or more private equity funds or private equity fund advisers. AAG will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. Services Limited to Specific Types of Investments in the gold and precious metal sectors), treasury AAG generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, hedge funds, private equity funds, ETFs inflation (including ETFs protected/inflation linked bonds, non-U.S. securities, venture capital funds and private placements. AAG may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status 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. We also have a fiduciary duty under the Investment Advisers Act of 1940 with respect to all client accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions AAG offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent AAG from properly servicing the client account, or if the restrictions would require AAG 3  to deviate from its standard suite of services, AAG reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. AAG does not participate in wrap fee programs. E. Assets Under Management AAG has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: December 2025 $ 289,834,017 $ 328,218,041 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $10,000,000 0.85% $10,000,001 - $25,000,000 0.50% $25,000,001 - $50,000,000 0.40% $50,000,001 - AND UP 0.30% AAG uses the value of the account as of the last business day of the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of AAG's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. 4  Selection of Other Advisers Fees Clients will pay AAG its standard fee in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between AAG and each third-party adviser. The fees will not exceed any limit imposed by any regulatory agency. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in arrears. Payment of Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by AAG. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees AAG collects its fees in arrears. It does not collect fees in advance. E. Outside Compensation For the Sale of Securities to Clients Neither AAG nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management AAG does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. 5  Item 7: Types of Clients AAG generally provides advisory services to the following types of clients: ❖ ❖ High-Net-Worth Individuals Charitable Organizations There is no account minimum for any of AAG’s services. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis AAG’s methods of analysis include Fundamental analysis and Quantitative analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Investment Strategies AAG uses long term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. 6  Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Selection of Other Advisers: Although AAG will seek to select only money managers who will invest clients' assets with the highest level of integrity, AAG's selection process cannot ensure that money managers will perform as desired and AAG will have no control over the day-to-day operations of any of its selected money managers. AAG would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market 7  is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. 8  Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Hedge funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. 9  B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither AAG nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither AAG nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Roman Guy Brent is owner and an investment adviser representative with another investment advisory firm, Anacapa, LLC, and from time to time, may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. AAG always acts in the best interest of the client and clients are in no way required to use the services of any representative of AAG in connection with such individual's activities outside of AAG. A supervised person of AAG, Brian Pierson, is a significant equity owner (approximately 41%) of Integrated Wealth Platform (“IWP”), a Delaware corporation that develops and markets financial planning and estate planning software to financial professionals. IWP is a separate legal entity and is not owned by AAG. Mr. Pierson will be involved in activities related to IWP, including promoting the software to potential users. Although Mr. Pierson does not currently receive salary or other direct compensation from IWP, he may receive financial benefits in the future based on his ownership interest. 10  In certain circumstances, a client of AAG may independently choose to invest in IWP securities (such as a convertible note or other investment instrument). This presents a conflict of interest because Mr. Pierson has a financial interest in IWP and may benefit from its success. AAG does not require or condition the provision of advisory services on a client’s decision to invest in IWP. Clients are under no obligation to invest, and any such investment decision is made solely at the client’s discretion. To mitigate this conflict, AAG provides full and fair disclosure of Mr. Pierson’s financial interest and, where applicable, requires pre-approval and supervision of any related activities in accordance with the firm’s policies and procedures governing outside business activities and private securities transactions. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections AAG may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Clients will pay AAG its standard fee in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between AAG and each third-party advisor. The fees will not exceed any limit imposed by any regulatory agency. AAG will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. AAG will ensure that all recommended advisers are licensed or notice filed in the states in which AAG is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics AAG has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. AAG's Code of Ethics is available free upon request to any client or prospective client. AAG’s Code of Ethics also addresses conflicts arising from outside business activities and personal ownership interests of its supervised persons. 11  B. Recommendations Involving Material Financial Interests AAG generally does not recommend that clients buy or sell any security in which AAG or a related person has a material financial interest. However, as disclosed in Item 10, a supervised person of AAG has a significant ownership interest in Integrated Wealth Platform (“IWP”). A client of AAG has invested in IWP through a convertible note. While AAG did not recommend this investment and the investment was made at the client’s initiative, this situation creates a conflict of interest because the supervised person may benefit from the client’s investment and the overall success of IWP. Clients should be aware that such conflicts could affect the objectivity of the adviser. AAG addresses this conflict by: • Providing full and fair disclosure of the supervised person’s financial interest in IWP • Not exercising discretionary authority over such investments • Requiring that any such investment decisions be made by the client • Subjecting any related activities to the firm’s policies and procedures governing outside business activities and private securities transactions AAG will continue to act in the best interest of its clients and encourages clients to perform their own due diligence and seek independent advice when considering such investments. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of AAG may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of AAG to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. AAG will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of AAG may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of AAG to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, AAG will never engage in trading 12  that operates to the client’s disadvantage if representatives of AAG buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on AAG’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and AAG may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in AAG's research efforts. AAG will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. AAG recommends Schwab Institutional, a division of Charles Schwab & Co., Inc. and Fidelity Brokerage Services LLC. 1. Research and Other Soft-Dollar Benefits While AAG has no formal soft dollars program in which soft dollars are used to pay for third party services, AAG may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). AAG may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and AAG does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. AAG benefits by not having to produce or pay for the research, products or services, and AAG will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that AAG’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals AAG receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 13  3. Clients Directing Which Broker/Dealer/Custodian to Use AAG may permit clients to direct it to execute transactions through a specified broker- dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to AAG to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts AAG does not aggregate or bunch the securities to be purchased or sold for multiple clients. This may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for AAG's advisory services provided on an ongoing basis are reviewed at least monthly by Roman G Brent, Chief Compliance Officer and Chief Investment Officer, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at AAG are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of AAG's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. AAG will also provide at least quarterly a separate written statement to the client. 14  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Other than soft dollar benefits as described in Item 12 above, AAG does not receive any economic benefit, directly or indirectly from any third party for advice rendered to AAG's clients. With respect to Schwab, AAG receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For AAG client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to AAG other products and services that benefit AAG but may not benefit its clients’ accounts. These benefits may include national, regional or AAG specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of AAG by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist AAG in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of AAG’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of AAG’s accounts. Schwab Advisor Services also makes available to AAG other services intended to help AAG manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to AAG by independent third parties. Schwab Advisor Services may 15  discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to AAG. AAG is independently owned and operated and not affiliated with Schwab. B. Compensation to Non – Advisory Personnel for Client Referrals AAG does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, AAG will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. AAG does not maintain custody of client funds or securities in connection with investments in privately held companies, including IWP. Any such investments are made directly by the client with the issuer, and AAG does not have authority to withdraw or transfer such funds. Item 16: Investment Discretion AAG provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, AAG generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Item 17: Voting Client Securities (Proxy Voting) AAG will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 16  Item 18: Financial Information A. Balance Sheet AAG neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore it is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither AAG nor its management has any financial condition that is likely to reasonably impair AAG’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years AAG has not been the subject of a bankruptcy petition in the last ten years. 17