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Cover Page – Item 1
Accredited Investor Services, LLC
Doing Business As
AIS Planning
622 Roosevelt Road
Suite 160
St. Cloud, MN 56301
Phone: (320) 252-6552
Fax: (320) 252-6534
Email: meet@aisplanning.com
www.aisplanning.com
March 23, 2026
Form ADV Part 2A Brochure
Accredited Investor Services, LLC, doing business as AIS Planning (“AIS Planning”) is a registered
investment adviser. An “investment adviser” means any person who, for compensation, engages in the
business of advising others, either directly or through publications or writings, as to the value of securities
or as to the advisability of investing in, purchasing, or selling securities, or who, for compensation and as
part of a regular business, issues or promulgates analyses or reports concerning securities. Registration
with the United States Securities and Exchange Commission (“SEC”) or any state securities authority does
not imply a certain level of skill or training.
This brochure provides information about the qualifications and business practices of AIS Planning. If you
have any questions about the contents of this Brochure, please contact us at (320) 252-6552. The
information in this Brochure has not been approved or verified by the SEC or by any state securities
authority.
Additional information about AIS Planning is available on the SEC’s website at www.adviserinfo.sec.gov.
AIS Planning
Form ADV Part 2A Brochure
Page 2
Material Changes - Item 2
The purpose of this page is to inform you of any material changes since the previous version of this
Disclosure Brochure.
On March 23, 2026, we submitted our annual updating amendment filing for fiscal year 2025. We have
updated Item 4 of our Form ADV Part 2A Brochure to disclose discretionary assets under management
of approximately $585,971,551 and non-discretionary assets under management of approximately
$5,014,187.
In addition, we amended the Methods of Analysis, Investment Strategies and Risk of Loss section (Item
8) of the document to disclose additional material investment risks (Item 8) pertaining to Direct
Indexing, Securities Backed Lines of Credit (SBLOCs), Political Risk and Artificial Intelligence ("AI") Risk.
We review and update our Disclosure Brochure at least annually to make sure that it remains current.
If you would like to receive a copy of our Form ADV Part 2 Brochure, please contact us at (320) 252-
6552.
AIS Planning
Form ADV Part 2A Brochure
Page 3
Table of Contents - Item 3
Contents
Cover Page – Item 1 .................................................................................................................................. 1
Material Changes - Item 2 ......................................................................................................................... 2
Table of Contents - Item 3 ........................................................................................................................ 3
Advisory Business - Item 4 ........................................................................................................................ 4
Fees and Compensation - Item 5 .............................................................................................................. 9
Performance-Based Fees and Side-By-Side Management - Item 6 ........................................................ 14
Types of Clients - Item 7 .......................................................................................................................... 14
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8 ................................................... 14
Disciplinary Information - Item 9 ............................................................................................................ 23
Other Financial Industry Activities or Affiliations - Item 10 .................................................................... 23
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11 ........... 24
Brokerage Practices – Item 12 ................................................................................................................ 25
Review of Accounts - Item 13 ................................................................................................................. 26
Client Referrals and Other Compensation - Item 14 .............................................................................. 26
Custody - Item 15 .................................................................................................................................... 27
Investment Discretion - Item 16 ............................................................................................................. 28
Voting Client Securities - Item 17 ........................................................................................................... 28
Financial Information - Item 18 .............................................................................................................. 28
Requirements of State-Registered Advisers - Item 19 ............................................................................ 28
Miscellaneous ......................................................................................................................................... 29
AIS Planning Privacy Notice .................................................................................................................... 29
AIS Planning
Form ADV Part 2A Brochure
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Advisory Business - Item 4
Accredited Investor Services, LLC, doing business as AIS Planning, is a registered investment adviser
based in St. Cloud, Minnesota. We are a limited liability company formed under the laws of the State
of Minnesota, and we have been providing investment advisory services since 2008. Registration with
the SEC or any state securities authority does not imply any level of skill or education.
Cathy L. Juilfs, Jason C. Hallonquist, Sarah Noble, and Nathan Goebel are the principal owners of AIS
Planning. Cathy L. Juilfs is the Chief Executive Officer and Nathan Goebel is the Chief Compliance Officer
of the firm.
Currently, we offer financial planning, investment management, and qualified retirement plan
consulting services personalized to each client. You will see the term “Associated Person” throughout
this Brochure to refer to anyone from our firm who is an officer, employee, or individual providing
investment advice on behalf of our firm. Such persons are properly authorized and/or registered as
investment adviser representatives ("IAR") in all required jurisdictions.
Initial Onboarding Process
Our initial onboarding process starts with an analysis of the client’s financial situation and needs and
the formulation of an action plan. Through this process, we strive to gain an understanding of who you
are and what you care about, so we may advise and act in ways that meet your unique needs and
objectives.
Financial Planning Advice
Our financial planning process is based on an effort to gain a deep understanding of client needs,
personal values, and objectives to provide personalized investment advice that is designed to help
clients achieve their financial goals. We believe that time spent getting to know our clients and their
finances in detail is an important investment towards delivering quality advice. We do this by gathering
information, reviewing data, and working through our analytic tools and processes to understand and
assess the various facets of the client’s life and wealth.
Financial planning advice and services may include, but are not limited to:
Insurance review and assessment
• Net worth and cash flow assessment and coaching
• Emergency account and cash flow planning
• Debt analysis and reduction strategy
• Behavioral risk analysis
• Retirement savings review
•
• Education planning, funding, and monitoring
• Retirement income planning and coordination
• Estate and beneficiary planning (in coordination with the client’s attorney)
• Tax planning (in coordination with the client’s tax accountant)
• Outside asset review, advice, and monitoring
• Wealth transfer strategies
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Our advice is based on your financial situation and the financial information you provide to our firm.
You must provide all items that are necessary or desirable for AIS Planning to perform the fiduciary and
ministerial tasks required of us, including information that accurately reflects fees on assets that may
be rolled over into accounts managed by AIS Planning. If your financial situation, goals, objectives, or
needs change, you must notify us promptly. You may choose to accept or reject our recommendations.
If you decide to proceed with our recommendations, you may do so either through our firm or by using
the advisory/brokerage firm of your choice.
Ongoing Investment Management
With the client’s best interest in mind, AIS Planning provides access to a broad spectrum of investment
solutions. We focus on delivering a personalized approach to developing and maintaining a customized
portfolio, utilizing academic-based disciplines for asset allocation, diversification, and tax awareness.
Our firm offers discretionary portfolio management services to our clients. Discretionary portfolio
management means we will make investment decisions and place portfolio reallocation orders in your
account without contacting you prior to each transaction. These decisions would be made based upon
your stated investment objectives. If you wish, you may limit our discretionary authority by, for
example, setting a limit on the type of securities that can be purchased for your portfolio. Simply
provide us with your restrictions or guidelines in writing.
Currently, our investment management services are offered in conjunction with a sub adviser. The sub
adviser assists our firm with back-office support, trading, report preparation, and billing. We use model
portfolios developed by the sub adviser and/or other registered investment advisers. These other
investment advisers are responsible for the research and security selection within model portfolios,
day-to-day trading, billing calculation, and other back-office operations. AIS Planning is responsible for
the supervision of the account, portfolio reallocations and rebalancing, and ongoing client interaction
and servicing. At this time, AIS Planning uses the following programs:
SEI Investments Management Corporation (“SIMC”)
SIMC gives us the ability to place client portfolios in their proprietary models, along with models
created by AIS Planning and models provided by other investment advisers. All clients will be
provided with a current copy of SIMC’s Form ADV Part 2 Brochure at the inception of services. This
document provides important disclosures about SIMC’s services, portfolio models, fees, conflicts of
interest, disciplinary history (if any), and other important information that would help clients
understand the scope of sub advisory services provided by SIMC.
All accounts are managed in accordance with the client’s investment needs. Investments may
include various types of securities such as equity securities, Exchange Traded Funds (ETFs), mutual
funds, corporate debt securities, municipal securities, and U.S. Government securities. Other types
of investments may also be recommended where such investments are appropriate based on the
client’s stated goals and objectives.
American Funds Model Portfolios
The American Funds Model Portfolios Program (“American Funds Program”) is a mutual fund
advisory service that provides clients the opportunity to allocate assets among various asset classes
that cover a variety of investment objectives. The American Funds Program is an asset allocation-
based mutual fund investment program that invests exclusively in American Funds mutual funds.
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Form ADV Part 2A Brochure
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Investments and allocations are determined and based upon the client’s predefined objectives, risk
tolerance, time horizon, financial horizon, financial information, and other various suitability factors.
Further restrictions and guidelines imposed by the client may affect the composition and performance
of a client’s portfolio. For these reasons, performance of the portfolio may not be identical to other
clients of AIS Planning. On an ongoing basis, AIS Planning reviews the client’s financial circumstances
and investment objectives, and instructs SIMC or American Funds to make the necessary adjustments
to the client’s portfolio.
Associated Persons of AIS Planning will periodically, as agreed upon with each client, review reports to
measure the client’s portfolio against the client’s financial situation and objectives, communicate
information to SIMC or American Funds as warranted, and assist the client in understanding and
evaluating the services provided by SIMC and American Funds. Clients are expected to notify AIS
Planning of any changes in their financial situation, investment objectives, or account restrictions.
Third-Party Investment Management Services
Historically, we have recommended the services of various third-party investment managers. These
recommendations were made after an analysis of other investment advisers’ advisory platforms with
the goal of meeting the client’s financial needs and objectives.
We monitor the strategies offered through third-party investment management platforms to ensure
that the objectives align with clients’ investment objectives and risk tolerance. By authorization
incorporated in the service agreement, third-party investment management platforms are granted
discretionary authority to manage assets.
All third-party investment managers that our firm recommends to its clients must either be exempt
from registration or registered as investment advisers with the Securities and Exchange Commission or
with the appropriate state authorities. AIS Planning will continuously monitor the performance of the
third-party investment managers to ensure their performance and investment style remains aligned
with the investment goals and objectives of the client.
Project-Specific Services
AIS Planning provides project-specific services that focus on the specific needs and concerns of the
client. Project specific services may include giving advice on investments and investment-related
matters. These services may include the identification of financial goals and objectives, collection and
assessment of all relevant data, identification of financial problems and formulation of solutions, and
the preparation of a financial plan with specific recommendations. The services we provide will typically
focus on the following areas:
Investment management
• Financial independence (retirement planning)
•
• Net worth planning
• Estate planning
• Family meetings
• Education planning
•
Insurance reviews
• Tax strategy planning, review of tax returns
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• Executive deferred compensation plans/pension pay-out elections
• Social Security planning
• Business consulting
• General investment and asset allocation advice
If your financial situation, goals, objectives, or needs change, you must notify us promptly.
Qualified Retirement Plan Consulting / Fiduciary Services
AIS Planning provides consulting and/or fiduciary services to qualified retirement, profit sharing, cash
balance, and 401(k) plans. AIS Planning will also offer these services, where appropriate, to individuals
and trusts, estates, and charitable organizations.
AIS Planning is registered as an investment advisor and represents that it is not subject to any
disqualification as set forth in Employee Retirement Income Security Act of 1974 (“ERISA”) Section 411.
Generally, services provided under the AIS Planning’s qualified retirement plan consulting and fiduciary
services, include, but are not limited to:
• Assisting the Plan Administrator/Plan Sponsor in the development of an Investment Policy
Statement (“IPS”) that establishes the investment policies and objectives for the Plan. The Plan
Administrator/Plan Sponsor shall have the ultimate responsibility and authority to adopt and
amend the Plan’s IPS;
•
•
•
• Assisting the Plan Administrator/Plan Sponsor in defining the goals and objectives for the
administration of the Plan and in the Plan Administrator/Plan Sponsor’s shaping the IPS to the
demographics of the participant census;
If selected to provide Section 3(21) investment advisor services under Section 4.B. herein, AIS
Planning will provide non-discretionary investment advice to the Plan Administrator/Plan
Sponsor about asset classes and investment alternatives available to the Plan in accordance
with the Plan’s investment policies and objectives. By providing non-discretionary investment
advice, AIS Planning acts in the capacity of an ERISA Section 3(21) fiduciary and does NOT act
in the capacity of an ERISA Section 3(38) fiduciary and, further, does not choose investment
selections. AIS Planning merely provides advice and recommendations to the Plan Trustee(s)
regarding Plan investment options. The Plan Administrator/Plan Sponsor shall have the final
decision–making authority regarding the initial selection, retention, removal, and addition of
Plan investment options. AIS Planning will assist the Plan Trustee(s) with the Plan Trustee (s’)
selection of a broad range of investment options consistent with ERISA Section 404(c) and the
regulations thereunder;
If selected to provide Section 3(38) investment management services under Section 4.B. herein,
AIS Planning will provide discretionary investment management to the Plan Administrator/Plan
Sponsor about asset classes and investment alternatives available to the Plan in accordance
with the Plan’s investment policies and objectives. By providing discretionary investment
management, AIS Planning acts in the capacity of an ERISA Section 3(38) fiduciary, thereby
making reasonable investment decisions on behalf of the Plan Trustee(s). These reasonable
investment decisions shall include the initial selection, retention, removal, and addition of Plan
investment options. Any selection of investment options shall be diverse and broad as well as
in compliance with ERISA Section 404(c) and the regulations thereunder;
If selected to provide Section 3(21) investment advisor services under Section 4.B. herein, AIS
Planning will provide non-discretionary investment advice to the Plan Administrator/Plan
AIS Planning
Form ADV Part 2A Brochure
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•
Sponsor with respect to the selection of a qualified default investment alternative (“QDIA”) for
participants who otherwise fail to make an investment election. The Plan Administrator/Plan
Sponsor acknowledges that it is responsible for determining whether the Plan should have a
QDIA and deciding upon the type of investment that will serve as a QDIA (e.g., target date, fund,
balanced fund, or managed account), as permitted by ERISA Section 404(c)(5) and the
regulations promulgated thereunder. Once the Plan Administrator/Plan Sponsor has made that
determination, AIS Planning will assist the Plan Sponsor in selecting the investments to serve
as the QDIA. The Plan Administrator/Plan Sponsor retains the sole responsibility to provide all
notices to participants required under ERISA Section 404(c)(5);
If selected to provide Section 3(38) investment management services under Section 4.B. herein,
AIS Planning will provide discretionary investment management to the Plan Administrator/Plan
Sponsor with respect to the selection of a qualified default investment alternative (“QDIA”) for
participants who otherwise fail to make an investment election. As a 3(38), AIS Planning shall
decide upon the type of investment that will serve as a QDIA (e.g., target date, fund, balanced
fund, or managed account), as permitted by ERISA Section 404(c)(5) and the regulations
promulgated thereunder. Once chosen by AIS Planning, then AIS Planning shall select the
investments to serve as the QDIA. The Plan Administrator/Plan Sponsor retains the sole
responsibility to provide all notices to participants required under ERISA Section 404(c)(5);
• AIS Planning will keep the Plan Administrator/Plan Sponsor informed of any search for
investment managers/funds to replace or fill asset class gaps in accordance with the IPS. The
Plan Administrator/Plan Sponsor shall have the final decision–making authority regarding the
initial selection, retention, removal, and addition of investment options, if AIS Planning is
operating as a Section 3(21) investment advisor; otherwise, as a Section 3(38) investment
manager, AIS Planning shall have the final decision–making authority regarding the initial
selection, retention, removal and addition of investment options;
• AIS Planning will assist the Plan Trustee(s) in the Plan Trustee(‘s)(s’) monitoring investment
options by preparing periodic investment reports that document investment performance,
consistency of fund management, and conformance to the guidelines set forth in the IPS and
make recommendations to maintain or remove and replace investment options; and
• AIS Planning will meet with the Plan Administrator/Plan Sponsor on a professionally reasonable
periodic basis, not less than annually but not more frequently than quarterly, to discuss Plan
administration reports and Plan operational issues.
AIS Planning also provides non fiduciary services to the plan. These services include, but are not limited
to, Plan Support Services, Recordkeeper & Third-Party Administration Selection and monitoring,
Conversion Services, Fiduciary and Non-Fiduciary Planning Services to Plan Participants and certain
recordkeeping services. Each Plan’s specific services will vary. However, all services will be outlined in
the executed Retirement Plan Service Agreement.
Wrap Fee Programs
A wrap fee program combines asset management, advisory services, and trade execution for a single
fee. We do not sponsor or manage any wrap fee programs. The sub-advisory program offered through
SEI Investments Management Corporation (SIMC) is a wrap fee program. Clients should refer to SIMC’s
Form ADV Part 2, Appendix 1 disclosures for more information about the program, its associated costs,
and conflicts of interest.
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Form ADV Part 2A Brochure
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Assets Under Management
As of February 12, 2026, we manage approximately $585,971,551 in client assets on a discretionary
basis and approximately $5,014,187 in client assets on a non-discretionary basis.
Fees and Compensation - Item 5
AIS Planning may charge, depending on your specific contract, a set-up fee, annual planning fees,
project specific fees, hourly fees, or fees based on assets under advisement and/or fees based on assets
managed by TPAs for its advisory services.
Initial Onboarding Process Fees
At the inception of a client relationship, AIS Planning generally charges a maximum negotiable fee of
up to $10,000, which covers the initial onboarding process. Fees are payable upon execution of the
financial services agreement. The exact fee payable by the client will be clearly set forth in the executed
agreement. AIS planning also reserves the right to waive the onboarding fee. AIS Planning expects to
complete this service within six months. We do not require prepayment of over $1,200, six or more
months in advance.
Financial Planning Service Fees
If a client chooses our financial planning offering, AIS Planning charges a fixed fee, which generally
ranges from $200/month for lower net worth/less complex clients to $15,000/quarter for higher net
worth/more complex clients. The exact amount depends upon the complexity and scope of required
services. Fixed fees are paid in arrears. The exact fee payable by the client will be clearly set forth in the
executed agreement. Advisory fees may be increased from time to time by providing advance written
notice to the client.
Ongoing Investment Management Fees
Ongoing investment management fees are determined based on the total amount of client assets
directly under the care of AIS Planning. Fees are charged quarterly or monthly in arrears, based on the
account balance at the end of the billing period as indicated in each client’s service agreement. The fee
for accounts custodied at American Funds will be calculated based on the average daily balance of the
account. Fees are only changed upon written notification to the client. The maximum fee is 1.00% per
year, and is negotiable depending on the size and complexity of the client’s accounts, services required,
and historically grandfathered fee schedules. The specific fee schedule is established in the client’s
agreement with the firm. Advisory fees shall apply to cash balances unless agreed otherwise.
Third-Party Investment Management Services Fees
AIS Planning shares in the fee paid to the third-party investment managers. The management fee is
disclosed in the third-party investment manager’s disclosure documents. These fees may or may not
be negotiable. AIS Planning's compensation may differ depending upon the firm’s individual agreement
with each third-party investment manager. AIS Planning or its Associated Persons may have an
incentive to recommend one third-party investment manager over another with whom it has less
favorable compensation arrangements or other advisory programs offered by third-party investment
managers with which it has no compensation arrangements.
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Form ADV Part 2A Brochure
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Project-Specific Services Fees
Project-specific fees are quoted based on the time, scope, and complexity of the project. Our minimum
engagement fee is $300/hour, with a minimum of $1,800. The total fee is based on the estimated time
required to provide the contracted services and billed incrementally based on agreed upon
deliverables. AIS Planning is responsible for notifying you in advance if/when estimated project fees are
expected to be exceeded due to changes in time, scope and/or complexity of the project.
Qualified Retirement Plan Services
AIS Planning charges the following fees for Qualified Retirement Plan Services:
Initial onboarding fee: Up to $1,000
Minimum fiduciary services fee:
• $7,500 for 3(21) fiduciary services
• $15,000 for 3(38) fiduciary service
The Plan can select one of the 3 payment options listed below:
1. Monthly deduction via signed ACH payment authorization form to the Plan Sponsor
2. Quarterly deduction via signed ACH payment authorization form to the Plan Sponsor
3. Monthly payment in arrears through investment custodian to the Plan participants
Plan Assets Fee’s payable as follows:
Monthly or Quarterly in Arrears through Investment Custodian to the Plan Participants. Per AUA Fee
Schedules below.
Plan Asset Balance
$0 - $1,000,000
$1,000,001 - $2,500,000
$2,500,001 - $5,000,000
$5,000,001 - $10,000,000
$10,000,001 - $25,000,000
$25,000,001 - $50,000,000
$50,000,001 and up
3(21) Fiduciary Annual Fee %
0.75%
0.68%
0.60%
0.55%
0.45%
0.35%
negotiated
3(38) Fiduciary Annual Fee %
0.90%
0.82%
0.72%
0.66%
0.54%
0.42%
negotiated
Fiduciary Advisory Participant Services: The fee is 20 basis points on the total Plan assets and is paid to
AIS Planning directly out of the Plan assets. These fees are allocated among participants’ individual
accounts in proportion to each account balance as indicated by the Retirement Plan Service Agreement.
For purposes of determining and calculating Fees, the market value of Plan assets means the average
value of assets as reported by the recordkeeper/investment custodian over each month’s time.
Note that AIS Planning will not charge more than is reasonable for its services. Any fees based on the
Plan’s monthly average value of assets shall be charged within the first five (5) days after the end of the
previous month or quarter, as further indicated below. Other fees and fee payment arrangement can
be negotiated on a case by case basis. However, such fees and payment arrangements will be outlined
in the Retirement Plan Service Agreement.
IRA Rollover Considerations
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In conjunction with the advisory services offered, we may provide education or recommendations
related to the rollover of an employer sponsored retirement plan. A plan participant leaving
employment has several options. Each choice offers advantages and disadvantages, depending on
desired investment options and services, fees and expenses, withdrawal options, required minimum
distributions, tax treatment, and the investor's unique financial needs and retirement plans. The
complexity of these choices may lead an investor to seek assistance from us.
When our firm or our Associated Person(s) recommend an investor roll over plan assets into an
Individual Retirement Account (“IRA”), we and our Associated Person(s) may earn an asset-based fee
as a result. However, no compensation is received if assets are retained in the plan. Thus, we have an
economic incentive to encourage an investor to roll plan assets into an IRA. In most cases, your fees
and expenses will increase because fees will apply to assets rolled over to an IRA and ongoing services
will be extended to these assets.
Further, you may incur other levels of fees and expenses, including, but not limited to, investment-
related expenses imposed by other service providers and mutual fund managers not affiliated with us,
as well as other fees and expenses charged by the custodian, third-party administrator, and/or record-
keeper. We make no representations or warranties relating to any costs or expenses associated with
the services provided by any third parties, and you understand that these fees are in addition to the fee
paid to us for the rollover advice.
In cases where we provide you with rollover advice as defined by the Department of Labor, which may
also include setting up and/or completing the rollover transaction, we do not serve as a custodian, and
we do not provide legal or tax advice to you. In addition, we do not have any responsibilities or potential
liabilities in connection with assets not related to the rollover and investments that are not managed
by us.
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries. As such, we must act in your best interest, and we must not put
our interests ahead of your interests. Additionally, 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 polices, 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 any conflicts of interest.
We rely on all information you provide to us, whether financial or otherwise, without independent
verification. We request that you promptly notify us in writing of any material change in the financial
and other information provided to us, and to promptly provide any such additional information as may
be reasonably requested by us.
Due to the volatile and unpredictable nature of financial markets, we do not guarantee any future
performance, any specific level of performance, or the success of any recommendations or strategies
that we may take or recommend for you, or the success of our overall recommendations. Investment
recommendations are subject to various market, currency, economic, political, and business risks, and
that investment decisions will not always be profitable.
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Additional Fees and Expenses
Fees are charged as described above and are not based on a share of capital gains in the account of an
advisory client.
Negotiability of Fees: We allow Associated Persons servicing the account to negotiate the exact
investment management fees within the range disclosed in our Form ADV Part 2A Brochure. As a result,
the Associated Person servicing your account may charge more or less for the same service than
another Associated Person of our firm. Further, our annual investment management fee may be higher
than that charged by other investment advisors offering similar services/programs.
Billing on Cash Positions: The firm treats cash and cash equivalents as an asset class. Accordingly, unless
otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are
included as part of assets under management. At any specific point in time, depending upon perceived
or anticipated market conditions/events (there being no guarantee that such anticipated market
conditions/events will occur), the firm may maintain cash and/or cash equivalent positions for
defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such
amounts could miss market advances and, depending upon current yields, at any point in time, the
firm’s advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions.
limited to
investment performance,
Periods of Portfolio Inactivity: The firm has a fiduciary duty to provide services consistent with the
client’s best interest. As part of its investment advisory services, the firm will review client portfolios
on an ongoing basis to determine if any changes are necessary based upon various factors, including
but not
fund manager tenure, style drift, account
additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment
objectives. Based upon these and other factors, there may be extended periods of time when the firm
determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding,
unless otherwise agreed in writing, the firm’s annual investment advisory fee will continue to apply
during these periods, and there can be no assurance that investment decisions made by the firm will
be profitable or equal any specific performance level(s).
All fees paid to AIS Planning for portfolio management services are separate and distinct from the fees
and expenses charged by mutual funds or exchange traded funds to their shareholders. These fees and
expenses are described in each fund's prospectus and generally include a management fee, other fund
expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an
initial or deferred sales charge.
A client could invest in a mutual fund or security directly, without the services of AIS Planning. In that
case, the client would not receive the services provided by AIS Planning which are designed, among
other things, to assist in determining which investments are most appropriate to each client's financial
condition and objectives. Accordingly, the client should review both the fees charged by the funds and
the fees charged by AIS Planning to fully understand the total amount of fees to be paid by the client
and to thereby evaluate the management services provided.
AIS Planning generally recommends no-load mutual funds to client. The funds are sold without a
commission or sales charge. The reason for this is that the shares are distributed directly by the
investment company instead of going through a secondary party. This is the opposite of a load fund,
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which charges a commission at the time of the fund's purchase, at the time of its sale, or for as long as
the investor holds the fund.
Advisory recommendations are based on your financial situation and information disclosed to us at the
time the services are provided. We make certain assumptions with respect to interest and inflation
rates and the use of past trends and performance of the market and economy. Past performance is in
no way an indication of future performance. As your financial situation, goals, objectives, or needs
change, you must notify us promptly.
Either party may terminate the Agreement by written notice to the other. In the event the client
terminates AIS Planning’s consulting services, the balance of prepaid unearned fees (if any) shall be
refunded to the client.
Sales Compensation
AIS Planning is a licensed insurance agency and certain of our Associated Persons are licensed insurance
agents. AIS Planning and our dually licensed Associated Persons can affect transactions in insurance
products and earn commission-based compensation for these activities. Clients are instructed that the
fees paid to the firm for advisory services are separate and distinct from the commissions earned by us
and our dually licensed Associated Persons. Commissions from the sale of insurance products will not
be used to offset or credited against advisory fees.
The sale of annuity contracts or insurance products offered by Associated Persons are intended to
complement AIS Planning’s advisory services. However, a conflict of interest exists due to the receipt
of dual forms of compensation because Associated Persons have an incentive to recommend insurance
products based on the compensation to be received, rather than on a client’s needs. We address this
conflict of interest by recommending insurance products only where we, in good faith, believe that it is
appropriate for the client’s particular needs and circumstances and only after a full presentation of the
recommended insurance product to our client. In addition, we explain the insurance underwriting
process to our clients to illustrate how the insurer also reviews the client’s application and disclosures
prior to the issuance of a resulting insuring agreement. Clients to whom the firm offers advisory services
are informed that they are under no obligation to purchase insurance services. Clients who do choose
to purchase insurance services are under no obligation to use our licensed Associated Persons and may
use the insurance brokerage firm and agent of their choice.
Where fixed annuities are sold, clients should also note that the annuity sales result in substantial up-
front commissions and ongoing trails based on the annuity’s total value. In addition, many annuities
contain surrender charges and/or restrictions on access to your funds. Payments and withdrawals can
have tax consequences. Optional lifetime income benefit riders are used to calculate lifetime payments
only and are not available for cash surrender or in a death benefit unless specified in the annuity
contract. In some annuity products, fees can apply when using an income rider. Annuity guarantees are
based on the financial strength and claims-paying ability of the issuing insurance company. We urge
our clients to read all insurance contract disclosures carefully before making a purchase decision. Rates
and returns mentioned on any program presented are subject to change without notice. Insurance
products are subject to fees and additional expenses.
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We strive to identify all potential and actual conflicts of interest between you, our firm, and our
Associated Persons in this Disclosure Brochure. If additional conflicts arise in the future, we will notify
you in writing and/or provide you an updated Disclosure Brochure.
Any material conflicts of interest between you and our firm, and the Associated Persons of our firm,
are outlined in this Brochure. If additional material conflicts arise in the future, we will notify you in
writing or supply you with an updated Brochure.
Performance-Based Fees and Side-By-Side Management - Item 6
Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s
assets. AIS Planning and its Associated Persons do not accept performance-based fees.
Types of Clients - Item 7
We offer investment advisory services to individuals, qualified retirement and profit-sharing plans,
trusts, estates, charitable organizations, corporations, and other business entities.
We have a minimum annual fee requirement inclusive of all Management Fees, Fixed Fees, and
Onboarding Fees. The minimum fee shall be no less than $2,500 per year. However, AIS Planning
reserves the right to waive or lower this minimum.
Methods of Analysis, Investment Strategies and Risk of Loss - Item 8
Asset allocation models used by the sub advisers and/or other third-party investment managers (listed
under Item 4 above) are developed in accordance with investment programs developed by these
entities. Clients should refer to the relevant sub advisers' and/or third-party investment manager’s
Form ADV Part 2 Brochures or comparable disclosure documents for more information about the
methods of analysis and investment strategies used by those firms. As disclosed above, AIS Planning
will assist clients in selecting third-party investment managers whose investment programs and
strategies have been reviewed by AIS Planning and determined appropriate for AIS Planning’s clients
based on their individual circumstances and investment goals. We also obtain research from various
third-party research providers and subscription services.
The following are different methods of analysis that we may use when providing you with investment
advice:
• Fundamental analysis is a method of evaluating a company or security by attempting to
measure its intrinsic value. In other words, trying to determine a company’s or a security’s true
value by looking at all aspects of the business, including both tangible factors (e.g., machinery
buildings, land, etc.) and intangible factors (e.g., patents, trademarks, “brand” names, etc.).
Fundamental analysis also involves examining related economic factors (e.g., overall economy
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industry conditions, etc.), financial factors (e.g., company debt,
and
interest rates,
management salaries and bonuses, etc.), qualitative factors (e.g., management expertise,
industry cycles, labor relations, etc.), and quantitative factors (e.g., debt-to-equity and price-
to-equity ratios). The end goal of performing fundamental analysis is to produce a value that
an investor can compare with the security's current price in hopes of determining what sort of
position to take with that security (underpriced = buy, overpriced = sell or short). This method
of security analysis is considered the opposite of technical analysis. Fundamental analysis is
about using real data to evaluate a security's value. Although most analysts use fundamental
analysis to value stocks, this method of valuation can be used for just about any type of security.
• Technical analysis is a technique that relies on the assumption that current market data (such
as charts of price, volume, and open interest) can help predict future market trends, at least in
the short term. It assumes that market psychology influences trading and can predict when
stocks will rise or fall. Technical trading models are mathematically driven based upon historical
data and trends of domestic and foreign market trading activity, including various industry and
sector trading statistics within such markets. Technical trading models, through mathematical
algorithms, attempt to identify when markets are likely to increase or decrease and identify
appropriate entry and exit points. The primary risk of technical trading models is that historical
trends and past performance cannot predict future trends, and there is no assurance that the
mathematical algorithms employed are designed properly, updated with new data, and can
accurately predict future market, industry, and sector performance.
Our firm, the sub-advisers and/or other third-party investment managers managing your account, may
use one or more of the following investment strategies when advising you on investments:
•
•
Long Term Purchases – securities purchased with the expectation that the value of those
securities will grow over a relatively long period, generally greater than one year. Using a long-
term purchase strategy generally assumes the financial markets will go up in the long-term
which may not be the case. There is also the risk that the segment of the market that you are
invested in or perhaps just your particular investment will go down over time even if the overall
financial markets advance. Purchasing investments long-term may create an opportunity cost
- "locking-up" assets that may be better utilized in the short-term in other investments.
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. Using a short-term purchase strategy generally
assumes that we can predict how financial markets will perform in the short-term which may
be very difficult and will incur a disproportionately higher amount of transaction costs
compared to long-term trading. There are many factors that can affect financial market
performance in the short-term (such as short-term interest rate changes, cyclical earnings
announcements, etc.), but they may have a smaller impact over longer periods.
• Trading – securities are sold within 30 days. The principal type of risk associated with trading is
market risk. There can be no assurance that a specific investment will achieve its investment
objectives and past performance should not be seen as a guide to future returns. The value of
investments and the income derived may fall as well as rise and investors may not recoup the
original amount invested. Other factors, such as changes in exchange control regulation, tax
laws, withholding taxes, international, political and economic developments, and government,
economic or monetary policies, may affect investments as well. Additionally, trading is
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speculative. Market movements are difficult to predict and are influenced by, among other
things, government trade, fiscal, monetary and exchange control programs and policies;
changing supply and demand relationships; national and international political and economic
events; changes in interest rates; and the inherent volatility of the marketplace. In addition,
governments from time to time intervene, directly and by regulation, in certain markets, often
with the intent to influence prices directly. The effects of governmental intervention may be
particularly significant at certain times in the financial instrument markets and such
intervention (as well as other factors) may cause these markets to move rapidly.
• Margin Transactions – margin strategies allow an investor to purchase securities on credit and
to borrow on securities already in their custodial account. Interest is charged on any borrowed
funds for the period that the loan is outstanding. When you purchase securities, you may pay
for the securities in full or you may borrow part of the purchase price from your broker-dealer.
If you intend to borrow funds in connection with your account, you will be required to open a
margin account, which will be carried by the broker-dealer of your account. The securities
purchased in such an account are the broker-dealer’s collateral for its loan to you. If the
securities in a margin account decline in value, the value of the collateral supporting this loan
also declines, and, as a result, a brokerage firm is required to take action, such as issue a margin
call and/or sell securities or other assets in your accounts, in order to maintain necessary level
of equity in the account. It is important that you fully understand the risks involved in obtaining
loans or trading securities on margin. These risks are applicable to any margin account that you
may maintain, including any margin account that may be established as a part of our advisory
services and held by your custodian and/or broker-dealer. These risks include the following:
1. You can lose more funds than you deposit in your margin account.
2. The custodian and/or broker-dealer can force the sale of securities or other assets in
your account.
3. The custodian and/or broker-dealer can sell your securities or other assets without
contacting you.
4. You may not be able to choose which securities or other assets in your margin account
are liquidated or sold to meet a margin call.
5. The custodian and/or broker-dealer may move securities held in your cash account to
your margin account and pledge the transferred securities.
6. You may not be entitled to an extension of time on a margin call.
The advice provided by AIS Planning will vary depending on each client’s specific financial situation and
goals. This brief statement does not disclose all of the risks and other significant aspects of investing in
financial markets. In light of the risks, you should fully understand the nature of the contractual
relationships into which you are entering and the extent of your exposure to risk. Certain investing
strategies may not be suitable for everyone. You should carefully consider whether the strategies
employed would be appropriate for you in light of your experience, objectives, financial resources and
other relevant circumstances.
General Investment Risk: All investments come with the risk of losing money. Investing involves
substantial risks, including complete possible loss of principal plus other losses. Investments, unlike
savings and checking accounts at a bank, are not insured by the government to protect against market
losses. Different market instruments carry different types and degrees of risk and you should familiarize
yourself with the risks involved in the particular market instruments you intend to invest in.
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Loss of Value: There can be no assurance that a specific investment will achieve its investment
objectives and past performance should not be seen as a guide to future returns. The value of
investments and the income derived may fall as well as rise and investors may not recoup the original
amount invested. Investments may also be affected by any changes in exchange control regulation, tax
laws, withholding taxes, international, political and economic developments, and government,
economic or monetary policies.
Interest Rate Risk: Fixed income securities and funds that invest in bonds and other fixed income
securities may fall in value if interest rates change. Generally, the prices of debt securities rise when
interest rates fall, and their prices fall when interest rates rise. Longer-term debt securities are usually
more sensitive to interest rate changes.
Credit Risk: Investments in bonds and other fixed income securities are subject to the risk that the
issuer(s) may not make required interest payments. An issuer suffering an adverse change in its financial
condition could lower the credit quality of a security, leading to greater price volatility of the security.
A lowering of the credit rating of a security may also offset the security's liquidity, making it more
difficult to sell. Funds investing in lower quality debt securities are more susceptible to these problems
and their value may be more volatile.
Foreign Exchange Risk: Foreign investments may be affected favorably or unfavorably by exchange
control regulations or changes in the exchange rates. Changes in currency exchange rates may influence
the share value, the dividends or interest earned and the gains and losses realized. Exchange rates
between currencies are determined by supply and demand in the currency exchange markets, the
international balance of payments, governmental intervention, speculation, and other economic and
political conditions. If the currency in which a security is denominated appreciates against the U.S.
Dollar, the value of the security will increase. Conversely, a decline in the exchange rate of the currency
would adversely affect the value of the security.
Risks Associated with Investing in Equities: Investments in equities generally refers to buying shares
of stocks by an individual or firms in return for receiving a future payment of dividends and capital gains
if the value of the stock increases. There is an innate risk involved when purchasing a stock that it may
decrease in value and the investment may incur a loss.
Recommendation of Particular Types of Securities: As disclosed under the Advisory Business section
in this brochure, we recommend all types of securities and we do not necessarily recommend one
particular type of security over another since each client has different needs and different tolerance for
risk. Each type of security has its own unique set of risks associated with it and it would not be possible
to list here all of the specific risks of every type of investment. Even within the same type of investment,
risks can vary widely. However, in very general terms, the higher the anticipated return of an
investment, the higher the risk of loss associated with that investment.
Concentrated Position Risk: Certain Associated Persons may recommend that clients concentrate
account assets in an industry or economic sector. In addition to the potential concentration of accounts
in one or more sectors, certain accounts may, or may be advised to, hold concentrated positions in
specific securities. Therefore, at times, an account may, or may be advised to, hold a relatively small
number of securities positions, each representing a relatively large portion of assets in the account. As
a result, the account will be subject to greater volatility than a more sector-diversified portfolio.
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Investments in issuers within an industry or economic sector that experiences adverse economic,
business, political conditions or other concerns will impact the value of such a portfolio more than if
the portfolio’s investments were not so concentrated. A change in the value of a single investment
within the portfolio will affect the overall value of the portfolio and will cause greater losses than it
would in a portfolio that holds more diversified investments.
Preferred Securities Risk: Preferred securities have similar characteristics to bonds in that preferred
securities are designed to make fixed payments based on a percentage of their par value and are senior
to common stock. Like bonds, the market value of preferred securities is sensitive to changes in interest
rates as well as changes in issuer credit quality. Preferred securities, however, are junior to bonds with
regard to the distribution of corporate earnings and liquidation in the event of bankruptcy. Preferred
securities that are in the form of preferred stock also differ from bonds in that dividends on preferred
stock must be declared by the issuer’s board of directors, whereas interest payments on bonds
generally do not require action by the issuer’s board of directors, and bondholders generally have
protections that preferred stockholders do not have, such as indentures that are designed to guarantee
payments – subject to the credit quality of the issuer – with terms and conditions for the benefit of
bondholders. In contrast preferred stocks generally pay dividends, not interest payments, which can be
deferred or stopped in the event of credit stress without triggering bankruptcy or default. Another
difference is that preferred dividends are paid from the after-tax profits, while bond interest is paid
before taxes.
Risks Associated with Investing in Mutual Funds: Mutual funds are professionally managed collective
investment systems that pool money from many investors and invest in stocks, bonds, short-term
money market instruments, other mutual funds, other securities, or any combination thereof. The fund
will have a manager that trades the fund's investments in accordance with the fund's investment
objective. While mutual funds generally provide diversification, risks can be significantly increased if
the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative
companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular
type of security (i.e., equities) rather than balancing the fund with different types of securities. The
returns on mutual funds can be reduced by the costs to manage the funds. In addition, while some
mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of mutual funds do
charge such fees which can also reduce returns.
Risks Associated with Investing in Exchange Traded Funds (ETF): Investing in stocks & ETF's carries the
risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments
in these securities are not guaranteed or insured by the FDIC or any other government agency. Detailed
information about the risks associated with each ETF is provided in the relevant ETF’s prospectus. Below
are some specific risks related to the ETFs recommended by our firm:
• Leveraged and Inverse ETF Risk: A leveraged ETF generally seeks to deliver multiples of the
daily performance of the index or benchmark that it tracks. An inverse ETF generally seeks to
deliver the opposite of the daily performance of the index or benchmark that it tracks. Inverse
ETFs often are marketed as a way for investors to profit from, or at least hedge their exposure
to, downward-moving markets. Some ETFs are both inverse and leveraged, meaning that they
seek a return that is a multiple of the inverse performance of the underlying index. To
accomplish their objectives, leveraged and inverse ETFs use a range of investment strategies,
including swaps, futures contracts and other derivative instruments. Leveraged, inverse, and
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leveraged inverse ETFs are more volatile and riskier than traditional ETFs due to their exposure
to leverage and derivatives, particularly total return swaps and futures. At times, we will
recommend leveraged and/or inversed ETFs, which may amplify gains and losses.
Most leveraged ETFs are typically designed to achieve their desired exposure on a daily (in a
few cases, monthly) basis, and reset their leverage daily. A "single day" is measured from the
time the leveraged ETF calculates its net asset value ("NAV") to the time of the leveraged ETF's
next NAV calculation. The return of the leveraged ETF for periods longer than a single day will
be the result of each day's returns compounded over the period. Due to the effect of this
mathematical compounding, their performance over longer periods of time can differ
significantly from the performance (or inverse performance) of their underlying index or
benchmark during the same period of time. For periods longer than a single day, the leveraged
ETF will lose money when the level of the Index is flat, and it is possible that the leveraged ETF
will lose money even if the level of the Index rises. Longer holding periods, higher index
volatility and greater leverage all exacerbate the impact of compounding on an investor's
returns. During periods of higher Index volatility, the volatility of the Index may affect the
leveraged ETF's return as much as or more than the return of the Index itself. Therefore, holding
leveraged, inverse, and leveraged inverse ETFs for longer periods of time increases their risk
due to the effects of compounding and the inherent difficulty in market timing. Leveraged ETFs
are riskier than similarly benchmarked ETFs that do not use leverage. Non-traditional ETFs are
volatile and not suitable for all investors. Positions in nontraditional ETFs should be monitored
closely due to their volatile nature and inability to track the underlying index over an extended
period of time. Clients should carefully read the prospectus for a leveraged and inverse ETF to
fully understand the cost structures, risks and features of these complex products.
• Buffer ETFs: Buffer ETFs are also known as defined-outcome ETFs, since the ETF is designed to
offer downside protection for a specified period of time. These ETFs are modeled after options-
based structured notes, but are generally cheaper, and offer more liquidity. Buffer ETFs are
designed to safeguard against market downturns by employing complex options strategies.
Buffer ETFs typically charge higher management fees that are considerably more than the index
funds whose performance they attempt to track. Additionally, because buffer funds own
options, they do not receive dividends from their equity holdings. Both factors result in the
underperformance of the Buffer ETF compared to the index they attempt to track. Clients
should carefully read the prospectus for a buffer ETF to fully understand the cost structures,
risks and features of these complex products.
Environment, Social and Governance Investment Criteria Risk: If a portfolio is subject to certain
environmental, social and governance (ESG) investment criteria it may avoid purchasing certain
securities for ESG reasons when it is otherwise economically advantageous to purchase those securities,
or may sell certain securities for ESG reasons when it is otherwise economically advantageous to hold
those securities. In general, the application of portfolio’s ESG investment criteria may affect the
portfolio’s exposure to certain issuers, industries, sectors and geographic areas, which may affect the
financial performance of the portfolio, positively or negatively, depending on whether these issuers,
industries, sectors or geographic areas are in or out of favor. An adviser or vendor can vary materially
from other ESG advisers and vendors with respect to its methodology for constructing ESG portfolios
or screens, including with respect to the factors and data that it collects and evaluates as part of its
process. As a result, an adviser’s or vendor’s ESG portfolio or screen may materially differ from or
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contradict the conclusions reached by other ESG advisers or vendors with respect to the same issuers.
Further, ESG criteria is dependent on data and is subject to the risk that such data reported by issuers
or received from third party sources may be subjective, or may be objective in principal but not verified
or reliable.
Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in
cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices
designed to protect networks, systems, computers, programs, and data from cyber-attacks and hacking
by other computer users, and to avoid the resulting damage and disruption of hardware and software
systems, loss or corruption of data, and/or misappropriation of confidential information.
In general, cyber-attacks are deliberate; however, unintentional events may have similar effects. Cyber-
attacks may cause losses to clients by interfering with the processing of transactions, affecting the
ability to calculate net asset value or impeding or sabotaging trading. Clients may also incur substantial
costs as the result of a cybersecurity breach, including those associated with forensic analysis of the
origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use
of proprietary information, litigation, and the dissemination of confidential and proprietary
information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or
action. In addition, clients could be exposed to additional losses as a result of unauthorized use of their
personal information.
While our firm has established a business continuity plan and systems designed to prevent cyber-
attacks, there are inherent limitations in such plans and systems, including the possibility that certain
risks have not been identified. Similar types of cybersecurity risks are also present for issuers of
securities, investment companies and other investment advisers in which we invest, which could result
in material adverse consequences for such entities and may cause a client's investment in such entities
to lose value.
Pandemic Risk: Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality
over a wide geographic area, crossing international boundaries, and causing significant economic,
social, and political disruption. It is difficult to predict the long-term impact of such events because they
are dependent on a variety of factors including the global response of regulators and governments to
address and mitigate the worldwide effects of such events. Workforce reductions, travel restrictions,
governmental responses and policies and macroeconomic factors will negatively impact investment
returns.
Recommendation of Other Advisers: In the event we recommend a third-party investment adviser to
manage all or a portion of your assets, we will advise you on how to allocate your assets among various
classes of securities or third-party investment managers, programs, or managed model portfolios. As
such, we will primarily rely on investment model portfolios and strategies developed by the third-party
investment advisers and their portfolio managers. If there is a significant deviation in characteristics or
performance from the stated strategy and/or benchmark, we may recommend changing models or
replacing a third-party investment adviser.
The primary risk associated with investing with a third party is that, while a particular third party may
have demonstrated a certain level of success in the past, it may not be able to replicate that success in
future markets. In addition, as we do not control the underlying investments in third party model
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portfolios, there is also a risk that a third party may deviate from the stated investment mandate or
strategy of the portfolio, making it a less suitable investment for our clients. To mitigate this risk, we
seek third parties with proven track records that have demonstrated a consistent level of performance
and success over time.
A third party’s past performance is not a guarantee of future results and certain market and economic
risks exist that may adversely affect an account’s performance that could result in capital losses in your
account. Please refer to the third-party investment adviser’s advisory agreements, Form ADV Brochure,
and associated disclosure documents for details on their specific investment strategies, methods of
analysis, and associated risks.
Cryptocurrency Risk: Cryptocurrency (e.g., bitcoin and ether), often referred to as “virtual currency”,
“digital currency”, or “digital assets”, is designed to act as a medium of exchange. Cryptocurrency is an
emerging asset class. There are thousands of cryptocurrencies, the most well-known of which is bitcoin.
Certain of the firm’s clients may have exposure to bitcoin or another cryptocurrency, directly or
indirectly through an investment such as an ETF or other investment vehicles.
Cryptocurrency operates without central authority or banks and is not backed by any government.
Cryptocurrencies may experience very high volatility and related investment vehicles may be affected
by such volatility. As a result of holding cryptocurrency, certain of the firm’s clients may also trade at a
significant premium or discount to NAV. Cryptocurrency is also not legal tender. Federal, state or
foreign governments may restrict the use and exchange of cryptocurrency, and regulation in the U.S. is
still developing. The market price of many cryptocurrencies, including bitcoin, has been subject to
extreme fluctuations. If cryptocurrency markets continue to be subject to sharp fluctuations, investors
may experience losses if the value of the client’s investments decline. Similar to fiat currencies (i.e., a
currency that is backed by a central bank or a national, supra-national or quasi-national organization),
cryptocurrencies are susceptible to theft, loss and destruction. Cryptocurrency exchanges and other
trading venues on which cryptocurrencies trade are relatively new and, in most cases, largely
unregulated and may therefore be more exposed to fraud and failure than established, regulated
exchanges for securities, derivatives and other currencies. The SEC has issued a public report stating
U.S. federal securities laws require treating some digital assets as securities.
Cryptocurrency exchanges may stop operating or permanently shut down due to fraud, technical
glitches, hackers or malware. Due to relatively recent launches, most cryptocurrencies have a limited
trading history, making it difficult for investors to evaluate investments. Generally, cryptocurrency
transactions are irreversible such that an improper transfer can only be undone by the receiver of the
cryptocurrency agreeing to return the cryptocurrency to the original sender. Digital assets are highly
dependent on their developers and there is no guarantee that development will continue or that
developers will not abandon a project with little or no notice. Third parties may assert intellectual
property claims relating to the holding and transfer of digital assets, including cryptocurrencies and
their source code. Any threatened action that reduces confidence in a network’s long-term ability to
hold and transfer cryptocurrency may affect investments in cryptocurrencies.
Many significant aspects of the U.S. federal income tax treatment of investments in cryptocurrency are
uncertain and an investment in cryptocurrency may produce income that is not treated as qualifying
income for purposes of the income test applicable to regulated investment companies. Certain
cryptocurrency investments may be treated as a grantor trust for U.S. federal income tax purposes, and
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an investment by the firm’s clients in such a vehicle will generally be treated as a direct investment in
cryptocurrency for tax purposes and “flow-through” to the underlying investors.
Direct Indexing: Direct indexing strategies seek to replicate the performance of a market index by
directly holding the individual securities, or a representative sample of the individual securities, that
make up the index. Direct indexing can provide a more tax efficient means of investing, and allows for
more customized investment allocations, than investing in a fund or other commingled product that
seeks to replicate the index. The potential benefits of direct indexing, however, will not necessarily be
realized if a client does not take advantage of tax planning or impose account restrictions, such as
account level security or sector-based restrictions or customizations based on specific tax,
Environmental, Social, and Governance or other preferences. Fees and expenses for the direct indexing
strategy in some cases will be higher than the fees and expenses associated with alternative index
products. Higher fees and expenses could adversely impact account performance. The size of the
account and the number of securities in the index the account seeks to replicate also limit the ability of
the account to replicate the index. As a result, the direct indexing strategy introduces the risk of tracking
error relative to the index and can cause a portfolio to underperform the index, including as a result of
customization.
Securities Backed Lines of Credit (SBLOCs): SBLOCs are non-purpose loans where you pledge assets in
your account as collateral in return for a loan. The loan proceeds can be used for purposes other than
to purchase or trade securities. Depending on your objectives, we can help you apply for a SBLOC. This
can be a strategic alternative to liquidating assets to pay for unexpected expenses, a business
opportunity, or a personal goal, any of which could trigger capital gain taxes. While we do not receive
a fee for arranging these loans, our assistance in this process presents a conflict of interest, as we have
an incentive for you to maintain these assets in your account instead of liquidating them, as liquidation
could decrease the asset-based fees that we earn for managing your account. To address this conflict,
we only make recommendations to obtain such loans when we believe obtaining a SBLOC is in the best
interests of clients. Clients should note that they retain the ultimate decision to obtain such loans. The
following are some of the primary risks associated with obtaining a SBLOC:
•
Interest rate payments on the principal balance of the loan are not fixed and may increase;
•
If the value of the securities pledged as collateral decrease, you will be liable for any deficiency;
• The lender can force the sale or liquidation of securities held as collateral without contacting
you in advance to meet collateral requirements and you are not entitled to choose which
securities are liquidated or sold;
• You are only entitled to draw on the line to the extent there is credit availability; and
• There may be additional risks when money funds or similar investments may produce less
interest income or other yield than the interest you are paying on the loan.
We urge our clients to carefully read all disclosures and agreements prior to entering into an SBLOC or
non-purpose loan. While we can assist in the application process, we are not involved in the approval
process.
Political Risk: Each administration presents its own set of policy risks that could impact investors. One
of the policy tools that an administration can implement is the imposition of tariffs, or the threats
thereof. The scope, implementation, and duration of tariffs can create uncertainty domestically and
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globally. Industries that rely on imported raw material or that have heavily integrated cross-border
manufacturing practices may be most impacted by the imposition of tariffs. However, it is challenging
to predict the impact of actual and/or threatened tariffs and impossible to predict future policy
decisions. When tariffs are imposed, there is also a higher probability that retaliatory tariffs could be
imposed, which could further impact industries and products. Tariffs in general can also permanently
alter global supply chains and have far-reaching indirect impacts. Tariffs can hurt economic growth and
add to inflation, which can lead to rising interest rates.
Artificial Intelligence ("AI") Risk: We may rely on programs and systems that utilize AI, machine
learning, probabilistic modeling, and other data science technologies ("AI Tools") when delivering our
services. AI Tools are also used to record and transcribe client meetings. Clients should note that AI
Tools are highly complex, and are known to have been flawed, hallucinate, reflect biases included in
the data on which such tools are trained, be of poor quality, or be otherwise harmful. AI Tools present
Cybersecurity Risk. The U.S. and global legal and regulatory environment relating to the use of AI Tools
is uncertain and rapidly evolving, and could require changes in the firm’s implementation of AI Tools
and increase compliance costs and the risk of non-compliance. Further, the firm may rely on AI Tools
developed by third parties, and the firm has limited control over the accuracy and completeness of such
AI Tools. Clients who do not want us to record their meetings have the option to opt out at the time of
the meeting.
Disciplinary Information - Item 9
Registered investment advisers are required to disclose all material facts regarding any legal or
disciplinary events that would be material to your evaluation of us or the integrity of our management.
There is no history of reportable material legal or disciplinary events by our firm, our management, or
advisory representatives.
Other Financial Industry Activities or Affiliations - Item 10
AIS Planning is a licensed insurance agency that sells fixed insurance products. Cathy L. Juilfs, CEO, Jason
C Hallonquist, Senior Advisor, and other Associated Persons of AIS Planning, are licensed insurance
agents and can affect transactions in various insurance products, including life, health, disability, long-
term care, and annuities, among others. These individuals earn commissions for these activities. The
sale of annuity contracts or insurance products offered by Associated Persons are intended to
complement AIS Planning’s advisory services. However, a conflict of interest exists due to the receipt
of dual forms of compensation because Associated Persons have an incentive to recommend insurance
products based on the compensation to be received, rather than on a client’s needs. AIS Planning has
policies and procedures in place to monitor all client transactions and all client transaction costs will be
disclosed to the client. Clients to whom the firm offers advisory services are informed that they are
under no obligation to use the firm’s Associated Persons for insurance services and may use the
insurance brokerage firm and agent of their choice.
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Where AIS Planning finds an Associated Person has not acted in the best interest of the client, AIS
Planning may cancel the transaction. Alternatively, AIS Planning may deduct the commission costs from
the advisory fee paid by the client. In any event, all client transaction costs will be disclosed to the client.
Our Associated Persons spend a negligible amount of time in their capacities as insurance agents.
Recommendation of third-party investment managers
Historically, we have recommended the services of various third-party investment managers as part of
our asset allocation and investment strategy. AIS Planning shares in the compensation received by the
third-party investment manager for managing your account. The compensation arrangement presents
a conflict of interest due to a financial incentive to recommend the services of the third-party
investment manager based on the compensation received. You are not required to use the services of
any third-party investment manager we recommend.
Code of Ethics, Participation or Interest in Client Transactions and Personal Trading - Item 11
Description of Our Code of Ethics
AIS Planning has adopted a Code of Ethics (the “Code”) to address investment advisory conduct. The
Code focuses primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and
conflicts of interest. The Code includes AIS Planning’s policies and procedures developed to protect
clients’ interests in relation to the following topics:
• The duty at all times to place the interests of clients first;
• The requirement that all personal securities transactions be conducted in such a manner that
is consistent with the Code of Ethics;
• The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s
position of trust and responsibility;
• The fiduciary principle that information concerning the identity of security holdings and
financial circumstances of clients is confidential; and
• The principle that independence in the investment decision-making process is paramount.
You can request a copy of our Code of Ethics by calling us at (320) 252-6552 or mailing a request to our
principal office.
Personal Trading Practices
At times, AIS Planning and/or its Associated Persons may take positions in the same securities as clients,
which may pose a conflict of interest with clients. AIS Planning and its Associated Persons will generally
be “last in” and “last out” for the trading day when trading occurs in close proximity to client trades.
We will not violate our fiduciary responsibilities to our clients. Front running (trading shortly ahead of
clients) is prohibited. Should a conflict occur because of materiality (i.e., a thinly traded stock),
disclosure will be made to the client(s) at the time of trading. Incidental trading not deemed to be a
conflict (i.e., a purchase or sale which is minimal in relation to the total outstanding value, and as such
would have negligible effect on the market price) would not be disclosed at the time of trading.
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Brokerage Practices – Item 12
Suggestion of Broker
Clients invested through the various programs developed by SEI Investments Management Corporation
("SIMC"), are required to custody accounts with SEI Trust Company, (“SEI”), a wholly owned subsidiary
of SEI Investments. SEI is a federally registered thrift institution. Trades executed through SEI for SEI
funds are placed free of charge, as an accommodation to clients. However, accounts may be subject to
an annual custodial fee of up to $1,000. The exact fee will be listed in SEI’s account opening document.
Clients invested in the American Funds Program are required to custody accounts with American Funds.
All brokerage commissions, custodial fees and service charges, stock transfer fees, and other similar
charges incurred in connection with transactions for a client’s account will be paid out of the assets in
a client’s account or billed separately to the client (by the custodian) and is in addition to the investment
management fees paid to AIS Planning.
Research and Other Soft Dollar Benefits
Although not considered “soft dollar” compensation, AIS Planning may receive benefits from SEI/SIMC
or American Funds such as research services, reports, software, and institutional trading support.
Best Execution
AIS Planning will diligently comply with all federal securities laws regarding “best execution” to
ascertain the best markets for securities, and to buy or sell in such markets so prices to clients are as
favorable as possible under prevailing market conditions.
We are bound by ERISA and the Internal Revenue Code, and as such, are committed to avoiding
misleading statements about fees, investments, and services we provide, while disclosing basic
information about potential conflicts of interest that may arise while providing financial planning
services.
its duty for best execution and considers all factors
AIS Planning understands
in making
recommendations to its clients. These research services may be useful in servicing all AIS Planning
clients, and may not be used in connection with any particular account that may have paid
compensation to the firm in providing such services. While AIS Planning may not always obtain the
lowest commission rate, AIS Planning believes the rate is reasonable in relation to the value of the
brokerage and research services provided.
Brokerage for Client Referrals
AIS Planning does not receive client referrals from broker-dealers and custodians in which we have an
institutional advisory arrangement. Also, we do not receive other benefits from a broker-dealer in
exchange for client referrals.
Directed Brokerage
Clients invested through the various programs developed by SIMC are required to custody accounts
with SEI and clients invested in the American Funds Program are required to custody accounts with
American Funds. The client may direct brokerage to a specified broker-dealer other than the firm
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recommended by AIS Planning. However, the client will not be able to participate in the firm’s
recommended investment programs.
In client directed brokerage arrangements, it is up to the client to negotiate the commission rate, as AIS
Planning will not. The client may not be able to negotiate the most competitive rate and as a result,
may pay more than the rate available through the custodian used by AIS Planning. In client-directed
brokerage arrangements, the client may not be able to participate in aggregated (“blocked”) trades,
which may help reduce the cost of execution. Where the client does not otherwise designate a broker
dealer, AIS Planning recommends broker dealers with competitive commission rates.
Review of Accounts - Item 13
AIS Planning will monitor your portfolio’s performance on a continuous basis. Portfolio performance is
reviewed, at a minimum, on a quarterly basis. AIS Planning offers portfolio management clients an in-
person portfolio review meeting on an annual basis. We will also monitor the TPAs to ensure their
performance and investment style remains aligned with your investment goals and objectives.
The Associated Person assigned to each client relationship will conduct a formal account review once
every calendar year. The Chief Compliance Officer will oversee the Associated Persons' monitoring of
portfolios and financial plans for investment objectives and other supervisory review.
A financial plan is a snapshot in time and no on-going reviews are conducted. We recommend clients
engage us on an annual basis to update their financial plans.
Clients will receive statements directly from their account custodian(s) on at least a quarterly basis.
Additionally, the TPA managing the client's account may provide performance reports.
Client Referrals and Other Compensation - Item 14
We do not receive economic benefits from third parties in exchange for providing investment advice or
other advisory services to our clients. However, as disclosed in the Research and Other Soft Dollar
Benefits section above, we receive research and other benefits from SEI and SIMC.
Economic Benefits Received from Vendors and Product Sponsors
Occasionally, our firm and our Associated Persons will receive additional compensation from vendors.
Compensation could include such items as gifts; an occasional dinner or ticket to a sporting event;
reimbursement in connection with educational meetings with an Associated Person, reimbursement
for consulting services, client workshops, or events; or marketing events or advertising initiatives,
including services for identifying prospective clients. Receipt of additional economic benefits presents
a conflict of interest because our firm and Associated Persons have an incentive to recommend and use
vendors based on the additional economic benefits obtained rather than solely on the client’s needs.
We address this conflict of interest by recommending vendors that we, in good faith, believe are
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appropriate for the client’s particular needs. Clients are under no obligation contractually or otherwise,
to use any of the vendors recommended by us.
Recommendation of third-party investment managers
Historically, we have recommended the services of various third-party investment managers as part of
our asset allocation and investment strategy. AIS Planning shares in the compensation received by the
third-party investment manager for managing your account. The compensation arrangement presents
a conflict of interest due to a financial incentive to recommend the services of the third-party
investment manager based on the compensation received. You are not required to use the services of
any third-party investment manager we recommend.
We and our related persons do not compensate, either directly or indirectly, any person or entity who
is not our supervised person for client referrals.
Custody - Item 15
We do not have physical custody of any of your funds and/or securities. Your funds and securities will
be held with a bank, broker-dealer, or other independent, qualified custodian.
In most cases, the third-party investment adviser (“TPA”) calculates and deducts advisory fees directly
from the client’s custodial account(s) pursuant to an authorization provided by you directly to the TPA.
The TPA remits a portion of the fees to AIS Planning. In such cases, AIS planning does not get involved
in the fee calculation or deduction process.
Occasionally, AIS planning will directly instruct the custodian to debit your account(s) for the payment
of certain advisory fees, such as fees for financial planning services. In such cases, AIS Planning is
deemed to exercise custody over your funds or securities.
With respect to third party standing letters of authorization (“SLOA”) where a client grants us authority
to direct custodians to disburse funds to one or more third party accounts, we are deemed to have
custody pursuant to Rule 206(4)-2 (the “Custody Rule”). We have taken steps to have controls and
oversight in place to comply with the no-action letter issued by the SEC on February 21, 2017 (the “SEC
no-action letter”). We are not required to comply with the surprise examination requirements of the
Custody Rule if we are in compliance with the representations noted in the SEC no-action letter. Where
our firm acts pursuant to a SLOA, we believe we are making a good faith effort to comply with the
representations noted in the SEC no-action letter. Additionally, since many of the representations noted
in the SEC no-action letter involve the qualified custodian’s operations, we will collaborate closely with
our custodian(s) to ensure that the representations are met.
You will receive account statements from the independent, qualified custodian(s) holding your funds
and securities at least quarterly. The account statements from your custodian(s) will indicate the
amount of our advisory fees deducted from your account(s) each billing period.
We urge our clients to review their account statements for accuracy. The custodial statement is the
official record of your account for tax purposes. If you have questions about your statements, or if you
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did not receive a statement from the qualified custodian, please call our office number located on the
cover page of this brochure.
Investment Discretion - Item 16
Our firm offers Ongoing Investment Management services to its advisory clients on a discretionary
basis. Clients must grant the firm discretionary authority in the Financial Service Agreement.
Discretionary portfolio management means we will make investment decisions and place portfolio
reallocation orders in your account without contacting you prior to each transaction.
If you wish, you may limit our discretionary authority by, for example, setting a limit on the type of
securities that can be purchased for your portfolio. Simply provide us with your restrictions or
guidelines in writing.
Voting Client Securities - Item 17
Proxy Voting
AIS Planning will not vote proxies on behalf of client accounts, although, at the client’s request, AIS
Planning may offer clients advice regarding corporate actions and the exercise of proxy voting rights
and/or materials.
Questions about proxies may be made via the contact information on the cover page.
Financial Information - Item 18
We are required in this Item to provide you with certain financial information or disclosures about AIS
Planning’s financial condition.
AIS Planning does not require the prepayment of over $1,200 six or more months in advance.
Additionally, AIS Planning has no financial commitment that impairs its ability to meet contractual and
fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding.
Requirements of State-Registered Advisers - Item 19
This section is not applicable because our firm is SEC registered.
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Miscellaneous
Class Action Lawsuits
From time to time, securities held in the accounts of clients will be the subject of class action lawsuits.
AIS Planning has no obligation to determine if securities held by the client are subject to a pending or
resolved class action lawsuit. It also has no duty to evaluate a client’s eligibility or to submit a claim to
participate in the proceeds of a securities class action settlement or verdict. Furthermore, the firm has
no obligation or responsibility to initiate litigation to recover damages on behalf of clients who may
have been injured as a result of actions, misconduct, or negligence by corporate management of issuers
whose securities are held by clients.
Where the firm receives written or electronic notice of a class action lawsuit, settlement, or verdict
affecting securities owned by a client, it will forward all notices, proof of claim forms, and other
materials to the client. Electronic mail is acceptable where appropriate, and if the client has authorized
contact in this manner.
AIS Planning Privacy Notice
This notice is being provided to you in accordance with the Securities and Exchange Commission’s rule
regarding the privacy of consumer financial information (“Regulation S-P”). Please take the time to read
and understand the privacy policies and procedures that we have implemented to safeguard your non-
public personal information.
INFORMATION WE COLLECT
AIS Planning must collect certain personally identifiable financial information about its customers to
provide financial services and products. The personally identifiable financial information that we gather
during the normal course of doing business with you may include:
•
•
•
information we receive from you on applications or other forms;
information about your transactions with us, our affiliates, or others;
information we receive from a consumer reporting agency.
INFORMATION WE DISCLOSE
We do not disclose any non-public personal information about our customers or former customers to
anyone, except as permitted or required by law, as necessary to provide services to you, or if you have
given us permission in writing. In accordance with Section 248.13 of Regulation S-P, we may disclose all
of the information we collect, as described above, to certain non-affiliated third parties such as our
attorneys, accountants, auditors, and persons or entities that are assessing our compliance with
industry standards. We enter into contractual agreements with all non-affiliated third parties that
prohibit such third parties from disclosing or using the information other than to carry out the purposes
for which we disclose the information.
Regulation S-AM: Under Regulation S-AM, we are prohibited from using eligibility information that we
receive from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that
information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the consumer
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has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing
solicitations; and (3) the consumer has not opted out. We do not receive information regarding
marketing eligibility from affiliates to make solicitations.
Regulation S-ID: Regulation S-ID requires our firm to have an Identity Theft Protection Program (“ITPP”)
that controls reasonably foreseeable risks to customers or to the safety and soundness of our firm from
identity theft. We have developed an ITPP to adequately identify and detect potential red flags to
prevent and mitigate identity theft.
CONFIDENTIALITY AND SECURITY
We restrict access to non-public personal information about you to those Employees who need to know
that information to provide financial products or services to you. We maintain physical, electronic, and
procedural safeguards that comply with federal standards to guard your non-public personal
information.
ACCURACY
AIS Planning strives to maintain accurate personal information in our client files at all times. However,
as personal situations, facts and data change over time, we encourage our clients to provide feedback
and updated information to help us meet our goals.