Overview
- Headquarters
- Columbia, MO
- Average Client Assets
- $1.6 million
- SEC CRD Number
- 117153
Fee Structure
Primary Fee Schedule (FORM ADV PART 2A BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $2,000,000 | 1.00% |
| $2,000,001 | $2,500,000 | 0.85% |
| $2,500,001 | $5,000,000 | 0.75% |
| $5,000,001 | and above | 0.50% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $43,000 | 0.86% |
| $10 million | $68,000 | 0.68% |
| $50 million | $268,000 | 0.54% |
| $100 million | $518,000 | 0.52% |
Clients
- HNW Share of Firm Assets
- 80.39%
- Total Client Accounts
- 3,005
- Discretionary Accounts
- 2,996
- Non-Discretionary Accounts
- 9
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
Primary Brochure: FORM ADV PART 2A BROCHURE (2026-03-31)
View Document Text
PART 1 ITEM 1 – COVER PAGE
FORM ADV PART 2A – FIRM BROCHURE
MARCH 27, 2026
ALEXANDER LABRUNERIE &CO., INC.
DBA LABRUNERIE FINANCIAL
601 WEST NIFONG BOULEVARD, SUITE 3B
COLUMBIA, MO 65203-6804
573-449-5313
www.labrunerie.com
This brochure provides information about the qualifications and business practices of Alexander LaBrunerie &
Co., Inc. (“LaBrunerie”) DBA LaBrunerie Financial. If you have any questions about the contents of this
brochure, please contact us at 573-449-5313. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state securities authority. Alex
LaBrunerie & Co., Inc. is a Registered Investment Adviser. Registration as an Investment Adviser with the
United States Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
Additional information about LaBrunerie is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this
site by a unique identifying number, known as a IARD number. The IARD number for LaBrunerie is 117153.
ITEM 2 – MATERIAL CHANGES
SUMMARY OF MATERIAL CHANGES
This section of the Brochure will address only those “material changes” that have been incorporated since
our
last delivery or posting of this document on the SEC’s public disclosure website (IAPD)
www.adviserinfo.sec.gov.
Since our last annual update on March 25, 2025 24 the following material changes have been made:
•
•
Item 5 has been updated to clarify fees for Financial Portraits
Item 14 has been updated to reflect the firms use of Promoters for client referrals.
Currently, a free copy of our Brochure may be requested by contacting Alex LaBrunerie at 573-449-5313,
or alex@labrunerie.com.
We encourage you to read this document in its entirety.
ALEXANDER LABRUNERIE& CO., INC.
MARCH 2026 | PAGE 2 OF 24
ITEM 3 - TABLE OF CONTENTS
PART 1 ITEM 1 – COVER PAGE ................................................................................................................. 1
ITEM 2 – MATERIAL CHANGES ................................................................................................................ 2
ITEM 4 – ADVISORY BUSINESS ................................................................................................................ 4
ITEM 5 - FEES AND COMPENSATION ....................................................................................................... 8
ITEM 6 – PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............................................. 11
ITEM 7 - TYPES OF CLIENTS ................................................................................................................... 11
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS .................................. 11
ITEM 9 - DISCIPLINARY INFORMATION .................................................................................................. 15
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................................................. 15
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL
TRADING .............................................................................................................................................. 16
ITEM 12 - BROKERAGE PRACTICES ......................................................................................................... 17
ITEM 13 - REVIEW OF ACCOUNTS .......................................................................................................... 21
ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION .................................................................. 22
ITEM 15 – CUSTODY .............................................................................................................................. 22
ITEM 16 – INVESTMENT DISCRETION .................................................................................................... 23
ITEM 17 – VOTING YOUR SECURITIES .................................................................................................... 23
ITEM 18 – FINANCIAL INFORMATION .................................................................................................... 24
ALEXANDER LABRUNERIE& CO., INC.
MARCH 2026 | PAGE 3 OF 24
ITEM 4 – ADVISORY BUSINESS
This Disclosure document is being offered to you by Alexander LaBrunerie & Co., Inc., DBA LaBrunerie
Financial (“AFL” or “Firm”) about the investment advisory services we provide. It discloses information
about our services and the way those services are made available to you, the client.
We are an investment management firm located in Columbia, Missouri. We specialize in investment
advisory services for individuals, high-net-worth individuals, trusts, corporations and other businesses,
pension and profit-sharing plans, and charitable organizations. Our Firm was founded in 1995 as a
registered investment adviser. Alexander LaBrunerie, the firm’s President, is an 80% owner. Other owners
include Leslie Wilbers and Bret Rodabaugh, both 10% owners.
We are committed to helping clients build, manage, and preserve their wealth and provide clarity and
direction to help clients achieve their stated financial goals. We will offer an initial complimentary meeting
at our discretion; however, investment advisory services are initiated only after you and AFL execute a
signed Investment Advisory Agreement.
INVESTMENT AND WEALTH MANAGEMENT AND SUPERVISION SERVICES
We manage advisory accounts on a discretionary and non-discretionary basis, including 529 Education
Savings Accounts and no-load Variable Annuities. For discretionary accounts, once we have determined a
profile and investment plan with a client, we will execute the day-to-day transactions without seeking prior
client consent. The client profile and investment plan guide account supervision. We may accept accounts
with certain restrictions if circumstances warrant. We primarily allocate client assets among various
investments such as preferred stocks, commons stocks, Exchanged Traded Funds (“ETFs”), no-load or load-
waived mutual funds, no-load annuities, fixed income bonds, REITS, corporate bonds, municipal bonds,
money markets, CDs, U.S. Treasuries, and cash positions in accordance with their stated investment
objectives. We select money market funds based on ease of use and interest rate. All positions are
considered asset allocation categories for the client’s investment strategy.
Where deemed appropriate, we may recommend that our clients invest in alternative assets, including
hedge funds, private equity funds, real estate funds, and other alternative funds. Although the Investment
Advisory Agreement with our Clients gives us broad investment authority, we do not anticipate investing in
other security types. However, from time to time, we will consider incorporating socially responsible
investing (Sustainable Investing Strategies (“SIS”) or Environment, Social, and Governance Strategies
(“ESG”) for those Clients who wish to align their portfolios with their personal preferences for Impact
Investing. This may include investing in both public and private markets. A Client’s investment allocation
and our strategy will depend on the Client's responses in review meetings, written questionnaires, stated
goals, risk tolerance, objectives, and personal preference for Impact Investing.
Clients are advised to promptly notify us if there are changes in their financial situation or if they wish to
place any limitations on managing their portfolios.
During discussions with clients, we determine the client’s objectives, time horizons, risk tolerance, and
liquidity needs. As appropriate, we also review a client’s prior investment history, as well as family
composition and background. We develop a client’s personal profile and investment plan based on client
needs. We then create and manage the client’s investments based on that profile and plan.
In performing our services, we shall not be required to verify any information received from the client or
the client’s other professionals on their behalf. The client gives their express permission that we may rely
ALEXANDER LABRUNERIE& CO., INC.
MARCH 2026 | PAGE 4 OF 24
on this information. The client’s obligated to notify us immediately if circumstances have changed with
respect to their goals or changes in their financial condition.
Once we have determined the types of investments to be included in your portfolio and allocated them, we
will provide ongoing investment review and management services. This approach requires us to review
your portfolio periodically.
We tailor our advisory services to meet the needs of our clients and seek to ensure that your portfolio is
managed in a manner consistent with those needs and objectives. You can leave standing instructions with
us to refrain from investing in particular industries or invest in limited amounts of securities.
In all cases, you have a direct and beneficial interest in your securities, rather than an undivided interest in
a pool of securities. We have limited authority to direct the custodian to deduct our investment advisory
fees from your accounts, but only with your appropriate written authorization.
Where appropriate, we provide advice about any type of legacy position held in client portfolios. Typically,
these are ineligible assets to be custodied at our primary custodian. Clients will engage us to advise on
certain investment products not maintained at their primary custodian, such as variable life insurance,
annuity contracts, 529 education accounts, and assets held in employer-sponsored retirement plans.
You are advised and expected to understand that our past performance does not guarantee future results.
Certain capital market and economic risks exist that adversely affect an account’s performance. This could
result in capital losses in your account.
FINANCIAL PLANNING
Through the financial planning process, commonly referred to as the Financial Portrait, we strive to engage
our clients in conversations around the family’s goals, objectives, priorities, vision, and legacy – both for the
near term as well as for future generations. With the unique goals and circumstances of each family in
mind, our team will offer financial planning ideas and strategies to address the client’s holistic financial
picture, including estate, income tax, charitable donations, cash flow, long-term health care needs wealth
transfer, and family legacy, family educational plans for grandchildren, nieces, and nephews. Our team
works with our client’s other advisors (CPAs, Enrolled Agents, Estate Attorneys, Insurance Brokers, etc.) to
coordinate all parties' efforts toward the client’s stated goals. Such services include reports on specific
goals and objectives, general investment and/or planning recommendations, guidance to outside assets,
and periodic updates.
Our specific services in preparing your plan may include:
§ Review and clarification of your financial goals, such as retirement date
§ Assessment of your overall financial position, including cash flow, balance sheet, investment
strategy, risk management, and estate planning
§ Creation of a unique plan for each goal you have, including personal real estate, education,
retirement or financial independence, charitable giving, limited estate planning, and other
personal goals
§ Development of a goal-oriented investment plan, with input from various advisors to our clients
around tax suggestions, asset allocation, expenses, risk, and liquidity factors for each goal. This
includes IRA and qualified plans, taxable and trust accounts that require special attention
§ Design of a risk management plan including risk tolerance, risk avoidance, mitigation, and transfer,
including liquidity as well as various insurance and possible company benefits; and
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MARCH 2026 | PAGE 5 OF 24
§ Crafting and implementation of, in conjunction with your estate and/or corporate attorneys and a
tax advisor, an estate settlement to provide for you in the event of an incapacity or death
Clients are obligated to answer questions and provide accurate information regarding their current financial
situation and goals on an ongoing basis. In performing its services, Alexander LaBrunerie & Co. is not
obligated to verify any information received from the client or the clients other professional service
providers and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their
responsibility to promptly notify Alexander LaBrunerie & Co. if ever there is any change in their financial
situation or investment objectives to review, evaluate, or revise Alexander LaBrunerie & Co.’s previous
recommendations or services.
An evaluation of each client's initial situation or Financial Plan is provided to the client. Alexander
LaBrunerie & Co. does not advise on social security, Medicare, or Medicaid programs. We provide pertinent
information to assist the client in making an informed decision. An annual review will be provided by AFL,
if indicated by the client and the Firm per the Agreement. More frequent reviews occur but are not
necessarily communicated to the client unless immediate changes are recommended. Financial Plans are
not estate and tax plans, and Alexander LaBrunerie & Co. does not warrant their Financial Plans as such.
Beneficiary reviews of each account and the updating of primary and contingent beneficiaries is the
responsibility of the client.
The client will be solely responsible for accepting or rejecting the Planner’s financial planning advice and
implementing any such investment recommendations. Planner may recommend itself, one of its affiliates,
or a third party to assist the Client with the implementation of Planner’s financial planning advice. A conflict
of interest exists where the planner recommends itself or any of its affiliates to implement any such advice.
The client understands that the client may choose any advisor, brokerage firm, or other professionals to
implement the recommendations and advice given by the Planner. If the client engages any such
recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees
to seek recourse exclusively from and against the engaged professional/firm and hold harmless the Planner
and AFL, including any affiliates, from any and all damages or losses incurred by outside professionals AFL
refers to the client. employees and affiliates
Long term plans are not guaranteed, and future projections may turn out to be inaccurate. Inaccurate plans
may result in capital depletion and loss of income.
These services end upon your death and are not transferable to your heirs, beneficiaries or estate unless
previously agreed to in writing by all parties.
CONSULTING SERVICES
We also provide clients investment advice on a more-limited basis on one-or-more isolated areas of concern,
real estate, and/or advice.
In these consultation engagements, you will be required to select your own investment managers,
custodian and/or insurance companies for the implementation of consulting recommendations. If your
needs include brokerage and/or other financial services, we will recommend the use of one of several
investment managers, brokers, banks, custodians, insurance companies or other financial professionals.
You must independently evaluate these firms before opening an account or transacting business, and you
have the right to effect business through any firm you choose.
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RETIREMENT PLAN CONSULTING SERVICES
Retirement Plan Consulting Services includes providing participant enrollment meetings and assisting with
participant education. While the primary clients for these services will be pension, profit sharing and 401(k)
plans, we offer these services, where appropriate, to individuals and trusts and organizations.
When serving as an ERISA 3(21) investment advisor, the Plan Sponsor, and Our Firm share fiduciary
responsibility. The Plan Sponsor retains ultimate decision-making authority for the investments and may
accept or reject the recommendations in accordance with the terms of a separate ERISA 3(21) Plan Sponsor
Investment Advisory Agreement between our Firm and the Plan Sponsor. Under the 3(21) agreement. Our
Firm provides the following services to the Plan Sponsor:
Screen investments and make recommendations.
Provide a quarterly monitoring report.
§
§ Monitor the investments and suggests replacement investments when appropriate.
§
§ Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
§ Recommend QDIA alternatives.
§ Recommend non-discretionary model portfolios.
We can also be engaged to provide Plan Consulting Services. Plan Consulting Services include financial
education to Plan participants, participant seminars, benchmarking the Plan services, education to fiduciary
committee members, and monitoring the service provider. The scope of education provided to participants
will not constitute “investment advice” within the meaning of ERISA, and participant education will relate
to general principles for investing and information about the investment options currently in the Plan. We
may also participate in initial enrollment meetings and periodic workshops and enrollment meetings for
new participants.
Disclosure Regarding Rollover Recommendations
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to
you regarding your retirement plan account or individual retirement account, we are also fiduciaries within
the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code,
as applicable, which are laws governing retirement accounts. We have to act in your best interest and not
put our interest ahead of yours. At the same time, the way we make money creates some conflicts with
your interests.
A client or prospect leaving an employer typically has four options regarding an existing retirement plan
(and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if
permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted,
(iii) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an
investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a result,
our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that a client
or prospective client leave their plan assets with their previous employer or roll over the assets to a plan
sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore has
an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage, which
presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our Firm
will consider before recommending a rollover, including but not limited to: (i) the investment options
available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan
versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment
ALEXANDER LABRUNERIE& CO., INC.
MARCH 2026 | PAGE 7 OF 24
professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v)
required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any.
Our Firm’s Chief Compliance Officer remains available to address any questions that a client or prospective
client has regarding the oversight.
WRAP FEE PROGRAM
We do not participate in a Wrap Fee Program.
ASSETS
As of December 31, 2025, we managed a total of $618,861,751 in assets under management. $615,864,689
was managed on a discretionary basis and $2,997,062 was managed on a non-discretionary basis.
ITEM 5 - FEES AND COMPENSATION
INVESTMENT MANAGEMENT FEES AND COMPENSATION
Our Firm charges a fee as compensation for providing Investment advisory services on your account. These
services include advisory services, trade entry, investment supervision, and other account maintenance
activities. Our Custodians charges transaction costs, custodial fees, redemption fees, retirement plan and
administrative fees or commissions. These fees assessed by both Alexander LaBrunerie & Co. and its
custodians will reduce your account’s overall returns and performance. See Additional Fees and Expenses
below for details.
Our maximum investment advisory fee is 1.0%, or we may negotiate a lower advisory fee at the firm’s
discretion. The specific advisory fees are set forth in your Investment Advisory Agreement with our Firm.
Fees may vary based on the size of the account, complexity of the portfolio, extent of activity in the account,
or other reasons agreed upon by us and you as the client. In certain circumstances, our fees and the timing
of the fee payments may be negotiated. Our employees and their family-related accounts are charged a
reduced fee for our services.
Fees are based on a tiered schedule as set forth below and are negotiable at the firm’s discretion.
Assets Under Management
Annual Tiered Advisory Fee Schedule
First $0 - $1,999,999.99
1.00%
$2,000,000 - $2,499,999.99
0.85%
$2,500,000 - $4,999,999.99
0.75%
Over $5,000,000
0.50%
Fees are billed quarterly in advance or arrears based on the market value of the account at the end of the
preceding quarter. Fees are assessed on all assets under management, including securities, cash,
certificates of deposit and money market balances. AFL uses the Charles Schwab Money Market. The
Charles Schwab money market may not be the highest-yielding money market fund. Margin account
balances are not included in the fee billing. Management fees are prorated for each capital contribution or
withdrawal made during a calendar quarter. Other advisers may have higher or lower fees than AFL.
ALEXANDER LABRUNERIE& CO., INC.
MARCH 2026 | PAGE 8 OF 24
The independent and qualified custodian holding your funds and securities will debit your account directly
for the advisory fee and pay that fee to us. You will provide written authorization permitting the fees to be
paid directly from your account held by the qualified custodian. Further, the qualified custodian agrees to
deliver an account statement to you at least a quarterly basis indicating all the amounts deducted from the
account including our advisory fees. Client can elect to be directly billed as an alternative.
Either AFL, or you may terminate the management agreement immediately upon written notice to the
other party. The management fee will be pro-rated to the date of termination for the month in which the
cancellation notice was given and the refunded. If a managed account transfers custodian outside of AFL
in the middle of a billing period, we do not pro-rate fees.
Upon termination, you are responsible for monitoring the securities in your account, and we will have no
further obligation to act or advise with respect to those assets. In the event of the client’s death or disability,
AFL will continue the management of the account until we are notified of the client’s death or disability and
given alternative instructions by an authorized party. Mutual Funds and ETFs charge additional fees not
included in AFL’s fee.
FINANCIAL PLANNING FEES
AFL will negotiate the planning fees with the client for stand-alone financial planning arrangements. The
Financial Portrait fee is $200/hour or complementary if assets under management are greater than
$250,000 at the time of agreement. The Financial Portrait fee may be waived.
Typically, we complete a plan within 30 days and will present it to the client within 90 days of the contract
date, provided that the client has provided us all information needed to prepare the financial plan. The
client may terminate the financial planning agreement by providing us with written notice. Upon
termination, fees will be prorated to the date of termination, and any unearned portion of the fee will be
refunded to the client based on an hourly rate of $200. Services provided up to date of termination but not
yet paid to AFL will be billed to the client based on the hourly rate of $200. We will not require prepayment
of more than $1,200 in fees per client and six (6) or more months in advance of providing any services.
In no case are AFL fees based on, or related to, the performance of the client’s funds or investments.
When both investment management or plan implementation and wealth planning services are offered,
there is a conflict of interest since there is an incentive for us offering Financial Portrait services to
recommend products or services for which AFL receives compensation. However, AFL will make all
recommendations independent of such considerations and based solely on our obligations to consider the
client’s objectives and needs. As a Financial Portrait client, the client has the right not to act upon any of
our recommendations and not affect the transaction(s) through us if the client decides to follow the
recommendations.
CONSULTING FEES
We provide consulting services for clients who need advice on a limited scope of work. We will negotiate
consulting fees with the client or charge $200-$500 per hour. The range of fees for Consulting Services may
vary based on the extent and complexity of the consulting project. Fees will be billed as services are
rendered. Either party may terminate the agreement. Upon termination, fees will be prorated to the date
of termination, and any unearned portion of the fee will be refunded to you as described in the Agreement.
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RETIREMENT PLAN CONSULTING SERVICES
For Retirement Plan Advisory Services compensation, we charge an annual fee as negotiated with the client
and as disclosed in the Employer Sponsored Retirement Plans Consulting Agreement (“Plan Consulting
Agreement”). The compensation method is explained and agreed upon in advance before any services are
rendered and detailed in the Agreement.
Plan advisory services begin with the effective date of the Plan Consulting Agreement, which is the date the
client signs the Plan Consulting Agreement. For that calendar quarter, fees will be adjusted pro rata based
upon the number of calendar days in the calendar quarter that the Agreement was effective. Our fee is
billed in arrears or in advance on the last business day of the calendar month, as indicated in the Plan
Consulting Agreement. For Plans where our fee is billed to the custodian, the fee is deducted directly from
the participant accounts. Written authorization permitting us to be paid directly from the custodial account
is outlined in the Plan Consulting Agreement.
Either party may terminate the Plan Consulting Agreement at any time upon immediate notice. The client
is responsible to pay for services rendered until the termination of the agreement.
ADMINISTRATIVE SERVICES PROVIDED BY ADVYZON
Our Firm has contracted with Advyzon Technologies to utilize its technology platforms to support data
reconciliation, performance reporting, fee calculation, client relationship maintenance, quarterly
performance evaluations, and other functions related to managing Client accounts' administrative tasks.
Due to this arrangement, Advyzon will have access to client accounts, but Advyzon will not serve as an
investment advisor to our clients or bill the accounts. Advyzon charges our firm an annual fee for each
account administered by its software. Please note that our firm’s annual fee to Advyzon will not increase
the Client's fee. Our firm will pay the annual fee from the portion of the management fee retained by Our
Firm. Our firm and Advyzon are non-affiliated companies.
ADDITIONAL FEES AND EXPENSES
In addition to the advisory fees paid to our Firm, clients may also incur certain charges imposed by other
third parties, such as broker-dealers, custodians, trust companies, banks, and other financial institutions
(collectively “Financial Institutions”). These additional charges will include securities transaction fees,
custodial fees, fees charged by the Independent Managers, charges imposed directly by a mutual fund
company or ETF in a client’s account, as disclosed in the fund’s prospectus (e.g., fund management fees and
other fund expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer, and
electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. AFL’s
brokerage practices are described at length in Item 12, below. Legacy assets that pay a trail will be received
by supervised persons of Saxony Securities, Inc. Further, our Firm does not share in any of these additional
fees and expenses outlined above.
AFL may include mutual funds and exchange-traded funds (“ETFs”) in our investment strategies. AFL’s policy
is to purchase institutional share classes of those mutual funds selected for the client’s portfolio. The
institutional share class generally has among the lowest expense ratio. The expense ratio is the annual fee
that all mutual funds or ETFs charge their shareholders. It expresses the percentage of assets deducted each
fiscal year for funds expenses, including 12b-1 fees, management fees, administrative fees, operating costs,
and all other asset-based costs incurred by the fund. Some fund families offer different classes of the same
fund, and one share class may have a lower expense ratio than another share class. These expenses come
from client assets which could impact the client’s account performance. Mutual fund expense ratios are in
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MARCH 2026 | PAGE 10 OF 24
addition to the AFL fee, and we do not receive any portion of these charges. If an institutional share class is
not available for the mutual fund selected, the adviser will purchase the least expensive share class available
for the mutual fund. As share classes with lower expense ratios become available, AFL may use them in the
client’s portfolio, and/or convert the existing mutual fund position to the lower-cost share class. Clients
who transfer mutual funds into their accounts with AFL would bear the expense of any contingent or
deferred sales loads incurred upon selling the product. If a mutual fund has a frequent trading policy, the
policy can limit a client’s transactions in shares of the fund (e.g., for rebalancing, liquidations, deposits or
tax harvesting). All mutual fund expenses and fees are disclosed in the respective mutual fund prospectus.
The mutual fund and exchange-traded fund companies that choose to participate in your custodian’s NTF
fund program pay a fee to be included in the NTF program. The fees paid by these companies to participate
in the program are ultimately borne by the owners of the mutual fund or exchange-traded fund including
clients of our Firm. When we decide whether to choose a fund from your custodian’s NTF list or not, we
consider our expected holding period of the fund, the position size and the expense ratio of the fund versus
alternative funds. Depending on our analysis and future events, NTF funds might not always be in your best
interest.
ITEM 6 – PERFORMANCE BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not charge advisory fees on a share of the capital appreciation of the funds or securities in a client
account (so-called performance-based fees), nor engage side by side management.
ITEM 7 - TYPES OF CLIENTS
We provide investment advice to individuals, high net worth individuals, corporations and other businesses,
pension and profit-sharing plans, charitable organizations, estates, and trusts.
AFL does not require a minimum dollar value of any account to which it provides advisory and financial
planning services.
ITEM 8 - METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS
METHODS OF ANALYSIS AND INVESTMENT STRATEGIES
Once the client’s profile, financial situation, investment objectives, time horizon, and risk tolerance have
been determined, we will utilize cyclical and Fundamental Analysis. In formulating our investment advice,
the Firm uses financial media and websites, inspections of corporate activities on-line, research prepared
by others, corporate rating services, annual reports, prospectuses, filings with the SEC, and company press
releases. Research is used which is produced by yCharts and Standard and Poor’s. Interviews with mutual
fund companies’ management also serve for gathering insight and the Firm subscribes to economic
research.
CYCLICAL
A cyclical analysis focuses on industry sensitivity to the business cycle and attempts to benefit investment
decisions through understanding where the business cyclical is and where it may be heading.
Certain kinds of stock show marked tendencies to mirror these larger economic movements, either directly
or inversely. Automobile industry stocks, housing stocks, and many others belong to these groups. Others,
such as food-related stocks, have less or no relation to these cyclical economic movements. It is important
for the analyst using cyclical predictors to have a good understanding of how certain industries relate to the
ALEXANDER LABRUNERIE& CO., INC.
MARCH 2026 | PAGE 11 OF 24
overall economy and any verifiable changes occurring within the system, to ascertain which business
sectors will be affected and how greatly by economic changes.
The analysis is applied to limited kinds of stocks, ETF or stock Indices which either could limit a portfolio or
require other forms of investing whose analyses would then need to be related to and integrated with the
concepts and investment goals inherent in a cyclical view. Steep and severe losses occur to investors in
stocks from time to time.
Understanding business cycles is a complicated endeavor at the least. The time involved in these cycles is
generally longer historical periods whose effectiveness can be eclipsed by other forms of market action and
volatility.
Changes in the economy vary in the magnitude of their cyclical effects from period to period. Deciding
when to enter into a predicted cycle and when to leave can require very careful monitoring; demand for
certain cyclical industry items are not always predictable if a significant portion of consumption is from
certain foreign purchasers, the Chinese Peoples Republic, for example. Time spent using one analytical
method will compete with other analytical methods which might have proven more useful and profitable.
Political, legal and trade and timing of investment persist as risk to the client’s portfolio as well and must
be accepted by the client. When investing in mutual funds it is possible that managed accounts
underperform their benchmarks, resulting in lower returns or loss. AFL does not conduct specific analysis it
relies on research from third-party research firms and uses that data to inform our investment decisions.
FUNDAMENTAL ANALYSIS
Called the “bottom-up” approach to investing, a fundamental analysis seeks an in-depth understanding of
a specific firm/ company to evaluate its intrinsic value and its future prospects before investing in its stock.
Such an analysis studies the firm’s management, its debt, equity and cash flow, history of financial
performance/ growth, dividend payout percentages, its products, operating efficiency and marketing
structures, among other factors. The firm’s balance sheet and income statement are two key sources of
information about the firm.
Fundamental Analysis will compare a firm’s stock price with its earnings per share and its net earnings to
its gross revenues and compare both with the averages for that industry sector. The ratio of current
liabilities to current assets is another important element of this form of evaluation. A central focus is
deciding whether the stock is over-valued or undervalued. Revenue growth and the position in the industry
is reviewed.
As a term in large-scale economics, a fundamental analysis studies gross national product, inflation and
interest rates, trade and unemployment trends, consumer confidence, savings and spending patterns and
inventories in order to predict the larger movements of national and international economies. These larger
concerns greatly influence the elements considered in a fundamental analysis of any given company.
The factors involved can require time-consuming study that can fall behind the need to make decisions, if
such factors begin to change rapidly. Few of the numbers are absolutes; many are relative to other factors
or industry sector information. Most require informed judgment and experience to be applied meaningfully
to stock values. Steep and severe losses will occur from time to time to investors in stocks.
Fundamental analysis places value on the financial structure and health of the firm to be invested in. These
factors at times are of little or no interest to the marketplace, such that the stock prices for very sound
companies sometimes wither when investors look to other reasons and areas for investing.
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A firm can falsify facts to hide poor performance or a fragile financial situation. The independence of
balance sheets’ and other reports’ numerical information from such possible manipulation are not always
readily verifiable and result in negative news causing individual companies and the broad market to drop
in price. This can lead to permanent and severe loss to investors.
Time spent using one analytical method will compete with other analytical methods which might have
proven more useful and profitable in hindsight.
INVESTMENTS
Typical investments for clients may include cash and cash equivalents, equity securities such as equities,
mutual funds, exchange-traded funds, debt instruments such as US Government, municipal, and corporate
bonds may be selected by the representative. These investments will rely on one or several types of
analysis, as described in the next section. All investments involve some form of risk and no guarantees are
warranted or implied.
The Firm employs primarily long-term investment strategies, buying securities to be held for a year or longer
in most cases. All strategies are intended to enhance the portfolio’s value and ability to meet a client’s
stated goals. What is regarded as “frequent trading” varies according to both client and to the type of
security involved. All trading will normally add costs that a client’s account must pay, possibly reducing
overall performance for the account. In select accounts, the Firm’s strategy can include more frequent
trades, if a client directs the Firm that he or she wants to pursue a more aggressive growth, in which
securities are occasionally held for only a few days. Certain low operating cost funds such as Vanguard group
have higher one-time transaction fees on custodial platforms such as Charles Schwab and Pershing LLC than
other mutual funds.
From time-to-time other rebalancing or selling on market strength is recommended on an individual
account basis based on market conditions and investment performance monitoring, Trading costs and
taxation are taken into consideration when making the recommendation.
RISK OF LOSS
Clients must understand that past performance is not indicative of future results. Therefore, current and
prospective clients should never assume that future performance of any specific investment or investment
strategy will be profitable. Investing in securities involves risk of loss. Further, depending on the different
types of investments, there will be varying degrees of risk. Clients and prospective clients should be
prepared to bear investment loss, including loss of original principal.
Because of the inherent risk of loss associated with investing, our Firm is unable to represent, guarantee,
or even imply that our services and methods of analysis can or will predict future results, successfully
identify market tops or bottoms, or insulate you from losses due to market corrections or general declines.
Investors should be aware that accounts are subject to the following risks:
§ MARKET RISK - Even a long-term investment approach cannot guarantee a profit. Economic,
political, and issuer-specific events will cause the value of securities to rise or fall. Because the
value of investment portfolios will fluctuate, there is the risk that you will lose money, and your
investment may be worth more or less than your original investment upon liquidation.
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§
FOREIGN SECURITIES AND CURRENCY RISK - Investments in international and emerging-
market securities include exposure to risks such as currency fluctuations, foreign taxes and
regulations, and the potential for illiquid markets and political instability.
§ CAPITALIZATION RISK - Small-cap and mid-cap companies may be hindered as a result of limited
resources or less diverse products or services. Their stocks have historically been more volatile
than the stocks of larger, more established companies.
§
INTEREST RATE RISK - In a rising rate environment, the value of fixed-income securities generally
declines, and the value of equity securities may be adversely affected.
§ CREDIT RISK - Credit risk is the risk that the issuer of a security may be unable to make interest
payments and/or repay principal when due. A downgrade to an issuer’s credit rating or a perceived
change in an issuer’s financial strength may affect a security’s value and thus, impact the fund’s
performance.
§
EXCHANGE-TRADED FUNDS - ETFs face market-trading risks, including the potential lack of an
active market for shares, losses from trading in the secondary markets, and disruption in the
creation/redemption process of the ETF. Any of these factors may lead to the fund’s shares trading
at either a premium or a discount to its “net asset value.”
O
Investments in closed-end funds involve additional risks, including the potential for shares
to trade at a premium or discount to net asset value (NAV), the use of leverage that may
increase volatility and losses, and reduced liquidity compared to other investment
vehicles.
§ PERFORMANCE OF UNDERLYING MANAGERS - We select the mutual funds and ETFs in the
asset allocation portfolios. However, we depend on the manager of such funds to select individual
investments in accordance with their stated investment strategy.
§ ALTERNATIVE INVESTMENT RISK - Alternative investments include other additional risks. Lock-
up periods and other terms obligate Clients to commit their capital investment for a minimum
period, typically no less than one or two years and sometimes up to 10 or more years. Illiquidity is
considered a substantial risk and will restrict the ability of a Client to liquidate an investment early,
regardless of the success of the investment. Alternative investments are difficult to value within a
Client’s total portfolio. There may be limited availability of suitable benchmarks for performance
comparison; historical performance data may also be limited.
In some cases, there may be a lack of transparency and regulation, providing an additional layer of
risk. Some alternative investments may involve the use of leverage and other speculative
techniques. As a result, some alternative investments may carry substantial additional risks,
resulting in the loss of some or all of the investment. Using leverage and certain other strategies
will result in adverse tax consequences for tax-exempt investors, such as the possibility of
unrelated business taxable income, as defined under the U.S. Internal Revenue Code.
§ CYBERSECURITY RISK - In addition to the Material Risks listed above, investing involves various
operational and “cybersecurity” risks. These risks include both intentional and unintentional
events at AFL or one of its third-party counterparties or service providers, that may result in a loss
or corruption of data, result in the unauthorized release or other misuse of confidential
information, and generally compromise our Firm’s ability to conduct its business. A cybersecurity
ALEXANDER LABRUNERIE& CO., INC.
MARCH 2026 | PAGE 14 OF 24
breach may also result in a third-party obtaining unauthorized access to our clients’ information,
including social security numbers, home addresses, account numbers, account balances, and
account holdings. Our Firm has established business continuity plans and risk management
systems designed to reduce the risks associated with cybersecurity breaches. However, there are
inherent limitations in these plans and systems, including that certain risks may not have been
identified, in large part because different or unknown threats may emerge in the future. As such,
there is no guarantee that such efforts will succeed, especially because our Firm does not directly
control the cybersecurity systems of our third-party service providers. There is also a risk that
cybersecurity breaches may not be detected.
ITEM 9 - DISCIPLINARY INFORMATION
We do not have any legal, financial or other “disciplinary” item to report.
ITEM 10 - OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Clients should review our IARs Form ADV Part 2B Brochure Supplement to determine whether the Client’s
IAR is engaged in any of the activities described below that may create a conflict of interest. If the Client did
not receive the Advisor’s Form ADV Part 2B Brochure Supplement, the Client should contact the Firm’s Chief
Compliance Officer using the information on the cover page of this Brochure. The Chief Compliance Officer
is available to address any questions a Client or prospective client may have regarding any of the below
conflicts of interest, or any other information outlined in this Brochure.
LIFE AND LONG-TERM CARE INSURANCE
Some of our IARs are licensed insurance agents and sell various life insurance products, long term care and
fixed annuities through the licensed insurance agency. Our IARs receive compensation (commissions, trails,
or other compensation from the respective insurers) as a result of effecting insurance transactions for
clients. IARs spend a portion of their time in connection with these insurance activities and it represents
ongoing revenue for our IARs. The IAR has an incentive to recommend insurance and this incentive creates
a conflict of interest between your interests and our Firm. Clients should note that they have the right to
decide whether or not to engage the services of our IARs. Further, clients should note they have the right
to decide whether to act on the recommendations and the right to choose any professional to execute the
advice for any insurance products through our IAR or any licensed insurance agent not affiliated with our
Firm. We recognize the fiduciary responsibility to place your interests first and have established policies in
this regard to mitigate any conflicts of interest.
BROKER-DEALER AFFILIATED
Our Firm is not a broker-dealer, but some of the IARs are Registered Representatives of Saxony Securities.
(“Saxony”), a full-service broker-dealer, member FINRA/SIPC, which compensates them for effecting
securities transactions. When placing securities transactions through Saxony in their capacity as Registered
Representatives, they will earn sales commissions. Because some of the IARs are dually registered
representatives and agents of Saxony and our Firm, Saxony, has specific supervisory and administrative
duties under the requirements of FINRA Conduct Rule 3280. Saxony and our Firm are not affiliated
companies. Some of our IARs spend a portion of their time in connection with broker-dealer activities.
As a broker-dealer, Saxony engage in various activities normally associated with securities brokerage firms.
Pursuant to the investment advice given by our Firm or its IARs, investments in securities may be
ALEXANDER LABRUNERIE& CO., INC.
MARCH 2026 | PAGE 15 OF 24
recommended for Clients. If Saxony is selected as the broker-dealer, Saxony and its Registered
Representatives, including some of the IARs of our Firm, may individually receive commissions for executing
securities transactions.
If Saxony is selected as the broker-dealer, the transaction charges may be higher or lower than the charges
you may pay if the transactions were executed at other broker-dealers. You should note, however, that you
are under no obligation to purchase securities through the IARs of our Firm or Saxony.
Moreover, you should note that under the rules and regulations of FINRA, Saxony must maintain certain
Client records and perform other functions regarding certain aspects of the investment advisory activities
of its Registered Representatives. These obligations require Saxony to coordinate with and have the
cooperation of its Registered Representatives that operate as or are otherwise associated with investment
advisors other than Saxony. Accordingly, Saxony may limit the use of certain custodial and brokerage
arrangements available to Clients of our Firm, and Saxony may collect, as paying agent of our Firm, the
investment advisory fee remitted to our Firm by the account Custodian. Saxony may retain a portion of the
investment advisory fee you pay as a charge for the functions it performs and may be further re-allowed to
other Registered Representatives of Saxony. The charge will not increase the advisory fee you have agreed
to pay our Firm.
Some of the IARs, in their capacity as Registered Representatives of Saxony or as agents appointed with
various life, disability, or other insurance companies, receive insurance commissions, fee trails, or other
compensation from the respective insurers or because of effecting securities transactions for Clients.
However, Clients should note that they are not obligated to purchase investment products through our
IARs.
As a result of the relationship with Saxony, they may have access to certain confidential information (e.g.,
financial information, investment objectives, transactions, and holdings) about our Clients, even if the Client
does not establish any account through Saxony. If you would like a copy of the Saxony Privacy Policy, please
contact our Firm’s CCO. The contact information for our Firm can be found on the Cover Page of this
Brochure.
ITEM 11 - CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS
AND PERSONAL TRADING
Our Firm and persons associated with us are allowed to invest for their own accounts or to have a financial
investment in the same securities or other investments that we recommend or acquire for your account
and may engage in transactions that are the same as or different than transactions recommended to or
made for your account. This creates a conflict of interest. We recognize the fiduciary responsibility to act in
your best interest and have established policies to mitigate conflicts of interest.
We have developed and implemented a Code of Ethics that sets forth standards of conduct expected of our
advisory personnel to mitigate this conflict of interest. The Code of Ethics addresses, among other things,
personal trading, gifts, and the prohibition against the use of inside information.
The Code of Ethics is designed to protect our clients to detect and deter misconduct, educate personnel
regarding the Firm’s expectations and laws governing their conduct, remind personnel that they are in a
position of trust and must act with complete propriety at all times, protect the reputation of AFL, safeguard
against the violation of the securities laws, and establish procedures for personnel to follow so that we may
determine whether their personnel are complying with the Firm’s ethical principles.
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We have established the following restrictions in order to ensure our Firm’s fiduciary responsibilities:
§ A director, officer, or employee of AFL shall not buy or sell any securities for their personal
portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her
employment unless the information is also available to the investing public on reasonable inquiry
No supervised employee of AFL shall prefer his or her own interest to that of the advisory client.
Trades for supervised employees are traded alongside client accounts
§ We maintain a list of all securities holdings of anyone associated with this advisory practice with
access to advisory recommendations. These holdings are reviewed on a regular basis by an
appropriate officer/individual of AFL.
§ We emphasize the unrestricted right of the client to decline implementation of any advice
rendered, except in situations where we are granted discretionary authority of the client’s account
§ We require that all supervised employees must act in accordance with all applicable Federal and
State regulations governing registered investment advisory practices
§ Any supervised employee not in observance of the above may be subject to termination
INVESTMENT POLICY
None of our associated persons may affect for himself/herself or for accounts in which he/she holds a
beneficial interest, any transactions in a security which is being actively recommended to any of our clients,
unless in accordance with the Firm’s procedures.
You may request a complete copy of our Code by contacting us at the address, telephone, or email on the
cover page of this Part 2; ATTN: Bret Rodabaugh, Chief Compliance Officer.
ITEM 12 - BROKERAGE PRACTICES
We generally recommend that our Clients utilize Charles Schwab & Co., Inc. Advisor Services ("Schwab"), a
registered broker-dealer, Member SIPC, as the qualified Custodian. Our Firm is independently owned and
operated and unaffiliated with Schwab. Schwab will hold Client assets in a brokerage account and buy and
sell securities when our Firm instructs them.
While our Firm recommends that Clients use Schwab as a Custodian, Clients must decide whether to do so
and open accounts with Schwab by entering into account agreements directly with them. The Client opens
the accounts with Schwab. The accounts will always be held in the Client's name and never in our Firm’s.
HOW OUR FIRM SELECTS CUSTODIAN-BROKER
Our Firm seeks to recommend a Custodian-Broker who will hold Client assets and execute the transactions
on terms that are, overall, most advantageous compared to other available providers and their services.
Our Firm considers a wide range of factors, including, among others:
• Combination of transaction execution and asset custody services (generally without a separate fee
for custody).
• Capability to execute, clear, and settle trades (buy and sell securities for Client accounts).
• Capability to facilitate transfers and payments to and from accounts (wire transfers, check re-
•
quests, bill payments, etc.).
The breadth of available investment products (stocks, bonds, mutual funds, exchange-traded
funds [ETFs], etc.).
• Availability of investment research and tools that assist us in making investment decisions.
• Quality of services.
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• Competitiveness of the price of those services (commission rates, other fees, etc.) and willingness
to negotiate the prices.
Prior service to our Firm and our other Clients.
• Reputation, financial strength, and stability.
•
• Availability of other products and services that benefit our Firm, as discussed below (see “Products
And Services Available To Us From Schwab”).
CLIENT BROKERAGE & CUSTODY COSTS
For Clients' accounts, Schwab maintains and generally does not charge separately for custody services.
However, Schwab receives compensation by charging ticket charges or other fees on trades it executes or
settling into Clients' Schwab accounts. In addition to commissions, Schwab charges a flat dollar amount as
a "prime broker" or "trade away" fee for each trade that our Firm has executed by a different broker-dealer
but where the securities bought or the funds from the securities sold are deposited (settled) into a Client’s
Schwab account. These fees are in addition to the ticket charges or compensation the Client pays the
executing broker-dealer. Because of this, our Firm has Schwab execute most trades for Client accounts to
minimize trading costs. Our Firm has determined that having Schwab execute most trades is consistent with
our duty to seek the "best execution" of Client trades. Best execution means the most favorable terms for
a transaction based on all relevant factors, including those listed above (see How Our Firm Selects
Custodian-Broker).
PRODUCTS AND SERVICES AVAILABLE TO US FROM SCHWAB
Schwab Advisor Services™ (formerly called Schwab Institutional®) provides independent investment
advisory Firms and Clients with access to its institutional brokerage, trading, custody, reporting, and related
services, many of which are not typically available to Schwab retail customers. Schwab also makes available
various support services. Some of those services help us manage or administer our Clients’ accounts; others
help us manage and grow our business. Schwab’s support services generally are available on an unsolicited
basis and at no charge to our Firm. These are typically considered soft dollar benefits because there is an
incentive to do business with Schwab. Receiving soft dollar benefits creates a conflict of interest. We have
established policies in this regard to mitigate any conflicts of interest. We believe our selection of Schwab
as Custodian-Broker is in the Clients' best interests. Our Firm will always act in the best interest of our
Clients and act as fiduciary in carrying out services to Clients. The following is a more detailed description
of Schwab’s support services:
SERVICES THAT BENEFIT OUR CLIENTS
Schwab's institutional brokerage services include access to a broad range of investment products, execution
of securities transactions, and custody of Client assets. The investment products available through Schwab
include some we might not otherwise have access to or would require a significantly higher minimum initial
investment by our Clients. Schwab’s services described in this paragraph generally benefit our Clients and
their accounts.
SERVICES THAT MAY NOT DIRECTLY BENEFIT OUR CLIENTS
Schwab also makes other products and services available that benefit our Firm but may not directly benefit
our Clients or their accounts. These products and services assist our Firm in managing and administering
our Clients’ accounts. They include investment research, both Schwab’s own and that of third parties. Our
Firm may use this research to service all or a substantial number of our Client's accounts, including accounts
ALEXANDER LABRUNERIE& CO., INC.
MARCH 2026 | PAGE 18 OF 24
not maintained at Schwab. In addition to investment research, Schwab also makes available software and
other technology that:
•
Provides access to Client account data (such as duplicate trade confirmations and account state-
ments).
Facilitate trade execution and allocate aggregated trade orders for multiple Client accounts.
Provide pricing and other market data.
Facilitate payment of our fees from our Clients’ accounts.
•
•
•
• Assist with back-office functions, recordkeeping, and Client reporting.
SERVICES THAT GENERALLY BENEFIT ONLY US
Schwab also offers other services to help our Firm manage and further develop our business enterprise.
These services include:
Educational conferences and events
Publications and conferences on practice management and business succession
•
• Consulting on technology, compliance, legal, and business needs
•
• Access to employee benefits providers, human capital consultants, and insurance providers
Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to our Firm. Schwab may also discount or waive its fees for some of these services or
pay all or a part of a third party’s fees. Schwab may also provide our Firm with other benefits, such as
occasional business entertainment for our personnel.
OUR INTEREST IN SCHWAB’S SERVICES
•
•
The availability of these services from Schwab benefits our Firm because we do not have to pro-
duce or purchase them. These services are not contingent upon our Firm committing any specific
amount of business to Schwab in trading commissions. We believe our selection of Schwab as Cus-
todian and Broker is in our Client’s best interests.
Some of the products, services, and other benefits provided by Schwab benefit our Firm and may
not benefit our Client accounts. Our recommendation or requirement that you place assets in
Schwab's custody may be based, in part, on the benefits Schwab provides to our Firm or our Agree-
ment to maintain certain Assets Under Management at Schwab and not solely on the nature, cost,
or quality of custody and execution services provided by Schwab.
• Our Firm places trades for our Clients' accounts subject to its duty to seek the best execution and
other fiduciary duties. Schwab's execution quality may be different from other broker-dealers.
• Our Firm does not routinely recommend, request, or require that the Client direct us to execute
the transactions through a specified Custodian. Additionally, our Firm typically does not permit
the Client to direct brokerage. We place trades for Client accounts subject to our duty to seek the
best execution and other fiduciary duties.
• We will aggregate trades for ourselves or our associated persons with your trades, providing that
the following conditions are met:
o Our policy for the aggregation of transactions shall be fully disclosed separately to our
existing Clients (if any) and the broker/dealer(s) through which such transactions will be
placed.
o We will only aggregate transactions if we believe that aggregation is consistent with our
duty to seek the best execution (which includes the duty to seek the best price) for the
Client and is consistent with the terms of our investment advisory agreement.
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o Each Client that participates in an aggregated order will participate at the average share
price for all transactions in a given security on a given business day, with transaction costs
based on each Client's participation in the transaction.
o Our Firm will provide the allocation specifying the participating Client accounts and how
o
to allocate the order among those Clients.
If the aggregated order is filled in its entirety, it will be allocated among Clients per the
allocation statement; if the order is partially filled, the accounts that did not receive the
previous trade's positions should be "first in line" to receive the next allocation.
o Notwithstanding the preceding, the order may be allocated on a basis different from that
specified if all Client accounts receive fair and equitable treatment. The reason for the
difference in allocation will be documented and reviewed by our Firm’s Compliance Of-
ficer. Our Firm’s books and records will separately reflect, for each Client account, the
orders which are aggregated, and the securities held by and bought for that account.
o Our Firm will not receive additional compensation or remuneration of any kind because
of the proposed aggregation; and
Individual advice and treatment will be accorded to each advisory Client.
o
In the event you request us to recommend a broker/dealer custodian for execution and/or custodial ser-
vices, we generally recommend your account to be maintained at Schwab. We may recommend that you
establish accounts with Schwab to maintain custody of your assets and to effect trades for your accounts.
You are under no obligation to act upon any recommendations, and if you elect to act upon any recommen-
dations, you are under no obligation to place the transactions through any broker/dealer we recommend.
Our recommendation is generally based on the broker’s cost and fees, skills, reputation, dependability and
compatibility with the client. You may be able to obtain lower commissions and fees from other brokers
and the value of products, research and services given to us is not a factor in determining the selection of
broker/dealer or the reasonableness of their commissions.
BROKERAGE FOR CLIENT REFERRALS
Our Firm does not receive Client referrals from any Custodian or third party in exchange for using that
broker-dealer or third party.
AGGREGATION & ALLOCATION OF TRANSACTIONS
Our Firm may aggregate transactions if it believes that aggregation is consistent with the duty to seek the
best execution for its Clients and is consistent with the disclosures made to Clients and terms defined in the
Investment Advisory Agreement. Each account in an aggregated order will participate at the average share
price (per Custodian) for all transactions in that security on a given business day.
If we do not receive a complete fill for an aggregated order, we will allocate the order on a pro-rata basis.
If we determine that a pro-rata allocation is not appropriate under the particular circumstances, we will
base the allocation on other relevant factors, which may include:
• When only a small percentage of the order is executed, with respect to purchase allocations, allo-
cations may be given to accounts high in cash.
• Concerning sale allocations, allocations may be given to accounts low in cash.
• We may allocate shares to the account with the smallest order, to the smallest position, or to an
account that is out of line concerning security or sector weightings relative to other portfolios with
similar mandates.
ALEXANDER LABRUNERIE& CO., INC.
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•
•
• We may allocate one account when that account has limitations in its investment guidelines pro-
hibiting it from purchasing other securities that we expect to produce similar investment results,
and other accounts can purchase that in the block.
If an account reaches an investment guideline limit and cannot participate in an allocation, we may
reallocate shares to other accounts. For example, this may be due to unforeseen changes in an
account's assets after placing an order.
If a pro-rata allocation of a potential execution would result in a de minimis allocation in one or
more account(s), we may exclude the account(s) from the allocation.
• Our Firm will document the reasons for any deviation from a pro-rata allocation.
TRADE ERRORS
Our Firm has implemented procedures designed to prevent trade errors; however, our Firm cannot always
avoid Client trade errors.
Consistent with our Firm's fiduciary duty, it is our Firm’s policy to correct trade errors in a manner that is in
the Client's best interest. In cases where the Client causes the trade error, the Client will be responsible for
any loss resulting from the correction. Depending on the specific circumstances of the trade error, the Client
may not be able to receive any gains generated due to the error correction. In all situations where the Client
does not cause the trade error, the Client will be made whole, and we would absorb any loss resulting from
the trade error if our Firm caused the error. If the Custodian causes the error, the Custodian will cover all
trade error costs. If an investment error results in a gain when correcting the trade, the gain will be donated
to charity. Our Firm will never benefit or profit from trade errors.
DIRECTED BROKERAGE
Our Firm does not routinely recommend, request, or require that the Client direct us to execute the
transaction through a specified broker-dealer. Additionally, our Firm typically does not permit the Client to
direct brokerage. Our Firm places trades for Client accounts subject to its duty to seek the best execution
and other fiduciary duties.
ITEM 13 - REVIEW OF ACCOUNTS
ACCOUNT REVIEWS AND REVIEWERS – INVESTMENT SUPERVISORY SERVICES
Our Investment Adviser Representatives will monitor client accounts on a regular basis and perform
periodic reviews with each client. All accounts are reviewed for consistency with client investment strategy,
asset allocation, risk tolerance, and performance relative to the appropriate benchmark. The review could
include a written report. More frequent reviews may be triggered by changes in an account holder’s
personal, tax, or financial status. Geopolitical and macroeconomic specific events may also trigger reviews.
STATEMENTS AND REPORTS
The custodian for the individual client’s account will provide clients with an account statement at least
quarterly.
Reports may also be provided at every client meeting. Communication with clients will be done on an as-
needed basis.
Financial Portrait only clients (i.e. those who have no assets under management with us in our advisory
program) will not receive regular reports from the Firm.
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ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION
CLIENT REFERRALS
Our Firm pays referral fees to independent promotors for the referral of their clients to our Firm in
accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940. This arrangement will not result in
higher costs to you. In this regard, we maintain Promotors Agreements in compliance with Rule 206 (4)-1
of the Investment Advisers Act of 1940 and applicable state and federal laws. All clients referred by
Promotors to our Firm will be given full written disclosure describing the terms and fee arrangements
between our Firm and Promotor(s). The promotor will not provide clients with any investment advice on
behalf of AFL.
PROMOTERS
We may enter into agreements with individuals who will promote our Firm (“Promoters”). If a Client is
introduced to our Firm by a Promoter, we will pay that Promoter a referral fee per the requirements of Rule
206(4)-1 of the Investment Advisers Act of 1940 and any corresponding state securities law requirements.
Any referral fee will be paid solely from advisory fees and will not incur additional charges to the Client. The
Promoter, at the time of the referral, will disclose the nature of the Promoter relationship and provide each
prospective client with a copy of the written disclosure statement from the Promoter to the Client disclosing
the terms of the arrangement between our Firm and the Promoter, including the compensation to be re-
ceived by the Promoter from our Firm.
OTHER PROFESSIONALS
Our Firm may refer business to estate planning attorneys, accountants, insurance brokers, and other
professionals. However, we do not receive monetary or other material compensation for referring Clients
to such professionals. We also do not pay any person or firm commissions or other items of material value
for referring Clients to us, unless as disclosed in this Item 14. If we receive or offer an introduction to a
Client, we do not pay or earn a referral fee, nor are there established quid pro quo arrangements. Each
Client can accept or deny such referral or subsequent services.
ITEM 15 – CUSTODY
We do not have physical custody, as it applies to investment advisors. Custody has been defined by
regulators as having access or control over client funds and/or securities.
DEDUCTION OF ADVISORY FEES
For all accounts, our Firm has the authority to have fees deducted directly from client accounts. Our Firm
has established procedures to ensure all client funds and securities are held at a qualified custodian in a
separate account for each client under that client’s name. Clients, or an independent representative of the
client, will direct, in writing, the establishment of all accounts and therefore are aware of the qualified
custodian’s name, address, and the manner in which the funds or securities are maintained. Finally, account
statements are delivered directly from the qualified custodian to each client, or the client’s independent
representative, at least quarterly. The client should carefully review those statements and are urged to
compare the statements against reports received from AFL. When the client has questions about their
account statements or fee deductions, the client should contact AFL or the qualified custodian preparing
the statement.
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Please refer to Item 5 for more information about the deduction of advisor fees.
STANDING LETTERS OF AUTHORIZATION (“SLOA”)
Our Firm is deemed to have custody of clients’ funds or securities when clients have standing authorizations
with their custodian to move money from a client’s account to a third party (“SLOA”) and, under that SLOA,
it authorizes us to designate the amount or timing of transfers with the custodian. The SEC has set forth a
set of standards intended to protect client assets in such situations, which we follow. We do not have a
beneficial interest in any of the accounts we are deemed to have custody where SLOAs are on file. In
addition, account statements reflecting all activity on the account(s), are delivered directly from the
qualified custodian to each client or the client’s independent representative, at least quarterly. The client
should carefully review those statements and are urged to compare the statements against reports received
from us. When the client has questions about their account statements, the client should contact us, the
client’s Advisor or the qualified custodian preparing the statement.
ITEM 16 – INVESTMENT DISCRETION
For discretionary accounts, prior to engaging AFL to provide investment advisory services, you will enter
into a written Agreement with us granting the Firm the authority to supervise and direct, on an on-going
basis, investments in accordance with the client’s investment objective and guidelines. In addition, you will
need to execute additional documents required by the custodian to authorize and enable AFL, in its sole
discretion, without prior consultation with or ratification by you, to purchase, sell, or exchange securities in
and for your accounts. We are authorized, in our discretion and without prior consultation with you to: (1)
buy, sell, exchange, and trade any investment company registered under the Investment Company Act of
1940, (2) determine the amount of securities to be bought or sold, and (3) place orders with the custodian.
Any limitations to such discretionary authority will be communicated to our Firm in writing by you, the
client.
The limitations on investment and brokerage discretion held by AFL for you are:
§
For discretionary accounts, we require that we be provided with authority to determine which
securities and the amounts of securities to be bought or sold.
§ Any limitations on this discretionary authority shall in writing as indicated on the Investment
Advisory Agreement, Appendix B. You may change/amend these limitations as required.
In some instances, we may not have discretion. We will discuss all transactions with you prior to execution
or you will be required to make the trades if in an employer-sponsored account.
ITEM 17 – VOTING YOUR SECURITIES
We will not vote proxies on your behalf. You are welcome to vote proxies or designate an independent
third-party at your own discretion. You designate proxy voting authority in the custodial account
documents. You must ensure that proxy materials are sent directly to you or your assigned third party. We
do not take action with respect to any securities or other investments that become the subject of any legal
proceedings, including bankruptcies. Clients can contact our office with questions about a particular
solicitation by phone at (573) 449-5313.
Class action lawsuits are a procedural device used in litigation to determine the rights of and remedies, if
any, for large numbers of people whose cases involve common questions of law and/or fact. Class action
lawsuits frequently arise against companies that publicly issue securities, including securities recommended
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MARCH 2026 | PAGE 23 OF 24
by investment advisors to clients. With respect to class action suits and claims, you (or your agent) will have
the responsibility for class actions or bankruptcies, involving securities purchased for or held in your
account. We do not provide such services and are not obligated to forward copies of class action notices
we may receive to you or your agents.
ITEM 18 – FINANCIAL INFORMATION
We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in
advance. Therefore, we are not required to include a balance sheet for our most recent fiscal year. We are
not subject to a financial condition that is reasonably likely to impair our ability to meet contractual
commitments to clients. Finally, we have not been the subject of a bankruptcy petition at any time.
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