Overview
- Headquarters
- Los Angeles, CA
- Total Firm Assets
- $224 million
- Average High-Net-Worth Client Portfolio Size
- $1.8 million
- Minimum Account Size
- $500,000
Fee Structure
Primary Fee Schedule (AWAIM FORM ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $500,000 | 1.50% |
| $500,001 | $2,000,000 | 1.25% |
| $2,000,001 | $5,000,000 | 1.00% |
| $5,000,001 | and above | 0.85% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $13,750 | 1.38% |
| $5 million | $56,250 | 1.12% |
| $10 million | $98,750 | 0.99% |
| $50 million | $438,750 | 0.88% |
| $100 million | $863,750 | 0.86% |
Clients
- High-Net-Worth Share of Firm Assets
- 83.17%
- Number of High-Net-Worth Clients
- 105
- Total Client Accounts
- 342
- Discretionary Accounts
- 342
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting
Regulatory Filings
- SEC CRD Number
- 321735
Additional Brochure: AWAIM FORM ADV PART 2A (2026-06-08)
View Document Text
Item 1: Cover Page
Aligne Wealth
Advisors Investment
Management
(AWAIM®)
Form ADV Part 2A Brochure
Address:
1801 Century Park East
Suite 1440
Los Angeles, CA 90067
Phone:
(310) 795-0622
Email:
ivan@alignewealthllc.com
Website:
https://www.alignewealth.com/
This brochure provides information about the qualifications and business practices of Aligne Wealth
Preservation & Insurance Services, LLC, doing business as Aligne Wealth Advisors Investment
Management (“AWAIM”). If you have any questions about the contents of this brochure, please contact us
at the telephone number or email address listed above. 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. AWAIM is a registered investment adviser, but registration does not imply a certain level of skill
or training.
Additional information about AWAIM is also available on the SEC’s website at www.adviserinfo.sec.gov
and by searching for CRD# 321735.
Page 1 of 21
Date of Brochure: June 8, 2026
Item 2: Material Changes
The material changes in this brochure from the last annual updating amendment of AWAIM on
01/21/2026 are described below. Material changes relate to AWAIM’s policies, practices or conflicts of
interests.
•
Ivan Illan is the Chief Investment Officer of AWAIM (HK) LIMITED, an affiliate of AWAIM (Item
10).
• AWAIM has disclosed management of AWAIM Global Macro Opportunities Fund, LP, a private
fund (Items 4, 5, 6, 7, 10, 11, and 15).
Page 2 of 21
Date of Brochure: June 8, 2026
Item 3: Table of Contents
Item 1: Cover Page
1
Item 2: Material Changes
2
Item 3: Table of Contents
3
Item 4: Advisory Business
4
Item 5: Fees and Compensation
7
Item 6: Performance-Based Fees & Side-By-Side Management
9
Item 7: Types of Clients
9
Item 8: Methods of Analysis, Investment Strategies & Risk of Loss
10
Item 9: Disciplinary Information
12
Item 10: Other Financial Industry Activities & Affiliations
13
Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading
14
Item 12: Brokerage Practices
15
Item 13: Review of Accounts
16
Item 14: Client Referrals and Other Compensation
17
Item 15: Custody
18
Item 16: Investment Discretion
19
Item 17: Voting Client Securities
20
Item 18: Financial Information
21
Page 3 of 21
Date of Brochure: June 8, 2026
Item 4: Advisory Business
A. Aligne Wealth Preservation & Insurance Services, LLC, doing business as Aligne Wealth
Advisors Investment Management (“AWAIM”) (the “Adviser,” “we,” “us,” or “our”) is an investment
adviser first registered with the U.S. Securities and Exchange Commission (“SEC”) in 2022, and
principally owned by Ivan Illan.
B. Adviser primarily offers a suite of four (4) model portfolio solutions (each, a “Model Portfolio”) that
strategically allocate towards equities, fixed income, and cash, as determined by its proprietary
global, macroeconomic research and outlook.
More specifically, Adviser offers the following types of advisory services:
i.
Discretionary Investment Management. Adviser provides ongoing discretionary
investment management services to its clients based upon each client’s current financial
condition, goals, risk tolerance, income, liquidity requirements, investment time horizon,
and other information that is relevant to the management of clients’ account(s). This
information will then be used to make investment and Model Portfolio allocation decisions
that reflect clients’ individual needs and objectives on an initial and ongoing basis.
Adviser’s investment decisions, through its Model Portfolios, will allocate portions of
clients’ account(s) to various asset classes classified according to historical and projected
risks and rates of return. Adviser will retain the discretion to buy, sell, or otherwise
transact in securities and other investments in a client’s accounts without first receiving
the client’s specific approval for each transaction. Such discretionary authority is granted
by a client in his or her investment management agreement with Adviser. Clients may
impose restrictions on investing in certain securities or types of securities so long as such
restrictions may reasonably be implemented by Adviser.
Adviser generally implements its investments strategy by allocating clients’ investable
assets across a diversified risk-based portfolio of mutual funds and/or exchange traded
funds (“ETFs”), but its Model Portfolios may include additional types of investments as
well. The Model Portfolios are rebalanced periodically to remain in-line with the client’s
agreed-upon asset allocation, though the asset allocation may be changed from time to
time based on changes to a client’s specific situation.
ii.
Financial Planning. When rendering financial planning services (which are provided in
connection with investment management services), Adviser will evaluate and make
recommendations with respect to various financial planning topics that are relevant to a
particular client. Such topics can include, for example, retirement planning, education
savings, cash flow management, debt reduction, estate planning, insurance needs, risk
mitigation, tax planning, charitable giving strategies, and/or financial goal tracking.
Implementation of Adviser’s recommendations will be at the discretion of the client.
When rendering financial planning services, a conflict exists between Adviser’s interests
and the interests of its clients; clients are under no obligation to act upon Adviser’s
financial planning recommendations. If a client elects to act on any of the
recommendations made by Adviser, the client is under no obligation to affect the
transaction through Adviser or any of its personnel.
iii.
Pension Consulting Services. To the extent Adviser is retained by a pension or profit-
sharing plan (a “Plan”), Adviser shall review the Plan’s investment objectives, risk
tolerance, and goals, and shall work in partnership with applicable third-parties (such as
the Plan’s recordkeeper, third-party administrator, and/or discretionary investment
manager) to establish an appropriate investment policy statement and deploy applicable
investment options into the Plan’s account. Adviser shall periodically review the
Page 4 of 21
Date of Brochure: June 8, 2026
investment options available to the Plan and, if applicable, will make recommendations to
assist the Plan with respect to the selection of the Plan’s qualified default investment
alternative (“QDIA”). Adviser will provide reports, information and recommendations, on a
reasonably requested basis, to assist the Plan in monitoring the selected investments. If
elected by the Plan, Adviser may also provide various services related to the Plan’s
governance, the education of Plan participants, and the review of other service providers
to the Plan.
iv.
Private Fund Management. AWAIM serves as investment manager to AWAIM Global
Macro Opportunities Fund, LP (the "Fund"), a private investment fund organized for the
purpose of investing primarily in publicly traded equity and fixed income securities.
The Fund's investment objective is to generate attractive long-term risk-adjusted returns
through a high-conviction, long-only tactical multi-asset investment strategy. AWAIM
utilizes a combination of top-down macroeconomic analysis and bottom-up fundamental
security research in managing the Fund's portfolio.
AWAIM’s investment process generally begins with an assessment of global
macroeconomic conditions, including factors such as interest rate trends, economic
developments, geopolitical events, and sector-specific opportunities. Based on this
analysis, AWAIM determines asset allocation targets, portfolio risk exposures, and
investment themes.
AWAIM then conducts quantitative and qualitative analysis of individual securities to
identify investments that align with its investment themes and portfolio objectives. The
Fund may invest through exchange-traded funds, mutual funds, individual equity
securities, fixed income securities, and other publicly traded instruments.
AWAIM has broad discretion in managing the Fund's assets, subject to the investment
objectives, policies, and restrictions set forth in the Fund's governing documents. AWAIM
may modify portfolio allocations, security selections, and investment techniques as
market conditions and investment opportunities evolve.
There can be no assurance that the Fund will achieve its investment objective or avoid
losses.
Adviser typically provides investment advice with respect to limited types of investments, which
include mutual funds and ETFs.
C. Adviser does not participate in any wrap fee programs.
D. In connection with Plans subject to the Employee Retirement Income Security Act of 1974
(“ERISA”) and applicable provisions of the Internal Revenue Code of 1986, as amended (the
“Code”) Adviser acknowledges that it is a fiduciary under ERISA and the Code, shall render
prudent investment advice that is in Plan’s best interest, shall avoid making misleading
statements, and shall receive no more than reasonable compensation. When we provide
investment advice to you regarding your retirement plan account or individual retirement account,
we are fiduciaries within the meaning of Title I of ERISA and/or the Code, as applicable, which
are laws governing retirement accounts. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best interest and
not put our interest ahead of yours. Under this special rule’s provisions, we must:
i. Meet a professional standard of care when making investment recommendations (give
ii.
prudent advice);
Never put our financial interests ahead of yours when making recommendations (give
loyal advice);
Page 5 of 21
Date of Brochure: June 8, 2026
iii.
iv.
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your
best interest;
Charge no more than is reasonable for our services; and
v.
vi. Give you basic information about conflicts of interest.
E. As of December 31, 2025, Adviser had the following assets under management:
Discretionary:
Non-Discretionary:
$224,392,095
$0
Page 6 of 21
Date of Brochure: June 8, 2026
Item 5: Fees and Compensation
A. Adviser is compensated for its advisory services primarily by fees charged based on a client’s
assets under management with Adviser. Fees are negotiable, and each client’s specific fee
schedule is included as part of the investment advisory agreement signed by Adviser and the
client.
Adviser’s standard tiered fee schedule is included below, subject to negotiation with a client:
Client Assets Under Management
Under $500,000
From $500,000 to $1,999,999
From $2,000,000 to $4,999,999
$5,000,000 and above
Annual Fee Percentage
(paid quarterly)
1.50%
1.25%
1.00%
0.85%
Legacy variable annuity assets that are not being charged an ongoing management fee will also
not be included in the table above when determining the applicable tier.
Private Fund Fees
Investors in the Fund do not pay advisory fees directly to AWAIM. Instead, the Fund pays AWAIM
a management fee and a performance-based fee as described in the Fund's governing
documents.
AWAIM receives an annual management fee equal to 1.50% of the Fund's net asset value.
AWAIM also receives a performance-based fee equal to 20% of the Fund's profits, subject to
certain conditions. Specifically:
• The Fund must earn more than a 6% annual return before a performance fee is charged;
and
• The Fund must recover any prior losses before additional performance fees can be
earned (high-water mark).
For example, if the Fund experiences a loss in one year, AWAIM generally will not earn a
performance fee on future gains until those losses have been recovered.
Performance-based fees create an incentive for AWAIM to make investments that may involve
greater risk because AWAIM’s compensation increases when the Fund performs well. AWAIM
seeks to manage this conflict through its compliance policies, investment oversight, and fiduciary
obligations.
Additional information regarding the calculation and payment of these fees is available in the
Fund's offering and governing documents.
B. Fees are deducted in advance on a quarterly basis from clients’ assets and based upon the
market value of such assets managed by Adviser as of the last day of the prior calendar quarter.
Prorated fees are applied or refunded based on mid-quarter client deposits and withdrawals.
Outstanding margin balances and cash are included in the assets upon which fees are assessed.
For the Fund, management fees and any applicable performance-based fees are paid by and
deducted directly from the Fund's assets in accordance with the Fund's governing documents.
Investors do not receive separate invoices for these fees.
Page 7 of 21
Date of Brochure: June 8, 2026
The Fund's independent administrator, NAV Consulting, is responsible for administering investor
capital activity and processing fee payments and other authorized cash movements on behalf of
the Fund in accordance with the Fund's governing documents and applicable administrative
procedures. Accordingly, investors generally do not make fee payments directly to AWAIM.
C. In addition to the fees charged by Adviser, clients will incur brokerage and other transaction
costs. Please refer to Item 12: Brokerage Practices, for further information on such brokerage and
other transaction-related practices. Clients will also typically incur additional fees and expenses
imposed by independent and unaffiliated third-parties, which can include qualified custodian fees,
mutual fund or exchange traded fund fees and expenses, mark-ups and mark-downs, spreads
paid to market makers, wire transfer fees, check-writing fees, early-redemption charges, certain
deferred sales charges on previously-purchased mutual funds, margin fees, charges or interest,
IRA and qualified retirement plan fees, and other fees and taxes on brokerage accounts and
securities transactions. These additional charges are separate and apart from the fees charged
by Adviser.
D. If Adviser or client terminates the advisory agreement before the end of a quarterly billing period,
Adviser’s fees will be prorated through the effective date of the termination. The pro rata fees for
the remainder of the quarterly billing period after the termination will be refunded to the client.
E. Neither Aligne Wealth Preservation & Insurance Services, LLC nor its supervised persons accept
any compensation for the sale of securities or other investment products, including asset-based
sales charges or service fees from the sale of mutual funds.
Page 8 of 21
Date of Brochure: June 8, 2026
Item 6: Performance-Based Fees & Side-By-Side
Management
AWAIM receives performance-based compensation from AWAIM Global Macro Opportunities Fund, LP in
the form of an incentive allocation equal to 20% of the Fund's net profits, subject to a 6% annual hurdle
rate and an annual high-water mark. AWAIM also manages separate accounts that do not pay
performance-based fees. Managing both kinds of accounts at the same time presents a conflict of interest
because AWAIM or its supervised persons have an incentive to favor accounts for which AWAIM and its
supervised persons receive a performance-based fee. AWAIM addresses the conflicts by ensuring that
clients are not systematically advantaged or disadvantaged due to the presence or absence of
performance-based fees. AWAIM seeks best execution and upholds its fiduciary duty for all clients.
Clients that are paying a performance-based fee should be aware that investment advisers have an
incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher
reward attributes.
Item 7: Types of Clients
Adviser generally provides its services to individuals, high-net-worth individuals, trusts, business entities,
charitable organizations, pension and profit-sharing plans, and pooled investment vehicles. The minimum
account value required to open and maintain an account with Adviser is $500,000, subject to negotiation.
Page 9 of 21
Date of Brochure: June 8, 2026
Item 8: Methods of Analysis, Investment Strategies & Risk
of Loss
A. Our investment approach is guided by proprietary global, macroeconomic forecasts that inform
our allocation decisions to equities, fixed income and cash through the business cycle. Our
research considers various factors when formulating our Model Portfolio allocation decisions,
which can include but are not limited to: geopolitical events, currency flows, global trade data,
consumer and business sentiments, fund flows data, interest rates, monetary policies,
immigration data, manufacturing and consumption data, and valuation methodologies. Investing
in securities involves risk of loss that clients should be prepared to bear. Past performance does
not guarantee future returns.
B. Like any investment strategy, our investment strategy and our Model Portfolios involve material
risks. Such material risks are described in further detail below:
i.
Investing for the long term means that a client’s account will be exposed to short-term
fluctuations in the market and the behavioral impulse to make trading decisions based on
such short-term market fluctuations. Adviser does not condone short-term trading in an
attempt to “time” the market, and instead coaches’ clients to remain committed to their
financial goals. However, investing for the long term can expose clients to risks borne out
of changes to interest rates, inflation, general economic conditions, market cycles,
geopolitical shifts, and regulatory changes.
ii.
Inflation risk is the risk that the value of a client’s portfolio will not appreciate at least in an
amount equal to inflation over time. General micro- and macro-economic conditions may
also affect the value of the securities held in a client’s portfolio, and general economic
downturns can trigger corresponding losses across various asset classes and security
types. Market cycles may cause overall volatility and fluctuations in a portfolio’s value,
and may increase the likelihood that securities are purchased when values are
comparatively high and/or that securities are sold when values are comparatively low.
Geopolitical shifts may result in market uncertainty, lowered expected returns, and
general volatility in both domestic and international securities. Regulatory changes may
have a negative impact on capital formation and increase the costs of doing business,
and therefore result in decreased corporate profits and corresponding market values of
securities.
iii.
Investing in mutual funds does not guarantee a return on investment, and shareholders of
a mutual fund may lose the principal that they’ve invested into a particular mutual fund.
Mutual funds invest into underlying securities that comprise the mutual fund, and as such
clients are exposed to the risks arising from such underlying securities. Mutual funds
charge internal expenses to their shareholders (which can include management fees,
administration fees, shareholder servicing fees, sales loads, redemption fees, and other
fund fees and expenses, e.g.), and such internal expenses subtract from its potential for
market appreciation. Shares of mutual funds may only be traded at their stated net asset
value (“NAV”), calculated at the end of each day upon the market’s close.
Investing in ETFs bears similar risks and incurs similar costs to investing in mutual funds
as described above. However, shares of an ETF may be traded like stocks on the open
market and are not redeemable at an NAV. As such, the value of an ETF may fluctuate
throughout the day and investors will be subject to the cost associated with the bid-ask
spread (the difference between the price a buyer is willing to pay (bid) for an ETF and the
seller's offering (asking) price).
Page 10 of 21
Date of Brochure: June 8, 2026
Clients are encouraged to carefully read the prospectus of any mutual fund or ETF to be
purchased for investment to obtain a full understanding of its respective risks and costs.
Hedge Funds often engage in leveraging and other speculative investment practices that
may increase the risk of investment loss; can be highly illiquid; are not required to provide
periodic pricing or valuation information to investors; may involve complex tax structures
and delays in distributing important tax information; are not subject to the same
regulatory requirements as mutual funds; and often charge high fees. In addition, hedge
funds may invest in risky securities and engage in risky strategies.
Page 11 of 21
Date of Brochure: June 8, 2026
Item 9: Disciplinary Information
There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of
Adviser’s advisory business or the integrity of Adviser’s management.
Page 12 of 21
Date of Brochure: June 8, 2026
Item 10: Other Financial Industry Activities & Affiliations
A. Neither Aligne Wealth Preservation & Insurance Services, LLC nor its representatives are
registered as, or have pending applications to become, a broker/dealer or a representative of a
broker/dealer.
B. Neither Adviser nor any of its management persons are registered, or have an application
pending to register, as a futures commission merchant, commodity pool operator, a commodity
trading advisor, or an associated person of the foregoing entities.
C. Ivan Illan serves as Chief Investment Officer at AWAIM (HK) Limited, a participating affiliate of
Aligne Wealth Advisors Investment Management. His role involves investment-related activities,
dedicating about four hours monthly, with roughly 10% of his annual compensation expected from
this affiliation. AWAIM always acts in the best interest of the client and clients always have the
right to decide whether or not to utilize the services of any representative of AWAIM in such
individual’s outside capacities.
D. Ivan Illan is a licensed insurance agent and from time to time will earn an ordinary and customary
commission from the sale of insurance products in such capacity. This creates a conflict of
interest, because Mr. Illan has the potential to earn both an insurance commission and advisory
fee revenue from a client. Mr. Illan addresses this conflict of interest by fully disclosing his
relationship with the applicable insurance provider, and informing clients that they are under no
obligation to purchase any insurance products through him.
Ivan Illan is the General Partner of AWAIM Global Macro Opportunities Fund, GP, the general
partner of AWAIM Global Macro Opportunities Fund, LP, a private fund. AWAIM will recommend
investments in this private fund to those clients for which investment in the fund is suitable. This
presents a conflict of interest in that AWAIM or its related persons may receive more
compensation from investment in the fund than from other investments. Nevertheless, AWAIM
acts in the best interest of the client consistent with its fiduciary duties and clients are not required
invest in the private fund if they do not wish to do so.
Jacob Weston is the Manager of AWAIM Global Macro Opportunities Fund, GP, the general
partner of AWAIM Global Macro Opportunities Fund, LP, a private fund. AWAIM will recommend
investments in this private fund to those clients for which investment in the fund is suitable. This
presents a conflict of interest in that AWAIM or its related persons may receive more
compensation from investment in the fund than from other investments. Nevertheless, AWAIM
acts in the best interest of the client consistent with its fiduciary duties and clients are not required
invest in the private fund if they do not wish to do so.
Jonas Lee is a licensed insurance agent and from time to time will earn an ordinary and
customary commission from the sale of an insurance product in such capacity. This creates a
conflict of interest, because Mr. Lee has the potential to earn both an insurance commission and
advisory fee revenue from a client. Mr. Lee addresses this conflict of interest by fully disclosing
his relationship with the applicable insurance provider, and informing clients that they are under
no obligation to purchase an insurance product through him.
Page 13 of 21
Date of Brochure: June 8, 2026
Item 11: Code of Ethics, Participation or Interest in Client
Transactions & Personal Trading
A. Adviser has adopted a code of ethics that will be provided to any client or prospective client upon
request. Adviser’s code of ethics describes the standards of business conduct that Adviser
requires of its supervised persons, which is reflective of Adviser’s fiduciary obligations to act in
the best interests of its clients. The code of ethics also includes sections related to compliance
with securities laws, reporting of personal securities transactions and holdings, reporting of
violations of the code of ethics to Adviser’s Chief Compliance Officer, pre-approval of certain
investments by access persons, and the distribution of the code of ethics and any amendments to
all supervised persons followed by a written acknowledgement of their receipt.
Ivan Illan is the General Partner ad Jacob Weston is the Manger of AWAIM Global Macro
Opportunities Fund, GP, the general partner of AWAIM Global Macro Opportunities Fund, LP a
private fund. AWIAM will recommend investments in this private fund to those clients for which
investment in the fund is suitable.
B. From time to time, Adviser or its related persons will invest in the same securities (or related
securities such as warrants, options or futures) that Adviser or a related person recommends to
clients. This has the potential to create a conflict of interest because it affords Adviser or its
related persons the opportunity to profit from the investment recommendations made to clients.
Adviser’s policies and procedures and code of ethics address this potential conflict of interest by
prohibiting such trading by Adviser or its related persons if it would be to the detriment of any
client and by monitoring for compliance through the reporting and review of personal securities
transactions. In all instances Adviser will act in the best interests of its clients.
C. From time to time, Adviser or its related persons will buy or sell securities for client accounts at or
about the same time that Adviser or a related person buys or sells the same securities for its own
(or the related person’s own) account. This has the potential to create a conflict of interest
because it affords Adviser or its related persons the opportunity to trade either before or after the
trade is made in client accounts, and profit as a result. Adviser’s policies and procedures and
code of ethics address this potential conflict of interest by prohibiting such trading by Adviser or
its related persons if it would be to the detriment of any client and by monitoring for compliance
through the reporting and review of personal securities transactions. In all instances Adviser will
act in the best interests of its clients.
Page 14 of 21
Date of Brochure: June 8, 2026
Item 12: Brokerage Practices
A. Adviser considers several factors when recommending a custodial broker-dealer for client
transactions and determining the reasonableness of such custodial broker-dealer’s
compensation. Such factors include the custodial broker-dealer’s industry reputation and financial
stability, service quality and responsiveness, execution price, speed and accuracy, reporting
abilities, and general expertise. Assessing these factors as a whole allows Adviser to fulfill its duty
to seek best execution for its clients’ securities transactions. However, Adviser does not
guarantee that the custodial broker-dealer recommended for client transactions will necessarily
provide the best possible price, as price is not the sole factor considered when seeking best
execution. After considering the factors above, Adviser recommends LPL Financial LLC (“LPL”)
and Johnstone Brokerage Services, LLC as custodial broker-dealers for client accounts.
B.
i.
ii.
Adviser does not receive research and other soft dollar benefits in connection with client
securities transactions, which are known as “soft dollar benefits”. However, the custodial
broker-dealer(s) recommended by Adviser do provide certain products and services that
are intended to directly benefit Adviser, clients, or both. Such products and services
include (a) an online platform through which Adviser can monitor and review client
accounts, (b) access to proprietary technology that allows for order entry, (c) duplicate
statements for client accounts and confirmations for client transactions, (d) invitations to
the custodial broker-dealer(s)’ educational conferences, (e) practice management
consulting, and (f) occasional business meals and entertainment.
Adviser does not consider, in selecting or recommending custodial broker-dealers,
whether Adviser or a related person receives client referrals from a custodial broker-
dealer or third-party.
iii.
Adviser may permit clients to direct it to execute transactions through a specified broker-
dealer. Clients must refer to their advisory agreements for a complete understanding of
how they may be permitted to direct brokerage. If a client directs brokerage, the client will
be required to acknowledge in writing that the client’s direction with respect to the use of
brokers supersedes any authority granted to Adviser to select brokers; this direction may
result in higher commissions, which may result in a disparity between free and directed
accounts and trades for the client and other directed accounts may be executed after
trades for free accounts, which may result in less favorable prices, particularly for illiquid
securities or during volatile market conditions. Not all investment advisers allow their
clients to direct brokerage.
Adviser does not retain discretionary authority to select the broker used for transactions,
or to set commissions rates.
C. Adviser retains the ability to aggregate the purchase and sale of securities for clients’ accounts
with the goal of seeking more efficient execution and more consistent results across accounts.
Aggregated trading instructions will not be placed if it would result in increased administrative and
other costs, custodial burdens, or other disadvantages. If client trades are aggregated by Adviser,
such aggregation will be done so as to not to disadvantage any client and to treat all clients as
fairly and equally as possible.
Page 15 of 21
Date of Brochure: June 8, 2026
Item 13: Review of Accounts
A. The Chief Compliance Officer, Associate Portfolio Manager, and Internal Portfolio Operations
Associate of Adviser monitors client accounts on an ongoing basis, and typically reviews client
accounts on an annual basis. Such reviews are designed to ensure that the client is still on track
to achieve his or her financial goals, and that the investments remain appropriate given the
client’s risk tolerance, investment objectives, major life events, and other factors. Clients are
encouraged to proactively reach out to Adviser to discuss any changes to their personal or
financial situation.
B. Other factors that may trigger a review include, but are not limited to, material developments in
market conditions, material geopolitical events, and changes to a client’s personal or financial
situation (the birth of a child, preparing for a home purchase, plans to attend higher education, a
job transition, impending retirement, death or disability among family members, etc.).
C. The custodial broker-dealer will send account statements and reports directly to clients no less
frequently than quarterly. Such statements and reports will be mailed to clients at their address of
record or delivered electronically, depending on the client’s election. If agreed to by Adviser and
client, Adviser or a third-party report provider will also send clients reports to assist them in
understanding their account positions and performance, as well as the progress toward achieving
financial goals.
Page 16 of 21
Date of Brochure: June 8, 2026
Item 14: Client Referrals and Other Compensation
A. Nobody other than clients provide an economic benefit to Adviser for providing investment advice
or other advisory services to clients. However, as described above in Item 12, the custodial
broker-dealer(s) recommended for client accounts provides certain products and services that are
intended to directly benefit Adviser, clients, or both.
Adviser does not compensate non-advisory personnel (solicitors/promoters) for client referrals.
Page 17 of 21
Date of Brochure: June 8, 2026
Item 15: Custody
For clients that do not have their fees deducted directly from their account(s) and have not provided
Adviser with any standing letters of authorization to distribute funds from their account(s), Adviser will not
have any custody of client funds or securities. For clients that have their fees deducted directly from their
account(s) or that have provided Adviser with discretion as to amount and timing of disbursements
pursuant to a standing letter of authorization to disburse funds from their account(s), Adviser will typically
be deemed to have limited custody over such clients’ funds or securities pursuant to the SEC’s custody
rule and subsequent guidance thereto. At no time will Adviser accept full custody of client funds or
securities in the capacity of a custodial broker-dealer, and at all times client accounts will be held by a
third-party qualified custodian as described in Item 12, above.
If a client receives account statements from both the custodial broker-dealer and Adviser or a third-party
report provider, client is urged to compare such account statements and advise Adviser of any
discrepancies between them.
AWAIM may also be deemed to have custody over the funds and securities invested in pooled investment
vehicles that AWAIM manages.
Page 18 of 21
Date of Brochure: June 8, 2026
Item 16: Investment Discretion
Adviser accepts discretionary authority to manage securities accounts on behalf of clients only pursuant
to the mutual written agreement of Adviser and the client through a power-of-attorney, which is typically
contained in the advisory agreement signed by Adviser and the client. This includes the authority to buy,
sell, and otherwise transact in securities and other investment products in client’s account(s) without
necessarily consulting with clients in advance. Clients may place reasonable limitations on this
discretionary authority so long as it is contained in a written agreement and/or power-of-attorney.
Page 19 of 21
Date of Brochure: June 8, 2026
Item 17: Voting Client Securities
A. Adviser does not have and will not accept authority to vote client securities.
B. Clients will receive their proxies or other solicitations directly from their custodial broker-dealer or
a transfer agent, as applicable, and should direct any inquiries regarding such proxies or other
solicitations directly to the sender.
Page 20 of 21
Date of Brochure: June 8, 2026
Item 18: Financial Information
A. Adviser does not require or solicit prepayment of more than $1,200 in fees per client, six months
or more in advance.
B. Adviser has no financial condition that is reasonably likely to impair its ability to meet contractual
commitments to clients.
C. Adviser has not been the subject of a bankruptcy petition at any time during the past ten years.
Page 21 of 21
Date of Brochure: June 8, 2026