ALPHA ZERO LLC

Alpha Zero LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Alpha Zero LLC. If you have any questions about the contents of this brochure, please contact us at (561) 576-2599 or by email at: Jordan@alphazerowealth.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Alpha Zero LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Alpha Zero LLC’s CRD number is: 319050. 2500 North Military Trail, Suite 316 Boca Raton, Florida 33431 (561) 576-2599 Jordan@alphazerowealth.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 08/12/2025 i  Item 2: Material Changes Alpha Zero LLC (“AZ”) has the following material changes to report since its last annual updating amendment on March 19, 2025 are described below. Material changes relate to Alpha Zero LLC’s policies, practices or conflicts of interests only. • AZ has a new service offering and fee structure for advisory services related to alternative investments. Under this service, AZ will introduce, vet, recommend, and advise on one or more alternative investments, for instance real estate partnerships or similarly structured limited liability company, start-up financing and investment opportunities, debt deals, and similar non- traditional investments potentially with limited liquidity. (Items 4 and 5) • AZ has updated its Portfolio Management and Financial Planning fees. (Item 5) • AZ will charge certain clients performance-based fees based on a share of the capital gains or capital appreciation of the assets in a client’s account. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. (Item 6) • Portfolio management fees are calculated using the value of the assets in the Account on the last business day of the prior billing period. The final fee for each quarter will be prorated to reflect any deposits or withdrawals made during the quarter. Specifically, additions to or withdrawals from the account(s) will be prorated based on the number of days remaining in the quarter from the date of such transaction(s), and the fee will be adjusted accordingly. (Item 5) • • The monthly fixed rate for financial planning and consulting is up to $8,333 per month. Financial planning and consulting fees are paid via check, wire or debit/credit card using AdvicePay or Summit Pay. (Item 5) Investing in Leveraged Exchange Traded Funds (ETFs) carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Leverage provides additional risk, as any losses sustained will constitute a greater percentage of principal than if leverage had not been employed. (Item 8) ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................7 Item 7: Types of Clients ..........................................................................................................................................8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................9 Item 9: Disciplinary Information .........................................................................................................................14 Item 10: Other Financial Industry Activities and Affiliations .........................................................................14 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 ................................................................................................................................18 Item 14: Client Referrals and Other Compensation ..........................................................................................19 Item 15: Custody ....................................................................................................................................................20 Item 16: Investment Discretion ............................................................................................................................21 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................21 Item 18: Financial Information .............................................................................................................................21 iii  Item 4: Advisory Business A. Description of the Advisory Firm Alpha Zero LLC (hereinafter “AZ”) is a Limited Liability Company organized in the State of Delaware. The firm was originally formed in March 2022, and the principal owners are Eric Mechler and Jordan Grabowski. AZ also does business under the names Alpha Zero Wealth and Alpha Zero. B. Types of Advisory Services Portfolio Management Services AZ offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. AZ creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring AZ evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. AZ will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. AZ seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of AZ’s economic, investment or other financial interests. To meet its fiduciary obligations, AZ attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, AZ’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is AZ’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Financial Planning & Consulting Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and 2  debt/credit planning. When appropriate, AZ also offers general consulting services which include but are not limited to consultation on matter such as: investments, insurance, tax concerns, retirement, education and debt/credit matters. Financial planning and consulting services are offered as either a one-time service or an ongoing service, which will be specified with the client agreement. Advisory Services: Alternative Investments For certain clients, AZ will introduce, vet, recommend, and advise on one or more alternative investments, for instance real estate partnerships or similarly structured limited liability company, start-up financing and investment opportunities, debt deals, and similar non-traditional investments potentially with limited liquidity. Clients under this arrangement will appoint AZ to provide non-discretionary investment advice with respect to certain investments and potential investments including, in particular, investments introduced by AZ. AZ will assist the client with the implementation and performance monitoring of investment recommendations and oversee investments contained in the portfolio as an agent of the client to obtain and review updates, interact with sponsors, and work on client’s behalf to ensure timely payments from the investments. Services Limited to Specific Types of Investments in the gold and precious metal sectors), treasury AZ generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. AZ may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; 3  • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions AZ offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent AZ from properly servicing the client account, or if the restrictions would require AZ to deviate from its standard suite of services, AZ reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. AZ does not participate in wrap fee programs. E. Assets Under Management AZ has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 183,214,753.00 $ 175 December 2024 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees All assets Up to 2% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. The final fee for each quarter will be prorated to reflect any deposits or withdrawals made during the quarter. Specifically, additions to or withdrawals from the account(s) will be prorated based on the number of days remaining in the quarter from the date of such transaction(s), and the fee will be adjusted accordingly. 4  These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of AZ's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. Financial Planning and Consulting Fees Fixed Fees The negotiated one-time fixed rate for financial planning and consulting is between $0 and $100,000. The monthly fixed rate for financial planning and consulting is up to $8,333 per month. Clients may terminate the agreement without penalty, for full refund of AZ’s fees, within five business days of signing the Financial Planning and Consulting Agreement. Thereafter, clients may terminate the Financial Planning and Consulting Agreement generally upon written notice. Advisory Services: Alternative Investments Fees Clients will pay AZ a fee equal to 2.00% per annum of the capital commitment for each investment from the date of the capital commitment until the date of the investment exit (the “Asset Advisory Fee”). The fee shall be assessed and billed quarterly (0.5% per month) based on the average capital commitment for the prior month during the term. Clients under this arrangement will also pay AZ a performance fee equal to 20% of the profits realized on each investment (the “Performance Fee”). The Performance Fee shall be calculated and assessed as follows: i. ii. The Performance Fee shall be assessed upon client’s gross income from the investment during the life of the investment, such as upon interest payments, fees, dividends, and distributions to client. The Performance Fee shall be assessed upon client’s capital gain, exclusive of taxes, depreciation and costs, upon the investment exit. With respect to an investment exit, the Performance Fee shall be assessed on the amounts returned to client in excess of the capital commitment for the investment. The specific terms performance-based compensation will be clearly defined in the Investment Advisory Contract. Performance based fees are only offered to qualified clients that meets certain net worth and income thresholds, as discussed further below in Item 6. Clients may terminate the agreement without penalty for a full refund of AZ's fees within five business days of signing the Investment Advisory Contract. Thereafter, these services shall continue until the latest to occur of 12 months or the investment exit for any and all investments in the portfolio. 5  B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in advance. Payment of Financial Planning and Consulting Fees Financial planning and consulting fees are paid via check, wire or debit/credit card using AdvicePay or Summit Pay. Financial planning and consulting fees may also be directly deducted from an advisory account specified by the Client if authorization is provided via the client agreement. Fixed financial planning and consulting fees are paid in arrears or in advance, but never more than six months in advance. Fixed fees that are collected in advance, but unearned at the time termination becomes effective (if any), will be refunded based on the prorated amount of work completed at the point of termination. If the agreement is terminated prior to completion of services, the client will be responsible for paying the prorated fee for work completed but unpaid (if any) at the time termination becomes effective. Payment of Advisory Services: Alternative Investments Fees The Asset Advisory Fee and Performance Fees (upon income events for investments and upon an investment exit, including a deferred investment exit) shall be invoiced to the client quarterly in arrears. Payment is due 10 days from receipt by client. Past due invoices shall accrue interest at the lesser of 16% per annum or the maximum rate permitted by law. Payment of Fee-Based Annuities All fees paid to AZ for advisory services are separate and distinct from the internal fees and expenses charged by variable annuity sub-accounts, which are described in each variable annuity’s prospectus. Generally, these internal annuity fees and expenses include a management fee for the annuity and other expenses. Fees for fee-based annuities are billed quarterly, in arrears. AZ’s advisory fee for fee-based annuities is typically 0.5%, but is negotiable. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, annuity fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by AZ. Please see Item 12 of this brochure regarding broker-dealer/custodian. 6  D. Prepayment of Fees AZ collects some fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. E. Outside Compensation For the Sale of Securities to Clients Certain AZ representatives are licensed to accept compensation for the sale of investment products to AZ clients. This presents a conflict of interest and gives the supervised person an incentive to recommend products based on the compensation received rather than on the client’s needs. When recommending the sale of securities or investment products for which the supervised persons receives compensation, AZ will document the conflict of interest in the client file and inform the client of the conflict of interest. Clients always have the right to decide whether to purchase AZ-recommended products and, if purchasing, have the right to purchase those products through other brokers or agents that are not affiliated with AZ. Commissions are not AZ’s primary source of compensation for advisory services. Advisory fees that are charged to clients are not reduced to offset the commissions or markups on securities or investment products recommended to clients. Item 6: Performance-Based Fees and Side-By-Side Management Performance-based fees are based on a share of the capital gains or capital appreciation of the assets in a client’s account. Performance-based compensation may create an incentive for the adviser to recommend an investment that may carry a higher degree of risk to the client. AZ may charge performance fees on the accounts of qualified clients only. The term qualified client means: i. ii. A natural person who, or a company that, immediately after entering into the contract has at least $1,000,000 under the management of the investment adviser; A natural person who, or a company that, the investment adviser entering into the contract (and any person acting on his behalf) reasonably believes, immediately prior to entering into the contract, either: 7  a. Has a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more than $2,200,000. For purposes of calculating a natural person's net worth: i. the person's primary residence must not be included as an asset; ii. Indebtedness secured by the person's primary residence, up to the estimated fair market value of the primary residence at the time the investment advisory contract is entered into may not be included as a liability (except that if the amount of such indebtedness outstanding at the time of calculation exceeds the amount outstanding 60 days before such time, other than as a result of the acquisition of the primary residence, the amount of such excess must be included as a liability); and iii. Indebtedness that is secured by the person's primary residence in excess of the estimated fair market value of the residence must be included as a liability; or iii. iv. Is a qualified purchaser as defined in section 2(a)(51)(A) of the Investment Company Act of 1940 (15 U.S.C. 80a-2(a)(51)(A)) at the time the contract is entered into; or A natural person who immediately prior to entering into the contract is: a. An executive officer, director, trustee, general partner, or person serving in a similar capacity, of the investment adviser; or b. an employee of the investment adviser (other than an employee performing solely clerical, secretarial or administrative functions with regard to the investment adviser) who, in connection with his or her regular functions or duties, participates in the investment activities of such investment adviser, provided that such employee has been performing such functions and duties for or on behalf of the investment adviser, or substantially similar functions or duties for or on behalf of another company for at least 12 months. AZ manages accounts that are billed on performance-based fees (a share of capital gains on or capital appreciation of the assets of a client) as well as accounts that are NOT billed on performance-based fees. Managing both kinds of accounts at the same time presents a conflict of interest because AZ or its supervised persons have an incentive to favor accounts for which AZ and its supervised persons receive a performance-based fee. AZ addresses the conflicts by ensuring that clients are not systematically advantaged or disadvantaged due to the presence or absence of performance-based fees. AZ 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 AZ generally provides advisory services to the following types of clients: 8  ❖ ❖ ❖ Individuals High-Net-Worth Individuals Corporations or other businesses There is an account minimum of $100,000, which may be waived by AZ in its discretion. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis AZ’s methods of analysis include Cyclical analysis, Fundamental analysis and Modern portfolio theory. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Investment Strategies AZ uses long term trading, short term trading, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. 9  Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies AZ's use of margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 10  C. Risks of Specific Securities Utilized investment types AZ's use of margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading 11  conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Leveraged Exchange Traded Funds (ETFs): As addressed above, investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Leverage provides additional risk, as any losses sustained will constitute a greater percentage of principal than if leverage had not been employed. Additionally, if losses occur, the value of the account may fall below the lender’s threshold thereby forcing the account holder to devote more assets to the account or sell assets on a shorter time frame than desired. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance 12  policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Cryptocurrency investing refers to trading in digital/virtual currencies, such as Bitcoin, that are not back by real assets or tangible securities and are more volatile than traditional currencies and financial assets. Digital currency is a digital representation of value that functions as a medium of exchange, a unit of account, or a store of value, but it does not have legal tender status. Digital currency is not backed or supported by any government or central bank. Digital currency’s price is completely derived by market forces of supply and demand, traded between consenting parties with no broker and tracked on digital ledgers commonly known as blockchains. Investing in digital currency comes with significant risk of loss that a client should be prepared to bear and, due to the nature of cryptocurrencies, clients are exposed to the risks normally associated with investing but also unique risks not typical of investing in traditional securities. These, include, but are not limited to, volatile market price swings or flash crashes, market manipulation, 13  economic, regulatory, technical, and cybersecurity risks. Please also see below for additional description/properties: • • Unregulated – Digital currency markets and exchanges are not regulated with the same controls or customer protections available in fixed income, equity, option, futures, or foreign exchange investing. Increased Price Volatility – The price of cryptocurrency is constantly fluctuating. Trade or balance can surge or drop suddenly. Price can drop to zero. • Susceptible to Error/Hacking – Technical glitches, human error and hacking can occur, which typically do not affect traditional securities to the same extent. • Forks – This implies a splitting of the chain on which the cryptocurrency runs, which makes it go in a different direction, with different rules than the existing blockchain. o Soft Fork – only a protocol change; the cryptocurrency still continues to work on the original blockchain rules. o Hard Fork – a permanent divergence in the blockchain. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Some AZ representatives are registered representatives of The Leaders Group Inc., a broker dealer. 14  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither AZ nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Some investment advisor representatives of AZ are also independent licensed insurance agents. This activity creates a conflict of interest since there is an incentive to recommend insurance products based on commissions or other benefits received from the insurance company, rather than on the client’s needs. Additionally, the offer and sale of insurance products by supervised persons of AZ are not made in their capacity as a fiduciary, and products are limited to only those offered by certain insurance providers. AZ addresses this conflict of interest by requiring its supervised persons to act in the best interest of the client at all times, including when acting as an insurance agent. AZ periodically reviews recommendations by its supervised persons to assess whether they are based on an objective evaluation of each client’s risk profile and investment objectives rather than on the receipt of any commissions or other benefits. AZ will disclose in advance how it or its supervised persons are compensated and will disclose conflicts of interest involving any advice or service provided. At no time will there be tying between business practices and/or services (a condition where a client or prospective client would be required to accept one product or service conditioned upon the selection of a second, distinctive tied product or service). No client is ever under any obligation to purchase any insurance product. Insurance products recommended by AZ’s supervised persons may also be available from other providers on more favorable terms, and clients can purchase insurance products recommended through other unaffiliated insurance agencies. Jordan Grabowski and Eric Mechler are general partners of OnePointTwo Capital Management LLC, the manager of OnePointTwo Capital, a private fund. L. Sebastian Purcell is an owner and manager of OnePointTwo Capital. They 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 they may receive more compensation from investment in the fund than from other investments. Nevertheless, AZ 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. Mason Robert Schreck is a Managing Member at 8914 Milam Grove, LLC, 2141 NE 62nd CT, LLC, and at 1057 Hillsboro Mile, LLC. Some AZ representatives are registered representatives of The Leaders Group Inc, a broker-dealer. From time to time, they will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with 15  the fiduciary duties of a registered investment adviser. AZ always acts in the best interest of the client, including with respect to the sale of commissionable products to advisory clients. Clients always have the right to decide whether or not to utilize the services of any AZ representative in such individual’s outside capacities. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections AZ does not utilize nor select third party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics AZ has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. AZ's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests AZ is a general partner of OnePointTwo Capital Management LLC, the manager of OnePointTwo Capital, a private fund. AZ will recommend investments in this private fund to those clients for which investment in the fund is suitable. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of AZ may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of AZ to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. AZ will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. 16  D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of AZ may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of AZ to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, AZ will never engage in trading that operates to the client’s disadvantage if representatives of AZ buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on AZ’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and AZ may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in AZ's research efforts. AZ will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. AZ will require clients to use Schwab Institutional, a division of Charles Schwab & Co., Inc.. 1. Research and Other Soft-Dollar Benefits While AZ has no formal soft dollars program in which soft dollars are used to pay for third party services, AZ may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). AZ may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and AZ does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. AZ benefits by not having to produce or pay for the research, products or services, and AZ will have an incentive to recommend a broker- dealer based on receiving research or services. Clients should be aware that AZ’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 17  2. Brokerage for Client Referrals AZ receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use AZ will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If AZ buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, AZ would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. AZ would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for AZ's advisory services provided on an ongoing basis are reviewed at least monthly by Eric Mechler, Managing Partner, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at AZ are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Eric Mechler, Managing Partner. Financial planning clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts 18  Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, AZ’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of AZ's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) AZ does not receive any economic benefit, directly or indirectly from any third party for advice rendered to AZ's clients. With respect to Schwab, AZ receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For AZ client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to AZ other products and services that benefit AZ but may not benefit its clients’ accounts. These benefits may include national, regional or AZ specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of AZ by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist AZ in 19  managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of AZ’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of AZ’s accounts. Schwab Advisor Services also makes available to AZ other services intended to help AZ manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to AZ by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to AZ. AZ is independently owned and operated and not affiliated with Schwab. B. Compensation to Non – Advisory Personnel for Client Referrals AZ may enter into written arrangements with third parties to act as solicitors for AZ's investment management services. Solicitor relationships will be fully disclosed to each Client to the extent required by applicable law. AZ will ensure each solicitor is exempt, notice filed, or properly registered in all appropriate jurisdictions. All such referral activities will be conducted in accordance with Rule 206(4)-1 under the Advisers Act, where applicable. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, AZ will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Custody is also disclosed in Form ADV because AZ has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, AZ will follow the safeguards specified by the SEC rather than undergo an annual audit. AZ is also deemed to have custody over the funds and securities of clients invested in the pooled investment vehicles in which AZ related persons act as a general partner. Lastly, AZ is deemed to have custody over the funds and securities of clients who AZ has the authority to pay invoices related to third-party service providers. 20  Item 16: Investment Discretion AZ provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, AZ generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Item 17: Voting Client Securities (Proxy Voting) AZ will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet AZ neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither AZ nor its management has any financial condition that is likely to reasonably impair AZ’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years AZ has not been the subject of a bankruptcy petition in the last ten years. 21