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Brochure
Form ADV Part 2A
Item 1 - Cover Page
AM Investment Strategies, LLC
CRD #165823
832 Georgia Avenue
Suite 100
Chattanooga, Tennessee 37402
(423) 486-1888
November 6, 2025
This Brochure provides information about the qualifications and business practices of AM Investment
Strategies, LLC. If you have any questions about the contents of this Brochure, please contact us at
(423) 486-1888. The information in this Brochure has not been approved or verified by the United
States Securities and Exchange Commission or by any state authority.
AM Investment Strategies, LLC is an investment advisory firm registered with the appropriate
regulatory authority. Registration does not imply a certain level of skill or training. Additional
www.AdviserInfo.sec.gov
information about AM Investment Strategies, LLC is also available on the SEC’s website at
.
Item 2 - Material Changes
This Brochure is prepared in the revised format required beginning in 2011. Registered Investment
Advisers are required to use this format in order to inform clients of the nature of advisory services
provided, types of clients served, fees charged, potential conflicts of interest and other information.
The Brochure requirements include providing a Summary of Material Changes (the “Summary”)
reflecting any material changes to our policies, practices, or conflicts of interest made since our last
required “annual update” filing on February 4, 2025. In the event of any material changes, such
Summary is provided to all clients within 120 days of our fiscal year-end. Of course, the complete
Brochure is available to you at any time upon request.
Item 3 – Table of Contents
Page
....................................................................................................................................... 1
Item 1 - Cover Page
............................................................................................................................. 1
Item 2 - Material Changes
............................................................................................................................ 2
Item 3 – Table of Contents
........................................................................................................................... 3
Item 4 - Advisory Business
.................................................................................................................. 7
Item 5 - Fees and Compensation
........................................................... 9
Item 6 - Performance-Based Fees and Side-By-Side Management
............................................................................................................................... 9
Item 7 - Types of Clients
................................................... 10
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
.............................................................................................................. 12
Item 9 - Disciplinary Information
................................................................. 12
Item 10 - Other Financial Industry Activities and Affiliations
........ 13
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
.................................................................................................................... 14
Item 12 - Brokerage Practices
..................................................................................................................... 15
Item 13 - Review of Accounts
................................................................................ 16
Item 14 - Client Referrals and Other Compensation
........................................................................................................................................ 16
Item 15 - Custody
................................................................................................................ 16
Item 16 - Investment Discretion
.............................................................................................................. 17
Item 17 - Voting Client Securities
................................................................................................................. 17
Item 18 - Financial Information
Page 2
Item 4 - Advisory Business
Founded in October 2012, AM Investment Strategies, LLC (“AMIS”) (also referred to as the “firm”)
provides investment management services and limited financial planning. On occasion we will provide
reporting/limited account administration services.
Agreement
Prior to engaging us to provide any of the foregoing investment advisory services, you are required to
enter into one or more written agreements with us setting forth the terms and conditions under which
we render our services (collectively the “
”).
Brochure
who
Supplements
Aon D. Miller and Laura G. Owsley are the principal owners of AMIS. Please see
, Exhibit A, for more information on these principal owners and other individuals
formulate investment advice and have direct contact with clients or have discretionary authority over
client accounts.
As of December 31, 2024, AMIS managed $548,021,757 on a discretionary basis, and $161,881,595 on
a non-discretionary basis.
SERVICES OFFERED
Financial Planning Services
You may elect to retain us to provide limited financial planning services in conjunction with
investment management services. Financial planning services normally address areas such as general
cash flow planning, retirement planning, and insurance analysis. The goal of this service is to assess
your financial circumstances to more effectively develop your Investment Plan.
For those financial planning clients making this election, and for other clients who do not need
financial planning but retain us for investment management services, based on all the information
initially gathered, we generally develop:
•
•
a financial outline for you based on your financial circumstances and goals, and your risk
tolerance level (the “Financial Profile” or “Profile”); and
your investment objective and guidelines (the “Investment Plan” or “Plan”).
The Financial Profile is a reflection of your current financial picture and a look to your future goals.
The Investment Plan outlines the types of investments we will make or recommend on your behalf in
order to meet those goals. The Profile and the Plan are discussed regularly with you, but are not
necessarily written documents.
Investment Management Services
To implement your Investment Plan, we will manage your investment portfolio on a discretionary or a
non-discretionary basis. Most clients choose a discretionary arrangement. As a discretionary
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investment adviser, we have the authority to supervise and direct your portfolio without prior
must
consultation with you, although our typical practice is to discuss trades with you whenever possible
and practical. Under a non-discretionary arrangement, you
be contacted prior to the execution of
any trade in the account(s) under management. This could result in a delay in executing
recommended trades, which could adversely affect the performance of your portfolio. In a non-
discretionary arrangement, you retain the responsibility for the final decision on all actions taken with
respect to your portfolio.
Notwithstanding the foregoing, you may impose certain written restrictions on us in the management
of your investment portfolio, such as prohibiting the inclusion of certain types of investments in an
investment portfolio or prohibiting the sale of certain investments held in the account at the
commencement of the relationship. You should note, however, that restrictions imposed by you may
adversely affect the composition and performance of your investment portfolio. You should also note
that your investment portfolio is treated individually by giving consideration to each purchase or sale
for your account. For these and other reasons, performance of your investment portfolio within the
same investment objectives, goals and/or risk tolerance may differ and you should not expect that the
composition or performance of your investment portfolio would necessarily be consistent with similar
clients of ours.
Item 8
Methods of
We primarily allocate your investment management assets among individual equity securities, but
Analysis, Investment Strategies and Risk of Loss
may also incorporate other securities as further described in response to
-
. In addition, we may recommend that clients who
are “accredited investors” as defined under Rule 501 of the Securities Act of 1933, as amended, invest
in private placement securities, which may include debt, equity, and/or pooled investment vehicles
when consistent with your investment objectives. We also provide advice about any type of
investment held in your portfolio.
We tailor our advisory services to your individual needs. We consult with you initially and on an
ongoing basis to determine risk tolerance, time horizon and other factors that may impact your
investment needs. We ensure that your investments are suitable for your investment needs, goals,
objectives and risk tolerance.
You are advised to promptly notify us if there are changes in your financial situation or investment
objectives or if you wish to impose any reasonable restrictions upon our management services. You
may impose reasonable restrictions or mandates on the management of your account if, in our sole
discretion, the conditions will not materially impact the performance of a portfolio strategy or prove
overly burdensome to its management efforts.
Reporting/Limited Account Administration Services
From time to time you may need limited assistance with one or more accounts and may also request
quarterly reporting on such accounts. These relationships are generally non-discretionary in nature,
and you are the primary driver for activity in the accounts.
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Individual Retirement Advice
When we are making investment recommendations to you regarding your retirement plan account or
individual retirement account, we are acting as 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 or otherwise are compensated creates
some conflicts with your financial 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) to you;
Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
Avoid misleading statements about conflicts of interest, fees, and investments;
Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
Charge no more than what is reasonable for our services; and
Give you basic information about our conflicts of interest.
Retirement Plan Advisory Services
Establishing a sound fiduciary governance process is vital to good decision-making and to ensuring
that prudent procedural steps are followed in making investment decisions. We will provide
Retirement Plan consulting services to Plans and Plan Fiduciaries as described below. The particular
services provided will be detailed in the consulting agreement. The appropriate Plan Fiduciary(ies)
designated in the Plan documents (e.g., the Plan sponsor or named fiduciary) will (i) make the decision
to retain our firm; (ii) agree to the scope of the services that we will provide; and (iii) make the
ultimate decision as to accepting any of the recommendations that we may provide. The Plan
Fiduciaries are free to seek independent advice about the appropriateness of any recommended
services for the Plan. Retirement Plan consulting services may be offered individually or as part of a
comprehensive suite of services.
The Employee Retirement Income Security Act of 1974 (“ERISA”) sets forth rules under which Plan
Fiduciaries may retain investment advisers for various types of services with respect to Plan assets.
For certain services, we will be considered a fiduciary under ERISA. For example, we will act as an
ERISA § 3(21) fiduciary when providing non-discretionary investment advice to the Plan Fiduciaries
by recommending a suite of investments as choices among which Plan Participants may select. Also, to
the extent that the Plan Fiduciaries retain us to act as an investment manager within the meaning of
ERISA § 3(38), we will provide discretionary investment management services to the Plan.
Consulting
Fiduciary
Services
Investment Selection Services
•
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We will provide Plan Fiduciaries with recommendations of investment options consistent with
ERISA section 404(c). Plan Fiduciaries retain responsibility for the final determination of
investment options and for compliance with ERISA section 404(c).
• Non-Discretionary Investment Advice
We provide Plan Fiduciaries and Plan Participants general, non-discretionary investment
advice regarding asset classes and investments.
Investment Monitoring
•
We will assist in monitoring the plan’s investment options by preparing periodic investment
reports that document investment performance, consistency of fund management and
conformation to the guidelines set forth in the investment policy statement and we will make
recommendations to maintain or remove and replace investment options. The details of this
aspect of service will be enumerated in the engagement agreement between the parties.
Management
Fiduciary
Services
• Discretionary Management Services
When retained as an investment manager within the meaning of ERISA § 3(38), we provide
continuous and ongoing supervision over the designated retirement plan assets. We will
actively monitor the designated retirement plan assets and provide ongoing management of
the assets. When applicable, we will have discretionary authority to make all decisions to buy,
sell or hold securities, cash or other investments for the designated retirement plan assets in
our sole discretion without first consulting with the Plan Fiduciaries. We also have the power
and authority to carry out these decisions by giving instructions, on your behalf, to brokers and
dealers and the qualified custodian(s) of the Plan for our management of the designated
retirement plan assets.
• Discretionary Investment Selection Services
We will monitor the investment options of the Plan and add or remove investment options for
the Plan without prior consultation with the Plan Fiduciaries. We will have discretionary
authority to make and implement all decisions regarding the investment options that are
available to Plan Participants.
Non-Fiduciary Services
• Participant Education
We will provide education services to Participants about general investment principles and the
investment alternatives available under the Plan. Education presentations will not take into
account the individual circumstances and individual recommendations will not be provided
unless a Participant separately engage us for such services. Participants are responsible for
implementing transactions in their own accounts.
• Participant Enrollment
We will assist with group enrollment meetings designed to increase retirement Plan
participation among employees and investment and financial understanding by the employees.
Page 6
Item 5 - Fees and Compensation
Investment Management Fees
We provide investment management services for an annual fee based upon a percentage of the market
value of the assets under management. Depending on the specific circumstances, private fund
investments recommended by us may be included in the calculation of the value of your assets under
management. All such arrangements will be agreed to in advance.
Our annual fee is charged monthly, in advance, based upon the market value of the assets being
managed by us on the last day of the previous quarter. The annual fee varies depending upon the
market value of the assets under management, as follows:
Portfolio Value
Annual Fee
Less than $1,000,000
$1,000,000 to $2,000,000
$2,000,000 to $3,000,000
$3,000,001 to $4,000,000
$4,000,001 - $5,000,000
Above $5,000,000
1.00%
0.90%
0.80%
0.75%
0.70%
Negotiable
Our annual fee is exclusive of, and in addition to, brokerage commissions, transaction fees, and other
related costs and expenses which are incurred by you. We do not, however, receive any portion of
these commissions, fees, and costs.
We do not separately charge you for our financial planning services.
In our sole discretion, we may negotiate to charge a lesser management fee based upon certain criteria
pro bono
(i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to
be managed, related accounts, account composition, pre-existing client, account retention,
activities, etc.). Also, from time to time and in our sole discretion, we may agree to exempt certain
assets from the calculation of investment management fees. Although this is a benefit to you overall, it
represents a conflict of interest for us, as we are incentivized to encourage you to move more assets to
the billable category.
Fees Charged by Financial Institutions
Item 12
– Brokerage Practices
As further discussed in response to
, we generally recommend that you
utilize the brokerage and clearing services of an independent broker-dealer for investment
management accounts.
We may only implement our investment management recommendations after you have arranged for
and furnished us with all information and authorization regarding accounts with appropriate financial
institutions. Financial institutions include but are not limited to any broker-dealers recommended by
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Financial Institutions
us, broker-dealers directed by you, trust companies, banks, etc. (collectively referred to herein as the
“
”).
Financial Institutions
You may incur certain charges imposed by the
and other third parties such as
custodial fees, charges imposed directly by a mutual fund or ETF (exchange traded fund) in the
account, which are disclosed in the fund’s prospectus (i.e., fund management fees and other fund
expenses), deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic
fund fees, and other fees and taxes on brokerage accounts and securities transactions. Additionally,
you may incur brokerage commissions and transaction fees. Such charges, fees and commissions are
exclusive of and in addition to our fee.
Agreement
Financial Institutions
and the separate agreement with any
Financial
may authorize us to debit
Our
Institutions
your account for the amount of our fee and to directly remit that management fee to us. Any
recommended by us have agreed to send a statement to you, at least quarterly, indicating
all amounts disbursed from the account including the amount of management fees paid directly to us.
Alternatively, you may elect to receive an invoice for payment.
Fees for Management During Partial Quarters of Service
pro rata
For the initial period of investment management services, the fees are calculated on a
basis. If
assets are deposited into or withdrawn from an account after the inception of a quarter, the fee
payable with respect to such assets will not be adjusted or prorated based on the number of days
remaining in the quarter.
Agreement
Agreement
between you and AMIS will continue in effect until terminated by either party pursuant
. Our fees are prorated through the date of termination and any
The
to the terms of the
remaining balance is charged or refunded to you, as appropriate.
You may make additions to and withdrawals from your account at any time, subject to our right to
terminate an account. Additions may be in cash or securities provided that we reserve the right to
liquidate any transferred securities or decline to accept particular securities into your account. You
may withdraw account assets on notice to us, subject to the usual and customary securities settlement
procedures. However, we design our portfolios as long-term investments and the withdrawal of assets
may impair the achievement of your investment objectives. We may consult with you about the
options and ramifications of transferring securities. You are advised that when transferred securities
are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e.
contingent deferred sales charge) and/or tax ramifications.
Financial Planning Fees
Fees for this service are included in the investment management fee assessed.
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Reporting/Limited Account Administration Fees
Agreement
Fees for reporting only or limited account administration are annual set fees. They normally range
from $50 per year to $30,000 per year, depending upon the services requested. Our
authorizes us to debit your account for the amount of our fee and to directly remit this fee to us.
Other Compensation
Supervised Persons
Supervised Persons
Supervised Persons
Insurance Sales
Certain of our
, in their individual capacities, are also licensed insurance agents
appointed with various insurance companies, and in such capacity, may recommend, on a fully
disclosed commission basis, the purchase of certain insurance products. While we do not sell such
insurance products to our investment advisory clients, we do permit our
, in their
individual capacities as licensed insurance agents, to sell insurance products to our investment
advisory clients. A conflict of interest exists to the extent that we recommend the purchase of
insurance products where our
receive insurance commissions or other additional
compensation.
Insurance Referrals
When appropriate, AMIS will refer clients to certain insurance providers and from time to time certain
insurance providers will compensate AMIS for the referrals. This service is designed to assist clients in
finding an independent insurance provider. The fee is paid by the insurance provider, not the client,
and the client does not pay the insurance provider a higher premium as a result of this referral
arrangement.
Alternative Investment Funds
From time to time when appropriate, we will recommend investing in private funds. At least one
Manager of private funds that we have recommended in the past has established brokerage accounts
in which cash awaiting deployment or distribution is held in order to earn a more favorable rate of
interest than can be earned at a bank. We earn a deeply discounted fee on these accounts (2 bps per
year).
Item 6 - Performance-Based Fees and Side-By-Side Management
We do not have any performance-based fee arrangements. “Side-by-Side Management” refers to a
situation in which the same firm manages accounts that are billed based on a percentage of assets
under management and at the same time manages other accounts for which fees are assessed on a
performance fee basis. Because we have no performance-based fee accounts, we have no side-by-side
management.
Item 7 - Types of Clients
We provide our services to individuals, trusts, estates, pension and profit-sharing plans and business
entities.
Page 9
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Our primary method of analysis is fundamental, which involves the fundamental financial condition
and competitive position of a company. We will analyze the financial condition, capabilities of
management, earnings, new products and services, as well as the company’s markets and position
amongst its competitors in order to determine the recommendations made to you. The primary risk in
using fundamental analysis is that while the overall health and position of a company may be good,
market conditions may negatively impact the security.
Investment Strategies
We rely on our proprietary investment strategies to build custom portfolios based on your risk
tolerance and investment goals. The portfolio strategy may be conservative, moderate growth, or
aggressive growth (or a combination). We primarily utilize common or preferred stocks, money
market funds, individual debt securities, alternative securities and institutional mutual funds in our
client accounts, but may also hold a cash position depending on market conditions. In addition, when
appropriate for your circumstances, we may select one or sub-advisers to manage a portion of your
portfolio.
Risk of Loss
While we seek to diversify your investment portfolio across various asset classes consistent with your
Investment Plan in an effort to reduce risk of loss, all investment portfolios are subject to risks.
Accordingly, there can be no assurance that your investment portfolio will be able to fully meet your
investment objectives and goals, or that investments will not lose money.
Below is a description of several of the principal risks that your investment portfolio faces and that
you should be prepared to bear.
Management Risks.
While we manage your investment portfolio based on our experience, research
and proprietary methods, the value of your investment portfolio will change daily based on the
performance of the underlying securities in which they are invested. Accordingly, your investment
portfolio is subject to the risk that we (or a selected sub-adviser) may allocate your assets to individual
securities and/or asset classes that are adversely affected by unanticipated market movements, and
the risk that our specific investment choices could underperform their relevant indexes.
Risks of Investments in Mutual Funds, ETFs and Other Investment Pools.
As described above, we may
invest your portfolio in mutual funds, ETFs and other investment pools (“pooled investment funds”).
Investments in pooled investment funds are generally less risky than investing in individual securities
because of their diversified portfolios; however, these investments are still subject to risks associated
with the markets in which they invest. In addition, pooled investment funds’ success will be related to
the skills of their particular managers and their performance in managing their funds. Pooled
investment funds are also subject to risks due to regulatory restrictions applicable to registered
investment companies under the Investment Company Act of 1940.
Page 10
Risks Related to Alternative Investment Vehicles
. From time to time and as appropriate, we may
recommend that you invest a portion of your portfolio in alternative vehicles. The value of your
portfolio will be based in part on the value of alternative investment vehicles in which they are
invested, the success of each of which will depend heavily upon the efforts of their respective
Managers. When the investment objectives and strategies of a Manager are out of favor in the market
or a Manager makes unsuccessful investment decisions, the alternative investment vehicles managed
by the Manager may lose money. Your account may lose a substantial percentage of its value if the
investment objectives and strategies of many or most of the alternative investment vehicles in which it
is invested are out of favor at the same time, or many or most of the Managers make unsuccessful
investment decisions at the same time. From time to time, we may recommend alternative investment
vehicles in which our personnel have invested and/or alternative investment vehicles in which other
clients of ours have a financial interest.
Equity Market Risks.
We (or a selected sub-adviser) will generally invest portions of your assets
directly into equity investments, primarily stocks, or into pooled investment funds that invest in the
stock market. As noted above, while pooled investments have diversified portfolios that may make
them less risky than investments in individual securities, funds that invest in stocks and other equity
securities are nevertheless subject to the risks of the stock market. These risks include, without
limitation, the risks that stock values will decline due to daily fluctuations in the markets, and that
stock values will decline over longer periods (e.g., bear markets) due to general market declines in the
stock prices for all companies, regardless of any individual security’s prospects.
Fixed Income Risks.
We (or a selected sub-adviser) may invest portions of your assets directly into
fixed income instruments, such as bonds and notes, or may invest in pooled investment funds that
invest in bonds and notes. While investing in fixed income instruments, either directly or through
pooled investment funds, is generally less volatile than investing in stock (equity) markets, fixed
income investments nevertheless are subject to risks. These risks include, without limitation, interest
rate risks (risks that changes in interest rates will devalue the investments), credit risks (risks of
default by borrowers), or maturity risk (risks that bonds or notes will change value from the time of
issuance to maturity).
Foreign Securities Risks.
We (or a selected sub-adviser) may invest portions of your assets into pooled
investment funds that invest internationally. While foreign investments are important to the
diversification of your investment portfolio, they carry risks that may be different from U.S.
investments. For example, foreign investments may not be subject to uniform audit, financial
reporting or disclosure standards, practices or requirements comparable to those found in the U.S.
Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in
investment or exchange control regulations. Finally, foreign investments may involve currency risk,
which is the risk that the value of the foreign security will decrease due to changes in the relative value
of the U.S. dollar and the security’s underlying foreign currency.
Use of Margin:
To the extent that you authorize the use of margin, and margin is thereafter employed
by us in the management of your investment portfolio, the market value of your account and
Page 11
corresponding fee payable by you to us will not be increased.
While the use of margin borrowing can substantially improve returns, such use may also increase the
adverse impact to which your portfolio may be subject. Borrowings will usually be from securities
brokers and dealers and will typically be secured by your securities and/or other assets. Under certain
circumstances, such a broker-dealer may demand an increase in the collateral that secures your
obligations and if you were unable to provide additional collateral, the broker-dealer could liquidate
assets held in the account to satisfy your obligations to the broker-dealer. Liquidation in that manner
could have extremely adverse consequences. In addition, the amount of your borrowings and the
interest rates on those borrowings, which will fluctuate, will have a significant effect on your
profitability.
Item 9 - Disciplinary Information
®
®
certification, suspended Aon’s use of the CFP
We are required to disclose the facts of any legal or disciplinary events that are material to your
evaluation of our advisory business or the integrity of management. On December 18, 2015, a FINRA
hearing panel issued a decision finding that when Aon Miller was associated with a broker-dealer he
participated in certain private securities transactions without providing prior written notice to his
then employer as required by certain FINRA rules. The panel ordered a suspension from association
with any FINRA member for two years, a fifty thousand dollar fine, and an order to pay costs. Aon
appealed the decision on the grounds that he did not violate these rules and/or that the sanctions were
too high for various reasons, including that he received no compensation or other benefit in
connection with the transactions. On appeal, FINRA’s National Adjudicatory Council (“NAC”) agreed to
reduce the suspension by one year and the fine by one half. The NAC also found that Aon’s
participation in these private securities transactions violated certain FINRA rules but did not involve a
violation of any federal or state securities laws and he did not receive any compensation or pecuniary
interest resulting from the transactions. Although some sanctions remained in place, Aon has not been
associated with a broker-dealer since 2013; therefore, these sanctions have no effect on his advisory
business. AMIS is a registered investment adviser, and is not a FINRA member or broker-dealer;
consequently, the decision also has no effect on AMIS or its operations. Finally, in July 2019 the
Disciplinary and Ethics Commission of the Certified Financial Planner Board of Standards, which sets
marks for a period
and enforces standards for the CFP
of twelve (12) months based on the same issue.
Item 10 - Other Financial Industry Activities and Affiliations
From time to time when appropriate in light of client circumstances, AMIS will recommend
investments in private funds. The Manager of at least one of the funds has engaged AMIS to manage a
cash management brokerage account, and manage the cash held while awaiting investment inside the
fund or distribution to investors. AMIS earns a deeply discounted fee (2 bps annually) on these
accounts, and therefore has a conflict of interest in recommending these funds to our clients.
Neither AMIS nor its Management Persons have any other financial industry activities or affiliations to
report.
Page 12
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Code of Ethics and Personal Trading
We have adopted a Code of Ethics (“the Code”), the full text of which is available to you upon request.
Our Code has several goals. First, the Code is designed to assist us in complying with applicable laws
and regulations governing our investment advisory business. Under the Investment Advisers Act of
1940, we owe fiduciary duties to our clients. Pursuant to these fiduciary duties, the Code requires
persons associated with us (managers, officers and employees) to act with honesty, good faith and fair
dealing in working with clients. In addition, the Code prohibits such associated persons from trading
or otherwise acting on insider information.
Next, the Code sets forth guidelines for professional standards for our associated persons. Under the
Code’s Professional Standards, we expect our associated persons to put your interests ahead of
personal interests. In this regard, our associated persons are not to take inappropriate advantage of
their positions in relation to our clients.
Third, the Code sets forth policies and procedures to monitor and review the personal trading
activities of associated persons. From time to time our associated persons may invest in the same
securities recommended to you. Under our Code, we have adopted procedures designed to reduce or
eliminate conflicts of interest that this could potentially cause. The Code’s personal trading policies
include procedures for limitations on personal securities transactions of associated persons, reporting
and review of such trading and pre-clearance of certain types of personal trading activities. These
policies are designed to discourage and prohibit personal trading that would disadvantage clients. The
Code also provides for disciplinary action as appropriate for violations.
Personal Trading
Participation or Interest in Client Transactions
Because associated persons may invest in the same securities as those held in your account, we have
adopted policies that restrict personal trading so that associated persons either trade at the same time
(and same price) as you, or generally after 3:00 p.m. or after all client trades for the day are complete.
The goal of this policy is to avoid conflicts of interest that may arise. Some types of securities, such as
CDs, treasury obligations and open-end mutual funds are exempt from these requirements. However,
in the event of other identified potential trading conflicts of interest, our goal is to place your interests
first.
Consistent with the foregoing, we also maintain policies regarding participation in initial public
offerings (“IPOs”) and private placements to comply with applicable laws and avoid conflicts with
client transactions. If an associated person of ours wishes to participate in an IPO or invest in a private
placement, he or she must submit a pre-clearance request and obtain the approval of the Chief
Compliance Officer.
Page 13
.
Finally, if associated persons trade with client accounts (i.e., in a bundled or aggregated trade), and the
trade is not filled in its entirety, the associated person’s shares will be removed from the block, and the
balance of shares will be allocated among client accounts in accordance with our written policy
Other Conflicts
As previously noted, when appropriate for client circumstances we will recommend participation in
alternative investments (i.e., private funds). Associated persons of AMIS may also hold positions in the
same funds we recommend to clients.
At least one such fund manager has engaged AMIS to manage cash accounts for its funds. These
accounts hold deposits from capital calls until such time as cash is deployed for the fund’s investments.
The accounts may also hold proceeds from closed positions inside the funds until those proceeds are
reinvested or distributed. Because we earn a discounted fee of 2 bp annually on these cash
management account balances, we have a conflict of interest in recommending that clients invest in
these funds.
Item 12 - Brokerage Practices
Fidelity
We generally recommend that you utilize the brokerage and clearing services of Fidelity Brokerage
Services, LLC (“
”) for investment management accounts.
Fidelity
Fidelity
Fidelity
Financial Institutions
or any other broker-dealer to you include their
Factors which we consider in recommending
respective financial strength, reputation, execution, pricing, research and service.
enables us to
obtain some mutual funds without transaction charges and other securities at nominal transaction
charges. The commissions and/or transaction fees charged by
may be higher or lower than
those charged by other
.
Financial Institution
Financial Institution’s
The commissions paid by our clients comply with our duty to obtain “best execution.” You may pay
commissions that are higher than another qualified
might charge to effect the
same transaction where we determine that the commissions are reasonable in relation to the value of
the brokerage and research services received. In seeking best execution, the determinative factor is
not the lowest possible cost, but whether the transaction represents the best qualitative execution,
taking into consideration the full range of a
services, including among others, the
value of research provided, execution capability, commission rates, and responsiveness. We seek
competitive rates but may not necessarily obtain the lowest possible commission rates for your
transactions.
For our clients’ accounts that Fidelity maintains, Fidelity generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades that it
executes or that settle into your Fidelity account. Certain trades may not incur Fidelity commissions or
transaction fees. Fidelity is also compensated by earning interest on the uninvested cash in your
account.
Page 14
Financial Institutions
in light of our duty to obtain best execution.
We periodically and systematically review our policies and procedures regarding our recommendation
of
Support Provided by Financial Institutions
Fidelity
Fidelity
Fidelity
, without cost to us, computer software and related systems support,
We may receive from
. We may receive the software and
which allow us to better monitor your account maintained at
related support without cost because we render investment management services to clients that
maintain assets at
. The software and support is not provided in connection with securities
transactions of clients (i.e., not “soft dollars”). The software and related systems support may benefit
us, but not our clients directly. In fulfilling our duties to you, we endeavor at all times to put your
interests first. You should be aware, however, that our receipt of economic benefits from a broker-
dealer creates a conflict of interest since these benefits may influence our choice of broker-dealer over
another broker-dealer that does not furnish similar software, systems support, or services.
Fidelity
Additionally, we may receive the following benefits, without limitation, from
: receipt of
duplicate client confirmations and bundled duplicate statements; access to a trading desk that
exclusively services its Institutional Wealth Services Group participants; access to block trading which
provides the ability to aggregate securities transactions and then allocate the appropriate shares to
client accounts; and access to an electronic communication network for client order entry and account
information.
Directed Brokerage
We do not generally allow directed brokerage accounts.
Aggregated Trades
Transactions for you generally will be placed individually as opposed to being placed in a “block”
trade. Although in most cases we have the discretion to place trades without prior consultation with
you, our typical practice is to discuss trades with you whenever possible. This affords you an
opportunity to discuss the proposed trade, learn about a new security being added to a portfolio, and
discuss tax and other ramifications of the sale of securities. Because trades are placed at different
times throughout the day and even over multiple days, all clients will not receive the same execution
price for the same security. In addition, with block trading there may be some economies of scale to be
achieved, which could provide a price advantage that may not be achieved with individual trades.
Although not a common practice, in the event that we deem it to be necessary or advisable, as well as
consistent with our duty to seek best execution for you, we will block trades.
Item 13 - Review of Accounts
For those clients to whom we provide investment management services, we monitor those portfolios
as part of an ongoing process while regular account reviews are conducted on at least an annual basis.
For those clients to whom we provide financial planning and/or consulting services, reviews are
conducted on an “as needed” basis. Such reviews are conducted by one of our investment adviser
Page 15
representatives. You are encouraged to discuss your needs, goals, and objectives with us and to keep
us informed of any changes thereto. We contact ongoing investment advisory clients at least annually
to review our previous services and/or recommendations and to discuss the impact resulting from any
changes in your financial situation and/or investment objectives.
Unless otherwise agreed upon, you are provided with transaction confirmation notices and regular
summary account statements directly from the broker-dealer or custodian for your account. Those
clients to whom we provide investment advisory services will also receive a report from us that may
include such relevant account and/or market-related information such as an inventory of account
holdings and account as clients may request from time to time. You should compare the account
statements you receive from your custodian with those you receive from us.
Those clients to whom we provide financial planning services will receive reports from us
summarizing our analysis and conclusions as requested by you or as otherwise agreed to in writing by
us.
Item 14 - Client Referrals and Other Compensation
Item 12 - Brokerage Practices.
Financial Institution
As noted above, we receive an economic benefit from Fidelity in the form of support products and
services it makes available to us and other independent investment advisors that have their clients
maintain accounts at Fidelity. These products and services, how they benefit our firm, and the related
The availability of Fidelity’s
conflicts of interest are described in
products and services to us is based solely on our participation in the programs and not on the
provision of any particular investment advice. Neither Fidelity nor any other party is paid to refer
clients to us.
Item 15 - Custody
Agreement
Financial Institution
and/or the separate agreement with any
may authorize us through
to debit your account for the amount of our fee and to directly remit that
Our
such
management fee to us in accordance with applicable custody rules.
Financial Institutions
Item 13 -
Review of Accounts
Financial Institutions
recommended by us have agreed to send a statement to you, at least
The
quarterly, indicating all amounts disbursed from your account including the amount of management
fees paid directly to us. In addition, as discussed in
, we also send
periodic supplemental reports to you. You are urged to carefully review the statements sent directly
by the
and compare them to those received from us.
Item 16 - Investment Discretion
Item 4 - Advisory Business
, we manage most client portfolios on a
As described above under
discretionary basis. This means that after an Investment Plan is developed for your investment
portfolio, we will execute that plan without specific consent from you for each transaction. For these
discretionary accounts, a Limited Power of Attorney (“LPOA”) is executed by you, giving us the
authority to carry out various activities in your account, generally including the following: trade
execution; the ability to request checks on your behalf; and, the withdrawal of advisory fees directly
Page 16
from your account. We then direct investment of your portfolio using our discretionary authority. You
may limit the terms of the LPOA to the extent consistent with your investment advisory agreement
with us and the requirements of your custodian. The discretionary relationship is further described in
the agreement between you and AMIS.
non-discretionary
For
accounts, you also generally execute an LPOA, which allows us to carry out trade
recommendations and approved actions in your portfolio. However, in accordance with the
investment advisory agreement between you and AMIS, we do not
implement trading
recommendations or other actions in your account unless and until you have approved the
recommendation or action. As with discretionary accounts, you may limit the terms of the LPOA,
subject to our agreement with you and the requirements of your custodian.
Item 17 - Voting Client Securities
Financial
Institutions
We do not vote client securities on your behalf. You receive proxies directly from the
and may contact us with any questions by calling the number on the cover of this
Disclosure Brochure.
Item 18 - Financial Information
We do not require or solicit the prepayment of more than $1,200 in fees six months or more in
advance. In addition, we are required to disclose any financial condition that is reasonably likely to
impair our ability to meet contractual commitments to you. We have no disclosures pursuant to this
Item.
Page 17
Exhibit A
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Aon D. Miller, CFP®
CRD# 3083225
of
AM Investment Strategies, LLC
832 Georgia Avenue
Suite 100
Chattanooga, Tennessee 37402
(423) 486-1888
www.amillerinvest.com
November 6, 2025
This Brochure Supplement provides information about Aon Miller, and supplements the AM
Investment Strategies, LLC (“AMIS”) Brochure. You should have received a copy of that Brochure.
Please contact us at (423) 486-1888 if you did not receive our Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Aon is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Aon D. Miller (year of birth 1973) is Managing Principal and Portfolio Manager of AMIS. Aon
provides you with personalized financial planning that centers around your specific goals and
needs by focusing on individual portfolio management, comprehensive investment planning,
security trading and retirement planning services. Prior to forming AMIS in 2012, he was a
Financial Consultant with Benjamin F. Edwards & Co. (2011-2012) and served as an Investment
Adviser Representative with Wells Fargo Advisors (2009-2011), Wachovia Securities (2007-2009),
and A.G. Edwards & Sons (1998-2007).
Aon graduated from the University of Tennessee with a degree in Economics and he is a CERTIFIED
FINANCIAL PLANNER™ professional.
Aon is an active member of several local and regional boards. Some of his positions held include
Vice Chairman of the City of Chattanooga General Pension Plan Board of Directors, past president
and board member of the Tennessee Golf Association, associate director of the Southern Golf
Exhibit A-1
Association and board member of the Tennessee Golf Foundation and board member and secretary
of The Honors Course.
®
®
®
certification is granted by Certified Financial Planner Board of Standards, Inc. (“CFP
* The CFP
Board”). To attain the certification, the candidate must complete the required educational,
examination, experience and ethics requirements set forth by CFP Board. Certain designations,
such as the CPA, CFA and others may satisfy the education component, and allow a candidate to sit
Certification Examination. A comprehensive examination tests the candidate’s ability
for the CFP
to apply financial planning knowledge to client situations. Qualifying work experience is also
required for certification. Qualifying experience includes work in the area of the delivery of the
personal financial planning process to clients, the direct support or supervision of others in the
personal financial planning process, or teaching all, or any portion, of the personal financial
professionals must complete 30 hours of continuing education accepted by
planning process. CFP
the CFP Board every two years.
Item 3 - Disciplinary Information
®
®
AMIS is required to disclose the facts of any legal or disciplinary events that are material to a
client’s evaluation of its advisory business or the integrity of management. On December 18, 2015,
a FINRA hearing panel issued a decision finding that when Aon was associated with a broker-dealer
he participated in certain private securities transactions without providing prior written notice to
his then employer as required by certain FINRA rules. The panel ordered a suspension from
association with any FINRA member for two years, a fifty thousand dollar fine, and an order to pay
costs. Aon appealed the decision on the grounds that he did not violate these rules and/or that the
sanctions were too high for various reasons, including that he received no compensation or other
benefit in connection with the transactions. On appeal, FINRA’s National Adjudicatory Council
(“NAC”) agreed to reduce the suspension by one year and the fine by one half. The NAC also found
that Aon’s participation in these private securities transactions violated certain FINRA rules but did
not involve a violation of any federal or state securities laws and he did not receive any
compensation or pecuniary interest resulting from the transactions. Although some sanctions
remained in place, Aon has not been associated with a broker-dealer since 2013; therefore, these
sanctions have no effect on his advisory business. AMIS is a registered investment adviser, and is
not a FINRA member or broker-dealer; consequently, the decision also has no effect on AMIS or its
operations. Finally, in July 2019 the Disciplinary and Ethics Commission of the Certified Financial
certification,
Planner Board of Standards, which sets and enforces standards for the CFP
marks for a period of twelve (12) months based on the same issue.
suspended Aon’s use of the CFP
Item 4 - Other Business Activities
Aon is also a licensed insurance agent with various insurance companies, and in such capacity, may
recommend, on a fully-disclosed commission basis, the purchase of certain insurance products.
While we do not sell such insurance products to our investment advisory clients, we do permit Aon,
in his capacity as a licensed insurance agent, to sell insurance products to our investment advisory
clients. A conflict of interest exists to the extent that we recommend the purchase of insurance
products where Aon
receives insurance commissions or other additional compensation.
Other than the sale of insurance products, Aon is not engaged in any other investment-related
business or occupation and does not earn compensation for the sale of any other products or
services.
Exhibit A-2
Item 5 - Additional Compensation
As stated above, Aon has no other income or compensation to disclose.
Item 6 - Supervision
Aon is the Managing Principal of AMIS, and Laura Owsley is a Managing Member and Chief
Compliance Officer. Both are Portfolio Managers and serve on the investment committee. Amber
Erwin is the firm’s Compliance Officer.
Overall investment decisions are made as a team by the investment committee, and portfolio
activity based on these decisions will be carried out by these individuals, as assisted by other staff
members of the firm.
As Compliance Officer, Amber Erwin is responsible for providing compliance oversight to the staff.
She also participates as a team member in the investment and trading processes and may be
contacted at (423) 486-1888.
Exhibit A-3
Brochure Supplement
Form ADV Part 2B
Item 1 - Cover Page
Laura G. Owsley
CRD# 4886775
of
AM Investment Strategies, LLC
832 Georgia Avenue
Suite 100
Chattanooga, Tennessee 37402
(423) 486-1888
www.amillerinvest.com
November 6, 2025
This Brochure Supplement provides information about Laura Owsley, and supplements the AM
Investment Strategies, LLC (“AMIS”) Brochure. You should have received a copy of that Brochure.
Please contact us at (423) 486-1888 if you did not receive our Brochure, or if you have any
questions about the contents of this Supplement.
www.AdviserInfo.sec.gov.
Additional information about Laura is available on the SEC’s website at
Item 2 - Educational Background and Business Experience
Laura G. Owsley (year of birth 1976) is a Managing Member, Portfolio Manager and Chief
Compliance Officer (“CCO”) of AM Investment Strategies, LLC (“AMIS”). Laura is a graduate of
Covenant College, where she received a Bachelor of Science in Organizational Management.
She began her career in the financial industry as a client associate. Her position eventually evolved
to financial advisor/portfolio manager. After years of experience in the financial services industry,
she joined her business partner in forming AM Investment Strategies, LLC. With the formation of
AMIS, she has continued her role as a portfolio manager and also accepted the additional
responsibility of CCO.
As a portfolio manager, Laura focuses on client account servicing, life insurance and annuity
reviews, business account management, portfolio management, and retirement planning. She also
works to assist you in developing a disciplined wealth management process.
Exhibit A-4
Her goal is to have clients live their lives without undue financial sacrifice or overexposure to risk.
She believes that careful planning, while being mindful of tax efficiency and diversifications, offers
you the best chance of success at building wealth over time.
Item 3 - Disciplinary Information
As the CCO, she is responsible for administering all of our compliance procedures and policies.
Advisers are required to disclose any material facts regarding certain legal or disciplinary events
that would be material to your evaluation of an adviser; however, Laura has no such disciplinary
information to report.
Item 4 - Other Business Activities
receives
Laura is also a licensed insurance agent with various insurance companies, and in such capacity,
may recommend, on a fully disclosed commission basis, the purchase of certain insurance products.
While we do not sell such insurance products to our investment advisory clients, we do permit
Laura, in her capacity as a licensed insurance agent, to sell insurance products to our investment
advisory clients. A conflict of interest exists to the extent that we recommend the purchase of
insurance products where Laura
insurance commissions or other additional
compensation.
Other than the sale of insurance products, Laura is not engaged in any other investment-related
business or occupation and does not earn compensation for the sale of any other products or
Item 5 - Additional Compensation
services.
Other than as stated above, Laura has no other income or compensation to disclose.
Item 6 - Supervision
Laura is a Managing Member and Chief Compliance Officer of AMIS, and Aon Miller is the Managing
Principal. Both are Portfolio Managers and serve on the investment committee. Amber Erwin is the
firm’s Compliance Officer.
Overall investment decisions are made as a team by the investment committee, and portfolio
activity based on these decisions will be carried out by these individuals, as assisted by other staff
members of the firm.
As Compliance Officer, Amber Erwin is responsible for providing compliance oversight to the staff.
She also participates as a team member in the investment and trading processes and may be
contacted at (423) 486-1888.
Exhibit A-5