Overview

Assets Under Management: $294 million
Headquarters: CINCINNATI, OH
High-Net-Worth Clients: 87
Average Client Assets: $3 million

Frequently Asked Questions

ARGENTARII, LLC charges 1.00% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #332112), ARGENTARII, LLC is subject to fiduciary duty under federal law.

ARGENTARII, LLC is headquartered in CINCINNATI, OH.

ARGENTARII, LLC serves 87 high-net-worth clients according to their SEC filing dated November 18, 2025. View client details ↓

According to their SEC Form ADV, ARGENTARII, LLC offers portfolio management for individuals, portfolio management for pooled investment vehicles, portfolio management for institutional clients, pension consulting services, and selection of other advisors. View all service details ↓

ARGENTARII, LLC manages $294 million in client assets according to their SEC filing dated November 18, 2025.

According to their SEC Form ADV, ARGENTARII, LLC serves high-net-worth individuals, pooled investment vehicles, institutional clients, and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (ADV PART 2A)

MinMaxMarginal Fee Rate
$0 and above 1.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $50,000 1.00%
$10 million $100,000 1.00%
$50 million $500,000 1.00%
$100 million $1,000,000 1.00%

Clients

Number of High-Net-Worth Clients: 87
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 96.12
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 383
Discretionary Accounts: 383

Regulatory Filings

CRD Number: 332112
Filing ID: 2028256
Last Filing Date: 2025-11-18 12:51:56
Website: 0

Form ADV Documents

Additional Brochure: ADV PART 2A (2025-11-18)

View Document Text
Argentarii, LLC FORM ADV PART 2A BROCHURE 3825 Edwards Rd Suite 650 Cincinnati, OH 45209 Phone: 513.488.1600 Website: https://www.argentarii.com November 18, 2025 1 Item 2 Material Changes This item is used to provide you with a summary of new and/or updated information. You will receive a summary of any material changes to this brochure within 120 days of the end of our fiscal year. Furthermore, we will provide you with other interim disclosures about material changes, as necessary. Since our last brochure filed on August 27, 2025, the firm’s disclosure brochure has had the following material changes: • Item 6: Updated to add performance based fees for private placement offerings. • Item 8: Added structured notes as an investment offering. You may also obtain a copy of this brochure by contacting Ryan Murray, Chief Compliance Officer, by phone at (513) 800-4895, or by email at murray@argentarii.com. Additional information about Argentarii, LLC is available via the SEC’s website www.adviserinfo.sec.gov. 2 Contents Item 2 Material Changes ...................................................................................................................................... 2 Item 4 Advisory Business .................................................................................................................................... 4 Item 5 Fees and Compensation ........................................................................................................................... 6 Item 6 Performance-Based Fees and Side-By-Side Management ......................................................................... 7 Item 7 Types of Clients ........................................................................................................................................ 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss..................................................................... 8 Item 9 Disciplinary Information ........................................................................................................................... 15 Item 10 Other Financial Industry Activities and Affiliations ................................................................................... 16 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 .............................................................................................. 18 Item 15 Custody ................................................................................................................................................ 18 Item 16 Investment Discretion ............................................................................................................................ 18 Item 17 Voting Client Securities ......................................................................................................................... 19 Item 18 Financial Information ............................................................................................................................. 19 3 Item 4 Advisory Business Description of Firm Argentarii, LLC (“Argentarii” or “the Firm”) is a registered investment adviser based in Cincinnati, Ohio. Argentarii is organized as a limited liability company (“LLC”) under the laws of the Delaware in 2024. Brandon Hutchinson and Ryan Murray are Argentarii’s principal owners. Portfolio Management Services Argentarii provides investment management services for clients seeking a personalized approach to implementing an investment strategy designed to meet their goals and objectives. Argentarii works with clients to understand their individual investment objectives, liquidity and cash flow needs, time horizon and risk tolerance, as well as any other factors pertinent to their specific financial situations. After an analysis of the relevant information, Argentarii assists clients in developing an appropriate strategy for managing their assets and financial affairs. Client accounts are managed primarily on a discretionary basis, but the firm may accommodate clients who prefer their assets to be managed on a non-discretionary basis. At the beginning of Argentarii’s relationship with you, your financial professional will review your current investment portfolio, obtain information necessary to understand your current and expected financial situation, discuss with you your investment history, objectives, special interests, and risk tolerance, and make recommendations regarding your portfolio. Notwithstanding the foregoing, clients may impose certain written restrictions on us in the management of their investment portfolios, 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. Each client should note, however, that restrictions imposed by a client may adversely affect the composition and performance of the client's investment portfolio. Each client should also note that his or her investment portfolio is treated individually by giving consideration to each purchase or sale for the client's account. For these and other reasons, performance of client investment portfolios within the same investment objectives, goals and/or risk tolerance may differ, and clients should not expect that the composition or performance of their investment portfolios would necessarily be consistent with similar clients of ours. Clients who choose a nondiscretionary arrangement must be contacted prior to the execution of any trade in the account(s) under management. This may result in a delay in executing recommended trades, which could adversely affect the portfolio's performance. This delay also normally means the affected account(s) will not be able to participate in block trades, a practice designed to enhance the execution quality, timing and/or cost for all accounts included in the block. In a non-discretionary arrangement, the client retains the responsibility for the final decision on all actions taken with respect to the portfolio. You have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis. Client assets are generally invested according to one or more model portfolios developed by the firm or a third-party manager. These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive investment strategy to a more conservative investment approach. In some instances, clients whose assets are invested in model portfolios may not set restrictions on the specific holdings or allocations within the model, nor the types of securities that can be purchased in the model. Nonetheless, clients may impose restrictions on investing in certain securities or types of securities in their account. In such cases, this may prevent a client from investing in certain models that are managed by our firm. 4 Family Office Services In addition to traditional portfolio management, we offer a broad suite of family office services designed to provide centralized oversight and coordination of clients’ financial, estate, tax, and lifestyle matters. These services may include, but are not limited to: • Balance Sheet and Entity Architecture Review – evaluation of family balance sheets and ownership structures. • Investment Oversight, Treasury Execution, and Cash Flow Reporting – monitoring and coordination of investment accounts, discretionary execution of treasury functions, and consolidated cash flow reporting. • Estate Structuring, Tax Strategy, and Risk Review – coordination with tax and estate planning professionals to review structures, strategies, and risk exposures. • Legacy Development, Lifestyle Execution, and Family Coordination – planning and administration of legacy initiatives, coordination of family governance, and support for ongoing lifestyle needs. • Regulatory and Infrastructure Onboarding – assistance with custodian, regulatory, and reporting infrastructure. Family office services are provided under a fixed annual retainer fee, based on the client’s individual needs. See Item 5 for further information regarding family office service fees. Selection of Third-Party Managers On occasion, the Firm may choose to utilize investment strategies from third parties, selecting from a range of investment managers via Goldman Sachs Institutional platform available to RIAs utilizing Goldman Sachs as custodian for client accounts: iCapital, SmartX and CAIS. The firm retains the right to hire and fire third party managers for all client accounts. SMA Programs The firm participates in various SMA programs available through Goldman Sachs. Both single and dual contract programs are available for eligible firm clients. If a client participates in one of these programs, the client may sign an additional advisory agreement directly with the adviser of the SMA. The adviser of the SMA will charge their fee directly to the client, beyond any investment advisory fees charged by the firm. The additional fee for any SMA program available will not exceed 0.50% annually. GLASFunds Argentarii partners with GLASFunds in order to offer a range of alternative investments to qualified clients. GLASFunds is a leading alternative investment platform providing investors with direct access to exclusive private opportunities. If a client chooses to participate in an investment offered through GLASFunds, they will sign a separate client agreement directly with GLASFunds. Clients invested in GLASFunds will incur additional fees and expenses, including but not limited to platform access fees, fund fees, and custodial fees. The actual fees and expenses incurred vary by investment and are provided in the client agreement. For more information on GLASFunds’ fees, see Item 5. Private Placements Argentarii may act as an advisor to private placements. In addition, Argentarii may recommend these private placements to firm clients. Private placements are only available to qualified investors. Additional fees and expenses apply to private placements. See Item 5 for further details regarding fees, and Item 10 regarding important industry affiliations and related conflicts of interest surrounding private placements. Wrap Fee Program(s) A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. Argentarii, LLC does 5 not participate in a wrap fee program. Assets Under Management As of December 31, 2024, Argentarii provides continuous and regular supervisory management and oversight services for $293,787,123 in client assets on a discretionary basis, and $0 in client assets on a non-discretionary basis. Item 5 Fees and Compensation Portfolio Management Services Argentarii’s management fees are negotiable and will vary depending upon factors such as the type of Client Account, a Client’s relationship with the Firm, the size and complexity of assets being managed, and the investment strategies being employed by the Firm. Portfolio Management Services clients will be charged an annual management fee not exceeding 1% of assets under management. Portfolio management fees are generally payable monthly, in arrears, based on the average daily balance of the account(s) during the period. If the portfolio management agreement is executed at any time other than the first day of a calendar month, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the month for which you are a client. Argentarii’s fee is deducted directly from your account through the qualified custodian holding your funds and securities. Advisory fees are deducted only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, your qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account, including fees paid to Argentarii for services rendered. You should review all statements for accuracy. Family Office Services Family office services are generally provided for a fixed annual retainer fee. The fee will vary, depending on the scope of services and client needs. Fees are agreed upon in advance in writing. Retainer fees are typically billed quarterly, in arrears, in equal installments. Investment management services are included in the family office service fees rendered. Clients may incur separate costs and expenses charged by custodians or third-party investment managers. These may include brokerage commissions, transaction charges, custodial fees, mutual fund or exchange-traded fund expense ratios, private investment subscription costs, and other similar charges. Such costs are not included in our advisory fees and are borne directly by the client. SMA Programs Clients participating in SMA programs will have an additional advisory fee charged separately by the SMA adviser. The additional fee for any SMA program available will not exceed 0.50% annually. If a client participates in one of these programs, the client will sign an additional advisory agreement directly with the adviser of the SMA and the adviser of the SMA will charge their fee directly to the client. GLASFunds Additional fees and expenses for GLASFunds vary by investment and are discussed in the GLASFunds agreement signed by the client. They may include but are not limited to platform access fees, fund fees, and custodial fees. The actual fee amounts and terms of payment are set by GLASFunds and vary by investment. Refer to the GLASFunds client agreement for more information. Private Placements Fees and expenses for private placements recommended by Argentarii are fully disclosed in the offering memoranda for the applicable investment. The fees typically include an annual advisory fee (Argentarii fee), plus fees that cover the overhead and administrative expenses incurred by the placement. Some private placements have performance-based fees, which is discussed further in Item 6. Fees and expenses vary based on the underlying investment offering. The annual advisory portion of the fee (Argentarii fee) 6 will not exceed 2% annually. See the applicable private placement memorandum for more details. Additional Fees and Expenses Argentarii may recommend that you invest in mutual funds and exchange traded funds. The fees that you pay to the Firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You may also incur transaction charges and/or brokerage fees when purchasing or selling specific types of securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom your account transactions are executed. Most of the securities purchases on behalf of our clients have no front- end load, sales charge, or back-end load. Any security with such charges will be heavily scrutinized before placing it into a client’s account to ensure that it is the best possible investment for the client's objective. The Firm does not share in any portion of the brokerage fees/transaction charges imposed by the broker- dealer or custodian. Termination of Services Either Argentarii or the client may terminate the investment advisory agreement at any time, subject to written notification requirements in the investment advisory agreement. In the event of termination any fees due to the firm from the client will be invoiced or deducted from the client's account prior to termination. Rollover Recommendations As part of Argentarii’s investment advisory services to you, your financial professional may recommend that you withdraw the assets from your employer's retirement plan and roll the assets over to an individual retirement account ("IRA") that we will manage on your behalf. If you elect to roll the assets to an IRA that is subject to our management, you will be charged an asset-based fee as set forth in the agreement executed with our firm. This practice presents a conflict of interest as our financial professionals have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of: 1)) Leaving the funds in your employer's (former employer's) plan; 2) moving the funds to a new employer's retirement plan; 3) cashing out and taking a taxable distribution from the plan; and/or 4) rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. Our recommendations may include any of them, depending on what we feel is in your best interest. Argentarii’s financial professionals are fiduciaries under the Investment Advisers Act of 1940 and, when providing investment advice to you regarding your retirement plan account or individual retirement account, they are also fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. As a fiduciary, your financial professional is required to document the reason(s) for why the recommendation we made is in your best interest. Item 6 Performance-Based Fees and Side-By-Side Management Performance-Based Fees The Firm charges performance-based fees to certain clients, specifically the private funds that it manages 7 (each, a “Fund”). These performance fees are generally structured as an incentive allocation or performance allocation and are calculated based on the realized and unrealized gains of the Fund, as described in each Fund’s governing documents. Performance-based fees create an incentive for the Firm to make investments that may be riskier or more speculative than would be the case in the absence of such fees. To address this conflict, the Firm has adopted policies and procedures designed to ensure that all investment decisions are made in accordance with each Fund’s investment objectives, risk guidelines, and offering documents. Only “qualified clients,” as defined under Rule 205-3 of the Investment Advisers Act of 1940, are permitted to invest in a Fund that is subject to performance-based fees. The Firm does not charge performance- based fees to any separately managed account (“SMA”) clients. SMA clients pay only asset-based fees as disclosed elsewhere in this Brochure. Side-by-Side Management and Conflicts of Interest Because the Firm manages accounts and Funds with different fee structures, including Funds that pay performance-based fees and other accounts that do not, the Firm may have an incentive to allocate more time, attention, or investment opportunities to the performance-fee Funds. The Firm addresses these conflicts by following a trade allocation policy designed to ensure fair and equitable allocation of investment opportunities among all client accounts over time. In addition, all client accounts are managed in accordance with their stated investment strategies and guidelines. Performance-based compensation may also incentivize the Firm to value Fund assets in a manner that increases the incentive allocation. To mitigate this conflict, asset valuations are made in good faith in accordance with the valuation procedures described in each Fund’s offering documents. Where appropriate, valuations may rely on independent pricing sources or third-party valuation agents. Item 7 Types of Clients Argentarii offers investment advisory services to the following types of clients: Individuals; • • High Net Worth Individuals; • Corporations; • Trusts; • Estates; • Charitable organizations, Foundations, and Endowments; and • Retirement Plans • Pooled Investment Vehicles Clients are required to execute a written investment advisory agreement with Argentarii when establishing an investment advisory relationship. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies Argentarii may use one or more of the following methods of analysis or investment strategies when providing investment advice to you: Charting Analysis - involves the gathering and processing of price and volume pattern information for a particular security, sector, broad index, or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data is used to detect departures from expected performance and diversification and predict future price movements and trends. 8 Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Technical Analysis - involves studying past price patterns, trends, and interrelationships in the financial markets to assess risk-adjusted performance and predict the direction of both the overall market and specific securities. Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Cyclical Analysis - a type of technical analysis that involves evaluating recurring price patterns and trends. Economic/business cycles may not be predictable and may have many fluctuations between long-term expansions and contractions. Risk: The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. Modern Portfolio Theory - a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully diversifying the proportions of various assets. Risk: Market risk is that part of a security's risk that is common to all securities of the same general class (stocks and bonds) and thus cannot be eliminated by diversification. Long-Term Purchases - securities purchased with the expectation that the value of those securities will grow over a relatively extended period of time, generally greater than one year. Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long term, which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost, therefore "locking-up" assets that may be better utilized in the short-term in other investments. Short-Term Purchases - securities purchased with the expectation that they will be sold within a relatively brief period of time, generally less than one year, to take advantage of the securities' short- term price fluctuations. Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short-term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. There are many factors that can affect financial market performance in the short term (such as short-term interest rate changes, cyclical earnings announcements, 9 etc.) but may have a smaller impact over longer periods of time. Option Writing – a securities transaction that involves selling an option. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell a particular security at a specified price on or before the expiration date of the option. When an investor sells a call option, he or she must deliver to the buyer a specified number of shares if the buyer exercises the option. When an investor sells a put option, he or she must pay the strike price per share if the buyer exercises the option and will receive the specified number of shares. The option writer/seller receives a premium (the market price of the option at a particular time) in exchange for writing the option. Risk: Options are complex investments and can be very risky, especially if the investor does not own the underlying stock. In certain situations, an investor’s risk can be unlimited. The Firm’s investment strategies and advice may vary depending upon each client’s specific financial situation. As such, investments and allocations are determined based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. It is important that you notify Argentarii immediately with respect to any material changes to your financial circumstances, including for example, a change in your current or expected income level, tax circumstances, or employment status. Tax Considerations Any investment strategy may have unique and significant tax implications. Argentarii always strives to integrate clients’ tax needs with their investment strategy. However, unless specifically agreed otherwise, tax efficiency is not the primary consideration in the management of client assets. Regardless of your account size or any other factors, it is always strongly recommended that you consult with a tax professional regarding the investing of your assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Your custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to the Firm immediately and your account custodian will be alerted of your individually selected accounting method. Decisions about cost basis accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. Argentarii does not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. The Firm cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Other Risk Considerations When evaluating risk, financial loss may be viewed differently by each client and may depend on many different risks, each of which may affect the probability and magnitude of any potential losses. The following risks may not be all-inclusive but should be considered carefully by a prospective client before retaining our services. • Market Risk – Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. • Equity (stock) market risk – Common stocks are susceptible to general stock market fluctuations and to 10 volatile increases and decreases in value as market confidence in and perceptions of their issuers change. If you held common stock, or common stock equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and debt obligations of the issuer. • Company Risk - When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. • Fixed Income Risk - When investing in bonds, there is the risk that the issuer will default on the bond and be unable to make payments. Further, individuals who depend on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face the same inflation risk. • Options Risk - Options on securities may be subject to greater fluctuations in value than an investment in the underlying securities. Purchasing and writing put and call options are highly specialized activities and entail greater than ordinary investment risks. • ETF and Mutual Fund Risk – When investing in an ETF or mutual fund, you will bear additional expenses based on your pro rata share of the ETF’s or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. You may also incur brokerage costs when purchasing ETFs. • Management Risk – Your investment with our firm varies with the success and failure of our investment strategies, research, analysis, and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. • Liquidity Risk: The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price, or it may not be possible to sell the investment at all. • Credit Risk: Credit risk typically applies to debt investments such as corporate, municipal, and sovereign fixed income or bonds. A bond issuing entity can experience a credit event that could impair or erase the value of an issuer's securities held by a client. • Inflation and Interest Rate Risk: Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of a client's future interest payments and principal. Inflation also generally leads to higher interest rates, which may cause the value of many types of fixed income investments to decline. • Horizon and Longevity Risk: The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If you must sell at a time when the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired or are nearing retirement. Recommendation of Particular Types of Securities Argentarii recommends various types of securities. Each type of security has its own unique set of risks associated with it, and it would not be possible to list here all the specific risks of every investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with the investment. A description of the types of securities the Firm may recommend to you and some of their inherent risks are provided below. 11 Private Placements: A private placement (non-public offering) is an illiquid security sold to qualified investors and is not publicly traded nor registered with the Securities and Exchange Commission. Private placements generally carry a higher degree of risk due to illiquidity. The client’s ability to withdraw from or transfer interests in such funds is severely limited and could include risk of significant loss. Most securities that are acquired in a private placement will be restricted securities and must be held for an extended amount of time and therefore cannot be sold easily. The range of risks depends on the partnership and is disclosed in the offering documents. Money Market Funds: A money market fund is technically a security. The fund managers attempt to keep the share price constant at $1/share. However, there is no guarantee that the share price will stay at $1/share. If the share price goes down, you can lose some or all of your principal. The U.S. Securities and Exchange Commission ("SEC") notes that "While investor losses in money market funds have been rare, they are possible." In return for this risk, you should earn a greater return on your cash than you would expect from a Federal Deposit Insurance Corporation ("FDIC") insured savings account (money market funds are not FDIC insured). Next, money market fund rates are variable. In other words, you do not know how much you will earn on your investment next month. The rate could go up or go down. If it goes up, that may result in a positive outcome. However, if it goes down and you earn less than you expected to earn, you may end up needing more cash. The final risk you are taking with money market funds is inflation. Because money market funds are considered safer than other investments like stocks, long-term average returns on money market funds tend to be less than long-term average returns on riskier investments. Over extended periods of time, inflation can eat away at your returns. Municipal Securities: Municipal securities, while generally thought of as safe, can have significant risks associated with them including, but not limited to: the credit worthiness of the governmental entity that issues the bond; the stability of the revenue stream that is used to pay the interest to the bondholders; when the bond is due to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same amount of interest or yield to maturity. Bonds: Corporate debt securities (or "bonds") are typically safer investments than equity securities, but their risk can also vary widely based on the financial health of the issuer; the risk that the issuer might default; when the bond is set to mature; and, whether or not the bond can be "called" prior to maturity. When a bond is called, it may not be possible to replace it with a bond of equal character paying the same rate of return. Stocks: There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including, but not limited to the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and the overall health of the economy. In general, larger, better-established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") are but the mere size of an issuer is not, by itself, an indicator of the safety of the investment. Mutual Funds and Exchange Traded Funds: Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs of managing the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also 12 reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors. ETFs may have tracking error risks. For example, the ETF investment adviser may not be able to cause the ETF's performance to match that of the Underlying Index or other benchmark, which may negatively affect the ETF's performance. In addition, for leveraged and inverse ETFs that seek to track the performance of their Underlying Indices or benchmarks on a daily basis, mathematical compounding may prevent the ETF from correlating with performance of its benchmark. In addition, an ETF may not have investment exposure to all of the securities included in its Underlying Index, or its weighting of investment exposure to such securities may vary from that of the Underlying Index. Some ETFs may invest in securities or financial instruments that are not included in the Underlying Index, but which are expected to yield similar performance. Leveraged Exchange Traded Funds: Leveraged Exchange Traded Funds ("Leveraged ETFs" or "L- ETF") seek investment results for a single day only, not for longer periods. A "single day" is measured from the time the L-ETF calculates its net asset value ("NAV") to the time of the L-ETF's next NAV calculation. The return of the L-ETF for periods longer than a single day will be the result of each day's returns compounded over the period, which will highly likely differ from multiplying the return by the stated leverage for that period. For periods longer than a single day, the L-ETF will lose money when the level of the Index is flat, and it is possible that the L-ETF will lose money even if the level of the Index rises. Longer holding periods, higher index volatility and greater leverage both exacerbate the impact of compounding on an investor's returns. During periods of higher Index volatility, the volatility of the Index may affect the L-ETF's return as much as or more than the return of the Index. Leveraged ETFs are different from most exchange- traded funds in that they seek leveraged returns relative to the applicable index and only on a daily basis. The L-ETF also is riskier than similarly benchmarked exchange-traded funds that do not use leverage. Accordingly, the L-ETF may not be suitable for all investors and should be used only by knowledgeable investors who understand the potential consequences of seeking daily leveraged investment results. Leveraged ETF Leveraged Risk - The L-ETF obtains investment exposure in excess of its assets in seeking to achieve its investment objective — a form of leverage — and will lose more money in market environments adverse to its daily objective than a similar fund that does not employ such leverage. The use of such leverage could result in the total loss of an investor's investment. For example: a 2X fund will have a multiplier of two times (2x) the Index. A single day movement in the Index approaching 50% at any point in the day could result in the total loss of a shareholder's investment if that movement is contrary to the investment objective of the L-ETF, even if the Index subsequently moves in an opposite direction, eliminating all or a portion of the earlier movement. This would be the case with any such single day movements in the Index, even if the Index maintains a level greater than zero at all times. Leveraged ETF Compounding Risk - Compounding affects all investments but has a more significant impact on a leveraged fund. Particularly during periods of higher Index volatility, compounding will cause results for periods longer than a single day to vary from the stated multiplier of the return of the Index. This effect becomes more pronounced as volatility increases. Leveraged ETF Use of Derivatives - The L-ETF obtains investment exposure through derivatives. Investing in derivatives may be considered aggressive and may expose the L-ETF to greater risks than investing directly in the reference asset(s) underlying those derivatives. These risks include counterparty risk, liquidity risk and increased correlation risk (each as discussed below). When the L- ETF uses derivatives, there may be imperfect correlation between the value of the reference asset(s) and the derivative, which may prevent the L-ETF from achieving its investment objective. Because derivatives often require only a limited initial investment, the use of derivatives may also expose the L- ETF to losses in excess of those amounts initially invested. The L-ETF may use a combination of swaps on the Index and swaps on an ETF that is designed to track the performance of the Index. The performance of an ETF may not track the performance of the Index due to embedded costs and other factors. Thus, to the extent the L-ETF invests in swaps that use an ETF as the reference asset, the L- ETF may be subject to greater correlation risk and 13 may not achieve as high a degree of correlation with the Index as it would if the L-ETF only used swaps on the Index. Moreover, with respect to the use of swap agreements, if the Index has a dramatic intraday move that causes a material decline in the L- ETF's net assets, the terms of a swap agreement between the L-ETF and its counterparty may permit the counterparty to immediately close out the transaction with the L-ETF. In that event, the L-ETF may be unable to enter into another swap agreement or invest in other derivatives to achieve the desired exposure consistent with the L-ETF's investment objective. This, in turn, may prevent the L-ETF from achieving its investment objective, even if the Index reverses all or a portion of its intraday move by the end of the day. Any costs associated with using derivatives will also have the effect of lowering the L-ETF's return. Real Estate Investment Trust: A real estate investment trust ("REIT") is a corporate entity which invests in real estate and/or engages in real estate financing. A REIT reduces or eliminates corporate income taxes. REITs can be publicly or privately held. Public REITs may be listed on public stock exchanges. REITs are required to declare 90% of their taxable income as dividends, but they actually pay dividends out of funds from operations, so cash flow has to be strong or the REIT must either dip into reserves, borrow to pay dividends, or distribute them in stock (which causes dilution). After 2012, the IRS stopped permitting stock dividends. Most REITs must refinance or erase large balloon debts periodically. The credit markets are no longer frozen, but banks are demanding, and getting harsher terms to re-extend REIT debt. Some REITs may be forced to make secondary stock offerings to repay debt, which will lead to additional dilution of the stockholders. Fluctuations in the real estate market can affect the REIT's value and dividends. Options Contracts: Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and puts: A call gives the holder the right to buy an asset at a certain price within a specific period of time. Calls are similar to having a long position on a stock. Buyers of calls hope that the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. Puts are similar to having a short position on a stock. Buyers of puts hope that the price of the stock will fall before the option expires. Selling options are more complicated and can be even riskier. The option trading risks pertaining to option buyers are: • Risk of losing your entire investment in a relatively short period of time. • The risk of losing your entire investment increases if, as expiration nears, the stock is below the strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option). • European style options which do not have secondary markets on which to sell the options prior to expiration can only realize their value upon expiration. • Specific exercise provisions of a specific option contract may create risks. • Regulatory agencies may impose exercise restrictions, which stops you from realizing value. The option trading risks pertaining to options sellers are: • Options sold may be exercised at any time before expiration. • Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call options sold and continues to risk a loss due to a decline in the underlying stock. • Writers of Naked Calls risk unlimited losses if the underlying stock rises. • Writers of Naked Puts risk unlimited losses if the underlying stock drops. • Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include liquidation by the broker. 14 • Writers of call options could lose more money than a short seller of that stock could on the same rise on that underlying stock. This is an example of how the leverage in options can work against the option trader. • Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised. • Call options can be exercised outside of market hours such that effective remedy actions cannot be performed by the writer of those options. • Writers of stock options are obligated under the options that they sold even if a trading market is not available or that they are unable to perform a closing transaction. • The value of the underlying stock may surge or ditch unexpectedly, leading to automatic exercises. Other option trading risks are: • The complexity of some option strategies is a significant risk on its own. • Option trading exchanges or markets and option contracts themselves are open to changes at all times. • Options markets have the right to halt the trading of any options, thus preventing investors from realizing value. • Risk of erroneous reporting of exercise value. • • If an options brokerage firm goes insolvent, investors trading through that firm may be affected. Internationally traded options have special risks due to timing across borders. Risks not specific to options trading include market risk, sector risk and individual stock risk. Option trading risks are closely related to stock risks, as stock options are a derivative of stocks. Past performance is not indicative of future results. Therefore, you should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds, etc.) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. You should be prepared to bear investment loss including loss of original principal. Structured Notes: Structured notes are hybrid securities that combine a bond component with a derivative component and provide returns linked to the performance of an underlying asset, index, interest rate, or market measure. While these instruments may offer contingent income, partial downside protection, or enhanced return potential, they involve significant risks. Structured notes are unsecured debt obligations of the issuing bank, meaning clients are exposed to the issuer’s credit risk and could lose some or all of their investment if the issuer becomes unable to meet its obligations. These products are generally illiquid and may not have an active secondary market, so clients may be unable to sell the investment prior to maturity or may only do so at a material discount. Returns depend on the performance of the underlying reference asset and may expose clients to downside risk, capped upside potential, or leveraged losses. Structured notes can also be complex, and their valuations often may not reflect realizable market values. Many notes include call or early-redemption features that can limit return potential if the issuer exercises that option. In addition, the tax treatment of structured notes can be uncertain or complex, and clients should consult a qualified tax professional regarding potential tax consequences. Investing in structured notes involves the risk of loss of principal, including the possibility of a total loss, and such investments should only be made when appropriate for a client’s financial situation, risk tolerance, and investment objectives. Item 9 Disciplinary Information There are no legal or disciplinary events material to a client’s or prospective client’s evaluation of Argentarii, LLC. 15 Item 10 Other Financial Industry Activities and Affiliations ARG Private Wealth, LLC ARG Private Wealth, LLC is a Registered Investment Advisor with the SEC. ARG Private Wealth, LLC is owned and controlled by persons who own and control Argentarii, LLC. From time to time, representatives of Argentarii may refer clients to ARG Private Wealth. Alternatively, ARG Private Wealth representatives may refer clients to Argentarii. This creates a conflict of interest, as the firm(s) may benefit financially from these recommendations. Argentarii addresses the potential conflict by disclosing it to clients and by implementing policies and procedures designed to ensure the firm’s investment advice is in the best interest of clients, as well as consistent with each client’s investment goals. Argentarii Legacy Planning Services, LLC Argentarii owns and controls Argentarii Legacy Planning Services, LLC. Argentarii Legacy Planning Services, LLC is a consulting firm that specializes in aiding families in addressing the particular challenges of multi-generational enterprise management and family legacy planning through providing advice on strategic charitable giving, community engagement, foundation governance, and impact assessment. This is a fee-based consulting service. The generation of fees from Argentarii Legacy Planning, Services, LLC creates a financial incentive for Argentarii representatives to recommend these services. Argentarii always seeks to act in the best interest of the client, including when recommending additional services Argentarii Legacy Planning Services, LLC. You are under no obligation to implement any additional services suggested. Argentarii Private Capital, LLC, WBR Holdings, LLC, and RSC Holdings, LLC. Argentarii owns and controls Argentarii Private Capital, LLC,WBR Holdings, LLC, and RSC Holdings, LLC. These entities are affiliated with the management and sponsorship of pooled investment vehicles. Argentarii serves as the advisor to these investment vehicles. Argentarii may recommend these investment vehicles to firm clients. This creates a conflict of interest as the firm may benefit financially from these recommendations. Argentarii addresses the potential conflict by disclosing it to clients and by implementing policies and procedures designed to ensure Argentarii’s investment advice is in the best interest of clients, as well as consistent with each client’s investment goals. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Argentarii has an affirmative duty of care, loyalty, honesty, and good faith to act in the best interest of its clients. A conflict of interest may arise if a person’s personal interest interferes, or appears to interfere, with the interests of Argentarii or its clients. A conflict of interest can arise whenever a person takes action or has an interest that makes it difficult for him or her to perform his or her duties and responsibilities for Argentarii honestly, objectively, and effectively. In accordance with applicable rules and regulations, the Firm has adopted a code of ethics to: • Set forth standards of conduct expected of all supervised persons (including compliance with federal securities laws); • Safeguard material non-public information about client transactions; and • Require “access persons” to report their personal securities transactions. In addition, the activities of an investment adviser and its personnel must comply with the broad antifraud provisions of Section 206 of the Advisers Act. Clients may obtain a copy of our Code of Ethics by contacting us at the telephone number on the cover 16 page of this Brochure. Item 12 Brokerage Practices Your assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. In recognition of the value of the services the Custodian provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Argentarii seeks to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, the most favorable compared to other available providers and their services. We consider several factors, including: • Capability to buy and sell securities for your account itself or to facilitate such services. • The likelihood that your trades will be executed. • Availability of investment research and tools. • Overall quality of services. • Competitiveness of price. • Reputation, financial strength, and stability. • Existing relationship with our firm and our other clients. Argentarii recommends the brokerage services of Goldman Sachs. Research and Other Soft Dollar Benefits As a registered investment adviser, Argentarii has access to the institutional platform of your account custodian. The Firm also has access to research products and services from your account custodian and/or other brokerage firms. These products may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of Argentarii’s investment decision-making responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. Brokerage for Client Referrals Argentarii does not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Directed Brokerage Argentarii does not allow clients to direct brokerage. Block Trades When possible, the firm combines multiple orders for shares of the same securities purchased for discretionary advisory accounts we manage (this practice is commonly referred to as "block trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. Generally, accounts will pay a fixed transaction cost regardless of the number of shares transacted. In certain cases, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs on any given day. If you participate in our wrap fee program described above, you will not pay any portion of the transaction costs in addition to the program fee. In the event an order is only partially filled, the shares will be allocated to participating accounts in a fair and equitable manner, typically in proportion to the size of each client's order. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. 17 We do not block trade for non-discretionary accounts. Accordingly, non-discretionary accounts may pay different costs than discretionary accounts pay. If you enter into non-discretionary arrangements with our firm, we may not be able to buy and sell the same quantities of securities for you and as a result you may pay higher commissions, fees, and/or transaction costs than clients who enter into discretionary arrangements with our firm. Item 13 Review of Accounts Your financial professional will monitor your accounts on an ongoing basis and will conduct account reviews at least annually or upon client request, to ensure the advisory services provided to you are consistent with your investment needs and objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to: • contributions and withdrawals, • year-end tax planning, • market moving events, • security specific events, and/or, • changes in your risk/return objectives. Written reports will be provided upon your request. These may contain relevant account and/or market- related information such as an inventory of account holdings and account performance, etc. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). Item 14 Client Referrals and Other Compensation Argentarii may engage independent referral partners to introduce prospective clients to the firm. When a client is referred by such a partner, this relationship will be disclosed to the client at the time of introduction. In certain cases, the referral partner may receive a portion of the advisory fees earned from the referred client’s managed assets. These referral arrangements are governed by SEC Rule 206(4)-1 under the Investment Advisers Act of 1940. Argentarii does not charge clients referred through these arrangements fees or expenses in excess of those charged to clients who engage the firm directly. The Chief Compliance Officer maintains records of all compensation paid in connection with such referral relationships. Item 15 Custody As paying agent for Argentarii, your independent custodian will directly debit your account(s) for the payment of advisory fees. This ability to deduct advisory fees from your accounts causes the Firm to exercise limited custody over your funds or securities. Argentarii does not have physical custody of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other qualified custodian. You will receive account statements from the qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) indicate the amount of advisory fees deducted from your accounts each billing period. You should carefully review account statements for accuracy. Item 16 Investment Discretion Before securities can be bought or sold on your behalf, you must first sign the Firm’s discretionary management agreement and the appropriate trading authorization forms. If you enter into non-discretionary arrangements with the Firm, your approval will be obtained prior to the execution of any transactions for your accounts. You have an unrestricted right to decline to implement any advice provided by the Firm on a non-discretionary basis. 18 Item 17 Voting Client Securities As a policy and in accordance with Argentarii's investment advisory agreement, Argentarii does not vote proxies related to securities held in client accounts. Item 18 Financial Information Argentarii does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. The Firm does not take physical custody of client funds or securities, or serve as trustee or signatory for client accounts, and does not require the prepayment of more than $1,200 in fees six or more months in advance. Therefore, Argentarii is not required to include a financial statement with this brochure. Argentarii has never filed a bankruptcy petition. 19 Rev. June 2024 PRIVACY POLICY FACTS Why? WHAT DOES ARGENTARII, LLC DO WITH YOUR FINANCIAL INFORMATION? Financial companies choose how they share your personal information. Federal law gives consumers the right to limit some but not all sharing. Federal law also requires us to tell you how we collect, share, and protect your personal information. Please read this notice carefully to understand what we do. What? The types of personal information we collect and share depends on the product or service you have with us. This information can include:  Social Security number and income  Account balances and assets  Transaction history How? All financial companies need to share customers’ personal information to run their everyday business. In the section below, we list the reasons financial companies can share their customers’ personal information; the reasons we choose to share, and whether you can limit this sharing. Can you limit this sharing? Reasons we can share your personal information Does Argentarii, LLC share? Yes No For our everyday business purposes – such as to process your transactions, maintain your account(s), respond to court orders and legal investigations, or report to credit bureaus Yes No For our marketing purposes – to offer our products and services to you No Yes For joint marketing with other financial companies Yes No For our affiliates’ everyday business purposes – information about your transactions and experiences No Not Applicable For our affiliates’ everyday business purposes – information about your creditworthiness No Not Applicable For our affiliates to market to you For nonaffiliates to market to you No Not Applicable No No For non-affiliates to satisfy their regulatory oversight obligations – information about you, your account, transactions, and experiences Call our offices at 513.488.1600 Questions? Argentarii, LLC Who we are Who is providing this notice? What we do How does Argentarii, LLC protect my personal information? To protect your personal information from unauthorized access and use, we use security measures that comply with federal law. These measures include computer safeguards and secured files and building. We collect your personal information, for example, when you: How does Argentarii, LLC collect my personal information?  Open an account  Deposit money  Seek advice about your investments  Enter into an investment advisory contract  Tell us about your investment or retirement portfolio or earnings We also collect your personal information from other companies. Definitions Affiliates Companies related by common ownership and control. They can be financial and non-financial companies. Nonaffiliates Companies not related by common ownership and control. They can be financial or non-financial companies. Joint marketing A formal agreement between nonaffiliated financial companies that together market financial products or service to you.