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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
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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:
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Item 6: Updated to add performance based fees for private placement offerings.
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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.
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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
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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.
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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.
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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
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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)
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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
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(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;
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• 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.
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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,
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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
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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.
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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
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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.
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• 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.
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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.
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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.
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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.
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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.