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Ark Advisors, LLC
Firm Brochure - Form ADV Part 2A
This brochure provides information about the qualifications and business practices of Ark Advisors, LLC. If
you have any questions about the contents of this brochure, please contact Patrick Vance, Chief Compliance
Officer, via email at patrick@arkadvisorsllc.com or at (309) 661-2000. The information in this brochure has
not been approved or verified by the United States Securities and Exchange Commission or by any state
securities authority.
Additional information about Ark Advisors, LLC is also available on the SEC’s website at
www.adviserinfo.sec.gov. Ark Advisors, LLC’s CRD number is: 167456.
205 N Williamsburg Drive, Suite E
Bloomington, Illinois, 61704
(309) 661-2000
patrick@arkadvisorsllc.com
Registration does not imply a certain level of skill or training.
Version Date: January 2026
Item 2: Material Changes
This Brochure is amended and prepared pursuant to the SEC’s requirements and rules. This
Brochure contains material changes in content from our last annual amendment disclosure
document dated January 1, 2025, and provides new and updated information in plain simple
English. Ark Advisors, LLC has the following material changes to disclose:
•
Item 12 – Ark Advisors uses Wells Fargo Clearing Services for custody and trade
execution services. Ark Advisors no longer uses Charles Schwab & Co., Inc. See Item 12
for the additional custodians Ark Advisors utilizes.
______________________________________________________________________________________________________
This Brochure is required to be delivered to you 48 hours before or at the time you hire us, as
well as offered OR delivered to our existing clients on an annual basis, but not later than 120
days after the close of our fiscal year-end.
When there are material changes in our business activities or key personnel, this Brochure will
be updated and automatically delivered to you; if there are only minor changes and no material
changes to this Brochure, we will offer it to you annually. The annual offer or delivery upon
your request is free of charge.
If you misplace this Brochure, contact us at (309) 661-2000 and another will be provided at no
cost.
i
Item 3: Table of Contents
Item 2: Material Changes .................................................................................................................................................. i
Item 3: Table of Contents ................................................................................................................................................. ii
Item 4: Advisory Business ................................................................................................................................................ 1
A. Description of the Advisory Firm ......................................................................................................................................... 1
B. Types of Advisory Services ................................................................................................................................................... 1
Financial Planning ............................................................................................................................................................... 2
Retirement Plan (401k) Services ......................................................................................................................................... 2
ERISA Rollovers and Transfers PTE 2020-02 ........................................................................................................................ 4
Services Limited to Specific Types of Investments .............................................................................................................. 5
C. Client Tailored Services and Client Imposed Restrictions ..................................................................................................... 5
D. Wrap Fee Programs ............................................................................................................................................................ 6
E. Amounts Under Management ............................................................................................................................................. 6
Item 5: Fees and Compensation ....................................................................................................................................... 6
A. Fee Schedule ........................................................................................................................................................................ 6
Investment Supervisory Services Fees ................................................................................................................................ 6
Financial Planning Fees ....................................................................................................................................................... 7
Retirement Plan (401k) Fees ............................................................................................................................................... 7
B. Payment of Fees .................................................................................................................................................................. 8
Payment of Investment Supervisory Fees ........................................................................................................................... 9
Payment of Financial Planning Fees .................................................................................................................................... 9
Payment of Retirement Plan Fees ....................................................................................................................................... 9
C. Clients Are Responsible For Third Party Fees ....................................................................................................................... 9
D. Prepayment of Fees ........................................................................................................................................................... 10
E. Outside Compensation for the Sale of Securities to Clients ............................................................................................... 10
Item 6: Performance-Based Fees and Side-By-Side Management .................................................................................... 11
Item 7: Types of Clients .................................................................................................................................................. 11
Minimum Account Size ..................................................................................................................................................... 11
Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ........................................................... 11
A. Methods of Analysis and Investment Strategies ........................................................................................................... 11
Methods of Analysis .......................................................................................................................................................... 12
Investment Strategies ....................................................................................................................................................... 12
B. Material Risks Involved ................................................................................................................................................. 12
Methods of Analysis .......................................................................................................................................................... 12
Fundamental Analysis ....................................................................................................................................................... 13
Investment Strategies ....................................................................................................................................................... 13
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C.
Risks of Specific Securities Utilized ................................................................................................................................ 14
Item 9: Disciplinary Information ..................................................................................................................................... 15
A.
Criminal or Civil Actions ................................................................................................................................................ 15
B. Administrative Proceedings .......................................................................................................................................... 15
C.
Self-regulatory Organization (SRO) Proceedings .......................................................................................................... 15
Item 10: Other Financial Industry Activities and Affiliations ............................................................................................ 15
A.
Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ........ 15
B.
Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ............................... 16
C.
Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ....................... 16
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................... 16
A.
Code of Ethics ............................................................................................................................................................... 16
B.
Recommendations Involving Material Financial Interests ............................................................................................ 17
C.
Investing Personal Money in the Same Securities as Clients ......................................................................................... 17
D.
Trading Securities At/Around the Same Time as Clients’ Securities.............................................................................. 18
Item 12: Brokerage Practices .......................................................................................................................................... 19
A.
1.
2.
3.
Factors Used to Select Custodians and/or Broker/Dealers ........................................................................................... 19
Research and Other Soft-Dollar Benefits ................................................................................................................. 20
Brokerage for Client Referrals .................................................................................................................................. 20
Clients Directing Which Broker/Dealer/Custodian to Use ....................................................................................... 20
B. Aggregating (Block) Trading for Multiple Client Accounts ........................................................................................... 21
C.
Cybersecurity Practices and Data Protection ................................................................................................................ 21
Item 13: Reviews of Accounts ........................................................................................................................................ 22
A.
Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ............................................................... 22
B.
Factors That Will Trigger a Non-Periodic Review of Client Accounts ............................................................................ 22
C.
Content and Frequency of Regular Reports Provided to Clients ................................................................................... 23
Item 14: Client Referrals and Other Compensation ......................................................................................................... 23
A.
Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) 23
B.
Compensation to Non – Advisory Personnel for Client Referrals .................................................................................. 23
Item 15: Custody ........................................................................................................................................................... 23
Item 16: Investment Discretion ...................................................................................................................................... 24
Item 17: Voting Client Securities (Proxy Voting) ............................................................................................................. 25
Item 18: Financial Information ....................................................................................................................................... 25
A.
Balance Sheet ............................................................................................................................................................... 25
iii
B.
Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ..................... 25
C.
Bankruptcy Petitions in Previous Ten Years .................................................................................................................. 25
Item 19: Requirements For SEC-Registered Advisers ............................................................... Error! Bookmark not defined.
Principal Executive Officers and Management Persons; Their Formal Education and Business Background ......... Error!
A.
Bookmark not defined.
B. Other Businesses in Which This Advisory Firm or its Personnel are Engaged and Time Spent on Those (If Any) ... Error!
Bookmark not defined.
C. How Performance-based Fees are Calculated and Degree of Risk to Clients ................... Error! Bookmark not defined.
D. Material Disciplinary Disclosures for Management Persons of this Firm ......................... Error! Bookmark not defined.
E. Material Relationships That Management Persons Have With Issuers of Securities (If Any) ......... Error! Bookmark not
defined.
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Item 4: Advisory Business
A. Description of the Advisory Firm
Ark Advisors, LLC is a Limited Liability Company organized in the state of Illinois. The
firm was formed in March of 2013, and the principal owners are Patrick Andrew Vance
and Brad Richard Metz. Ark operates under the fiduciary obligations set forth in the
Investment Advisers Act of 1940.
Ark filed its initial application to become registered as in investment adviser with the U.S.
Securities and Exchange Commission in January 2025, which was accepted on February
10, 2025.
B. Types of Advisory Services
Ark Advisors, LLC (hereinafter “Ark”) offers the following services to advisory clients:
Ark Advisors, LLC offers ongoing portfolio management services tailored to the
individual goals, objectives, time horizon, and risk tolerance of each client. As a fiduciary
under the Investment Advisers Act of 1940, Ark is legally obligated to act in the best
interest of its clients and provide investment advice free from conflicts of interest. All
recommendations and actions are designed to align with the client’s stated objectives
and risk profiles.
Ark creates a personalized Investment Policy Statement (IPS) for each client, which
outlines the client’s current financial situation—including income, goals, investment
experience, tax levels, and risk tolerance—and uses this information to guide the
selection of a portfolio suited to the client’s specific needs. Investment Supervisory
Services include, but are not limited to, the following:
Investment strategy
•
• Personal investment policy
• Asset allocation
• Asset selection
• Risk tolerance
• Regular portfolio monitoring
Ark evaluates the current investments of each client in relation to their financial goals,
time horizon, other financial assets, and risk tolerance. Ark requests discretionary
authority from clients to select securities and execute transactions without obtaining
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prior approval from the client before each transaction. Risk tolerance levels are
documented in the IPS, which is provided to each client.
Client accounts are monitored on an ongoing basis, and reviews are conducted at least
quarterly. During these reviews, accounts are evaluated for consistency with the stated
investment objectives and risk tolerance.
Financial Planning
Financial planning services provided by Ark Advisors, LLC may include, but are not
limited to, investment planning, insurance planning, retirement planning, college
planning, cash flow planning, tax planning related to brokerage and retirement accounts,
and high-level estate planning.
For tax and estate planning matters, we emphasize that Ark is not a tax professional or
an attorney, and clients are encouraged to consult with qualified tax professionals or
legal advisors for specific advice in these areas.
These financial planning services are provided on a fixed-fee basis, and the final fee
structure is documented in Exhibit II of the Financial Planning Agreement.
Retirement Plan (401k) Services
Ark Advisors, LLC offers retirement plan services to both retirement plan sponsors
and individual participants. For corporate sponsors, our retirement plan services may
include, but are not limited to, the following fiduciary consulting services:
Fiduciary Consulting Services
•
Investment Policy Statement Preparation: Ark assists clients in developing an
investment policy statement (IPS), which outlines the investment objectives and
policies for the Plan. Clients retain ultimate responsibility for adopting and
amending the IPS.
•
•
• Non-Discretionary Investment Advice: Ark provides general, non-discretionary
investment advice regarding asset classes and investment options, consistent
with the Plan’s IPS.
Investment Selection Services: Ark recommends investment options in
alignment with ERISA section 404(c).
Investment Due Diligence Review: Ark conducts periodic due diligence reviews
of the Plan’s investment options and provides recommendations.
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•
Investment Monitoring: Ark assists in monitoring investment performance and
fund management, providing periodic reports and making recommendations
regarding the retention or removal of investment options.
•
• Default Investment Alternative Advice: Ark provides non-discretionary advice
to assist clients in developing Qualified Default Investment Alternatives (QDIA)
for participants who are automatically enrolled or fail to make an election.
Individualized Participant Advice: Upon request, Ark offers one-on-one advice
to Plan participants regarding their individual financial situations.
Fiduciary Consulting Services are non-discretionary, and the retirement plan sponsor
or participant is responsible for approving and implementing any recommendations
made by Ark. Ark does not serve as the administrator or trustee of the plan, nor does
it have custody of client assets, except for fee deductions as authorized in writing by
the client.
In providing Fiduciary Consulting Services, Ark acts as a fiduciary under ERISA
Section 3(21)(A)(ii), but Ark does not exercise discretionary authority over plan
management, asset disposition, or plan administration, nor does it serve as an ERISA
investment manager or plan administrator.
Non-Fiduciary Services
While Ark is a fiduciary under the Investment Advisers Act of 1940, the following
services are provided as non-fiduciary consulting under ERISA:
• Participant Education: Ark offers general education on investment principles
and the Plan’s investment alternatives. These educational services comply with
DOL Interpretive Bulletin 96-1 and do not involve personalized
recommendations.
• Participant Enrollment: Ark assists with group enrollment meetings aimed at
increasing employee participation and understanding of the retirement plan.
• Qualified Plan Development: Ark helps clients establish a qualified plan,
including assisting with the selection of a Third-Party Administrator (TPA) if
needed.
• Due Diligence Review: Ark provides periodic reviews of the Plan’s fees,
expenses, and service providers.
Ark may also meet with individual participants to discuss their risk tolerance, time
frames, and investment choices. However, participants are responsible for
implementing transactions in their own accounts.
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Ark will disclose any required information in accordance with ERISA Regulation
Sections 2550.408b-2(c) and 2550.408b-2(c)(vi)(A), including any changes to
compensation or fees as applicable.
ERISA Rollovers and Transfers PTE 2020-02
When Ark provides investment advice regarding your retirement plan account or
individual retirement account (“IRA”), including whether to maintain investments or
proceed with a rollover from a retirement plan account to an IRA, we acknowledge that
Ark is a “fiduciary” under Title I of the Employee Retirement Income Security Act
(“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable.
Because Ark earns advisory fees for managing IRA accounts, we recognize that this
creates potential conflicts of interest. Ark operates under a special rule that requires us
to act in your best interest and not put our interests ahead of yours.
Under this special rule’s provisions, Ark must act as a fiduciary to a retirement plan
account or IRA under ERISA/IRC:
•
Meet a professional standard of care when making investment recommendations
(e.g., give prudent advice);
•
Never put the financial interests of Ark ahead of you when making
recommendations (e.g., give loyal advice);
•
Avoid misleading statements about conflicts of interest, fees, and investments;
•
Follow policies and procedures designed to ensure that Ark gives advice that is in
your best interest;
•
Charge no more than is reasonable for the services of Ark; and
•
Give Client basic information about conflicts of interest.
To manage this conflict of interest, Ark has adopted policies and procedures that ensure:
• Our investment adviser representatives will act in a fiduciary capacity, providing
advice that prioritizes your best interest.
• They will not recommend investments that result in unreasonable compensation for
Ark related to a rollover.
• Any compensation received by Ark or its representatives will be disclosed to you,
including any conflicts of interest associated with a rollover recommendation.
When offering advice about your retirement plan or IRA, our representatives will act with
the care, skill, prudence, and diligence required, based on your investment objectives,
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financial circumstances, risk tolerance, and overall needs—without regard to Ark’s
financial interests or those of its affiliated personnel.
Services Limited to Specific Types of Investments
Ark generally limits its investment advice and/or money management services to the
following types of investments: mutual funds, equities, bonds, fixed income securities,
debt securities, exchange-traded funds (ETFs), real estate investment trusts (REITs), and
insurance products, including annuities. Additionally, Ark may incorporate other
securities to diversify a portfolio when deemed appropriate.
Ark also provides ongoing advisory services for clients with 529 college savings plans. In
these cases, Ark reviews your financial situation, goals, and objectives, along with the
investment options available within the 529 plan. At agreed-upon intervals, Ark will
review your 529 plan account and make recommendations from the available investment
options that align with your investment objectives and risk tolerance.
Please note that 529 college savings plans limit the frequency with which account owners
can reallocate assets within the plan. These services are provided as part of Ark's
Investment Supervisory Services and/or Financial Planning Services at no additional
charge. Ark may have investment discretion or trading authority over your 529 plan
account as outlined in your advisory agreement with Ark.
C. Client Tailored Services and Client Imposed Restrictions
Ark Advisors, LLC offers tailored investment services based on each client’s financial goals, risk
tolerance, and time horizon. We construct personalized financial plans and investment strategies
to meet the unique needs of each client, as documented in their Investment Policy Statement
(IPS).
While we strive to accommodate reasonable client preferences, we do not accept restrictions that
conflict with our investment philosophy, fiduciary obligations, or ability to act in the client’s best
interest. For example, we generally do not accept mandates that preclude investment in specific
securities or asset classes based on individual values or beliefs.
Clients who seek to impose restrictions of this nature may not be a good fit for our firm. We
reserve the right to decline such engagements to ensure we can consistently deliver services
aligned with our investment principles and fiduciary standards.
This policy allows us to maintain the integrity of our advisory services while upholding our
fiduciary duty to clients who align with our approach.
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D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee
that includes management fees, transaction costs, fund expenses, and any other
administrative fees.
Ark does not offer or participate in any wrap fee programs, where one consolidated fee
covers all services, including portfolio management and transaction costs. Instead,
clients are charged advisory fees separately from transaction and custodial costs,
ensuring transparency in billing.
E. Amounts Under Management
Ark Advisors, LLC has $179,142,310 in discretionary assets under management and
$16,497,500 in non-discretionary assets under management for a total of $195,639,810 in
assets under management as of 12/10/2025.
Item 5: Fees and Compensation
A. Fee Schedule
Investment Supervisory Services Fees
Total AUM < $250,000
Annual Fee
$0-250,000
1.50%
Total Assets Under Management
Annual Fee
First $1,000,000
1.00%
$1,000,001 - $3,000,000
0.50%
Above $3,000,001
0.25%
Ark Advisors charges an asset-based fee for investment advisory services, which ranges
from 0.25% to 1.50% annually, depending on the total assets under management and
the complexity of the client’s financial situation. Fees are negotiable based on specific
client needs, the scope of services provided, and the account size.
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The final fee schedule is attached as Exhibit I of the Investment Advisory Contract. Fees
are paid monthly or quarterly in arrears depending on the custodian, and clients may
terminate their contracts with written notice. Because fees are charged in arrears, no
refund policy is necessary. Clients may terminate their accounts without penalty within 5
business days of signing the advisory contract. Advisory fees are withdrawn directly from
the client’s accounts with client written authorization.
EXAMPLE: For example, a client with $500,000 in assets under management would pay
an annual fee of $5,000 (1.0% of AUM) for investment supervisory services.
Financial Planning Fees
Financial planning services are offered on a fixed-fee basis, with fees ranging from $500
to $20,000. The final fee is determined by the complexity of the client’s financial situation,
the breadth of the planning requested, and the time required to prepare the plan. Clients
will receive a customized quote prior to engaging these services.
Fees are paid in advance, but never more than six months in advance. Fees that are
charged in advance will be refunded based on the prorated amount of work completed at
the point of termination. The fees are negotiable, and the final fee schedule will be
attached as Exhibit I of the Financial Planning Agreement. Clients may terminate their
contracts without penalty within five business days of signing the advisory contract.
Retirement Plan (401k) Fees
Total Assets Under Management
Annual Fee
First $1,500,000
0.75%
$1,500,001 - $3,000,000
0.50%
$3,000,001 - $10,000,000
0.25%
$10,000,001+
0.10%
Ark Advisors charges an asset-based fee for retirement plan services, which ranges from
0.10% to 0.75% annually, depending on the total assets under management in plan as of
June 30th of the previous year. Fees are negotiable based on specific client needs, the
scope of services provided, and the account size.
The final fee schedule is attached as Exhibit I of the Retirement Plan Services Agreement.
Fees are paid monthly or quarterly in arrears depending on the custodian, and clients
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may terminate their contracts with written notice. Because fees are charged in arrears, no
refund policy is necessary. Clients may terminate their accounts without penalty within 5
business days of signing the advisory contract. Advisory fees are withdrawn directly from
the participant accounts or can be paid directly by plan trustee. Plan trustees are also
responsible for all custodian fees, TPA expenses, and applicable 401k audit charges.
EXAMPLE: For example, a retirement plan with $1,000,000 in assets under management
would pay an annual fee of $7,500 (0.75% of AUM) for fiduciary and non-fiduciary
services outlined in Item 4B of Form ADV 2A.
Services Termination
Either party may terminate services by providing written notice of termination to the
other party. If services are terminated within five business days of signing the client
agreement, services are terminated without penalty.
No Other Compensation
Ark does not reasonably expect to receive any other compensation, direct or indirect, for
its services. If Ark receives any other compensation for such services, Ark will (i) offset
that compensation against our stated fees, and (ii) will disclose the amount of such
compensation, the services rendered for such compensation and the payer of such
compensation to client.
B. Payment of Fees
It is important to understand how third-party fees, combined with advisory fees, can
impact the overall performance of your portfolio. Ark Advisors works to minimize
these costs where possible, but they are ultimately determined by the providers.
Billing Frequency
Fee Type
Asset-Based Fee
Range
0.25%-1.50% annually Monthly or Quarterly
Fixed Fee
Asset-Based Fee
$500-$20,000
0.10%-0.75%
Service
Investment
Supervisory
Financial Planning
Retirement Plan
Services
in Arrears
In Advance
Monthly or Quarterly
in Arrears
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Payment of Investment Supervisory Fees
Investment Supervisory fees are withdrawn by default directly from the client’s accounts
with client written authorization. Fees are paid monthly or quarterly in arrears depending
on custodian practices and technology.
Investment Supervisory fees may also be invoiced and billed directly to the client
monthly in arrears. Clients may select the method in which they are billed.
Investment Supervisory Fees are charged in arrears, so no refund policy is necessary for
these fee processes.
Payment of Financial Planning Fees
Fixed Financial Planning fees are paid via check in advance, but never more than six
months in advance.
Fixed financial planning fees, if paid in advance, will be refunded based on the prorated
amount of work completed at the time of termination. Refunds are typically issued
within 14 days via check.
Payment of Retirement Plan Fees
Retirement Plan Fees are withdrawn by default directly from the participant accounts
with plan trustee written authorization. Fees are paid monthly or quarterly in arrears
depending on custodian practices and technology.
Retirement Plan Fees may also be invoiced and billed directly to the client monthly in
arrears. Clients may select the method in which they are billed.
Retirement Plan Fees are charged in arrears, so no refund policy is necessary for these
fee processes.
C. Clients Are Responsible For Third Party Fees
Clients are responsible for the payment of all third-party fees, including but not limited
to custodial fees, TPA fees, audit fees, brokerage fees, mutual fund or ETF expenses,
account fees, and transaction fees. These fees are separate from the advisory fees
charged by Ark Advisors.
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D. Prepayment of Fees
Ark collects fees in advance and in arrears. Fixed financial planning fees that are collected
in advance will be refunded based on the prorated amount of work completed at the
point of termination. Fees will be returned within fourteen days to the client via mailed
check.
Ark ensures compliance with SEC rules by limiting prepayment of fees to no more than
$500 six months in advance. Clients will receive clear documentation of any prepayment
amounts and the associated refund calculation in the event of early termination.
E. Outside Compensation for the Sale of Securities to Clients
Certain representatives of Ark Advisors, LLC, including Patrick Andrew Vance and Brad
Richard Metz, are also licensed insurance agents. In their capacity as insurance agents,
these individuals may receive commission-based compensation for the sale of insurance
products to Ark Advisors' clients.
Potential Conflicts of Interest
The receipt of commissions creates a potential conflict of interest, as representatives may
have an incentive to recommend insurance products based on compensation rather than
the client’s specific needs. Ark Advisors addresses this conflict by:
1. Disclosure: Fully informing clients about any compensation arrangements related to
the recommendation of insurance products.
2. Prioritization of Client Interests: Ensuring that all recommendations are based on
the client’s best interests, regardless of any commissions received.
3. Monitoring: Implementing internal policies to document the rationale for any
insurance recommendations, which are subject to compliance oversight.
Client Flexibility
Clients are under no obligation to purchase insurance products through representatives
of Ark Advisors. They are encouraged to consider alternatives and may purchase these
products through other licensed agents or providers if they prefer.
Primary Source of Compensation
Ark Advisors’ primary source of compensation is advisory fees. Any commissions received
from the sale of insurance products are ancillary and do not offset or reduce the advisory
fees charged to clients.
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By maintaining a clear separation between advisory services and insurance sales, Ark
Advisors upholds its fiduciary obligation to act in the best interest of its clients.
Item 6: Performance-Based Fees and Side-By-Side
Management
Ark does not accept performance-based fees or other fees based on a share of capital
gains or capital appreciation of the assets of a client.
Item 7: Types of Clients
Ark generally provides investment advice and/or management supervisory services to
the following types of clients:
•
Individuals - Refers to natural persons who seek investment advice or
management services to meet personal financial goals. These clients may have
varied levels of investable assets and financial sophistication.
• High-Net-Worth Individuals - Defined under SEC rules as individuals or couples
with a net worth exceeding $2.2 million (excluding the value of their primary
residence) or those clients wit over $1.1 million in AUM with Ark Advisors.
• Pension and Profit Sharing Plans - These include employer-sponsored
retirement plans that are designed to provide retirement income or deferred
compensation to participants. Examples include defined benefit plans, 401(k)s,
and other profit-sharing arrangements.
• Charitable Organizations - Nonprofit entities established under Internal
Revenue Code Section 501(c)(3) or similar provisions. These organizations
operate for charitable, educational, religious, or other public service purposes and
may require investment management for endowments, operating reserves, or
other funds.
Minimum Account Size
There is no account minimum.
Item 8: Methods of Analysis, Investment Strategies, and
Risk of Investment Loss
A. Methods of Analysis and Investment Strategies
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Methods of Analysis
Fundamental Analysis - Fundamental analysis involves evaluating economic, financial,
and qualitative factors to assess the intrinsic value of a security. This method examines
key aspects such as a company’s financial statements, management, industry position,
and economic conditions to determine its potential for growth, earnings, or risk. The
goal is to identify securities that are undervalued or overvalued relative to their current
market price. Fundamental analysis typically focuses on long-term investment
opportunities.
Investment Strategies
Our firm employs a variety of investment strategies tailored to meet the individual goals, risk
tolerance, and time horizon of each client. Common strategies include:
•
•
Long-Term Purchases: Acquiring securities with the expectation of holding them for an
extended period, typically over a year, to capitalize on growth or income potential.
Short-Term Purchases: Acquiring securities with the intent to sell them within a relatively
short period, usually less than a year, to take advantage of market conditions.
• Asset Allocation: Diversifying investments across asset classes, such as equities, fixed income,
•
and alternative investments, to balance risk and return.
Income-Oriented Investing: Focusing on securities that provide regular income, such as
dividend-paying stocks or bonds.
• Growth Investing: Targeting investments with potential for significant capital appreciation,
often involving higher risk.
• Value Investing: Identifying undervalued securities based on intrinsic value assessments, with
the expectation of market correction over time.
Each strategy is implemented based on the client’s individual financial situation, goals, and
preferences.
Risk of Loss Disclaimer
Investing in securities involves a risk of loss, including the potential loss of principal, that
clients should be prepared to bear. The value of investments may fluctuate due to various
factors, including changes in market conditions, economic factors, and individual security
performance. While we aim to manage and mitigate risks through diversified strategies
and tailored investment approaches, there is no guarantee that any investment strategy
will achieve its intended goals or prevent losses.
B. Material Risks Involved
Methods of Analysis
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Fundamental Analysis - The primary risk of using fundamental analysis is that the data and
assumptions on which the analysis is based may be incorrect or incomplete. Even if the
analysis accurately assesses a security’s intrinsic value, external factors such as market
regulatory changes, or unexpected economic
sentiment, geopolitical events,
developments may affect the performance of the security. Additionally, fundamental
analysis often involves long-term projections, which can be disrupted by unforeseen
circumstances, making short-term price movements unpredictable. As a result,
investments based on fundamental analysis may not perform as expected, potentially
leading to financial losses.
Investment Strategies
•
•
Long-Term Purchases: The risk of holding investments for extended periods is that market
conditions, economic factors, or company performance may change,
leading to
underperformance or losses. There may also be periods of volatility, and investments may not
appreciate as expected, potentially resulting in missed opportunities in more favorable
markets.
Short-Term Purchases: Investments made with the intent to sell in the short term are subject
to higher volatility and market fluctuations. There is the risk that short-term price movements
may not align with expectations, leading to losses or reduced returns. Timing the market
accurately can be difficult, and unexpected events can cause significant price swings.
•
• Asset Allocation: While diversification can reduce risk, it does not guarantee profit or protect
against loss. Some asset classes may underperform during certain market conditions, which
could negatively affect the overall portfolio. Additionally, an asset allocation strategy may not
always be properly adjusted to reflect changes in market conditions or a client’s goals.
Income-Oriented Investing: Investments focused on generating income, such as dividend-
paying stocks or bonds, may be impacted by changes in interest rates, credit risk, or the
financial health of the issuing companies. There is a risk of reduced income or loss of principal,
particularly if the issuer defaults or the income-generating assets perform poorly.
• Growth Investing: Growth investments typically involve higher risk as they focus on
companies with the potential for significant capital appreciation. However, these companies
may not meet growth expectations, leading to high volatility and potential loss of value.
Additionally, growth investments may be more susceptible to market fluctuations and
economic cycles.
• Value Investing: Value investing carries the risk that a security may remain undervalued for
an extended period, or the market may not recognize its intrinsic value, leading to
underperformance. The company may face unforeseen challenges, or broader market trends
may prevent the stock price from recovering as expected.
These risks are inherent in each strategy and must be carefully considered relative to the client's
investment goals, risk tolerance, and time horizon.
Risk of Loss Disclaimer
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Investing in securities involves a risk of loss, including the potential loss of principal, that
clients should be prepared to bear. The value of investments may fluctuate due to various
factors, including changes in market conditions, economic factors, and individual security
performance. While we aim to manage and mitigate risks through diversified strategies
and tailored investment approaches, there is no guarantee that any investment strategy
will achieve its intended goals or prevent losses.
C. Risks of Specific Securities Utilized
Different types of securities carry unique risks that may impact the performance of your
investment portfolio. The following outlines some of the specific risks associated with the
securities that may be utilized in your investment strategy:
• Equities (Stocks): The value of stocks can be highly volatile and subject to market risk,
economic conditions, company performance, and investor sentiment. Stock prices
can fluctuate significantly in response to changes in the broader market or specific
company circumstances, potentially resulting in a loss of principal.
• Bonds (Fixed-Income Securities): Bonds are subject to interest rate risk, meaning their
value may decline if interest rates rise. Additionally, bonds may carry credit risk if the
issuer is unable to meet its debt obligations. Long-term bonds are typically more
sensitive to interest rate changes, while lower-quality bonds (high-yield or junk
bonds) carry greater credit risk.
• Mutual Funds and Exchange-Traded Funds (ETFs): These pooled investment vehicles
carry the risks of the underlying securities in the fund. Additionally, mutual funds and
ETFs may experience liquidity risks, management risks, and may be subject to fees
that reduce returns. ETFs can also be impacted by market fluctuations similar to
individual stocks.
• Derivatives (Options, Futures, etc.): Derivatives are complex financial instruments that
derive their value from the performance of an underlying asset. They carry significant
risk, including the potential for substantial losses, and can be highly volatile.
Derivatives may also involve leverage, increasing both the potential for profit and the
risk of loss.
• Real Estate Investments: Real estate investments are subject to market fluctuations,
interest rate changes, and economic conditions. Property values can decline, rental
income may be unpredictable, and liquidity may be limited, making it challenging to
sell assets quickly without incurring a loss.
• Foreign Securities: Investing in foreign securities carries additional risks, including
currency risk, geopolitical risk, and economic instability in foreign markets. The value
of foreign investments can fluctuate due to changes in exchange rates or political
events.
• Alternative Investments: These may include investments in commodities, private
equity, hedge funds, or venture capital. Alternative investments can be illiquid, highly
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speculative, and subject to significant price swings. Due diligence is critical to
understanding the risks associated with these types of investments.
Each type of security may impact your portfolio differently based on your financial goals,
risk tolerance, and investment horizon. It is important to carefully consider these risks
before investing in any specific security.
Risk of Loss Disclaimer
Investing in securities involves a risk of loss, including the potential loss of principal, that
clients should be prepared to bear. The value of investments may fluctuate due to various
factors, including changes in market conditions, economic factors, and individual security
performance. While we aim to manage and mitigate risks through diversified strategies
and tailored investment approaches, there is no guarantee that any investment strategy
will achieve its intended goals or prevent losses.
Item 9: Disciplinary Information
Neither Ark Advisors, LLC nor its personnel have any legal or disciplinary history material to a
client’s evaluation of the firm or its advisory services.
A. Criminal or Civil Actions
There are no criminal or civil actions to report.
B. Administrative Proceedings
There are no administrative proceedings to report.
C. Self-regulatory Organization (SRO) Proceedings
There are no self-regulatory organization proceedings to report.
Item 10: Other Financial Industry Activities and
Affiliations
A. Registration as a Futures Commission Merchant, Commodity
Pool Operator, or a Commodity Trading Advisor
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Neither Ark nor its representatives are registered as or have pending applications to
become a Futures Commission Merchant, Commodity Pool Operator, or a Commodity
Trading Advisor.
B. Registration Relationships Material to this Advisory Business
and Possible Conflicts of Interests
Patrick Andrew Vance and Brad Richard Metz, both of whom are licensed insurance
agents, may from time to time offer clients advice or products in connection with their
insurance activities. Clients should be aware that these insurance-related services may
involve commission-based compensation, which creates a conflict of interest.
Commission-based products may be in conflict with the fiduciary duties of Ark Advisors,
LLC, as a registered investment adviser.
Despite this, Ark Advisors always acts in the best interest of the client, including in
connection with the sale of commissionable insurance products to advisory clients.
Clients are under no obligation to implement any plan or purchase products through any
investment adviser representative of Ark in their capacity as licensed insurance agents.
All insurance transactions are separate and distinct from the advisory services provided
by Ark Advisors, and clients are encouraged to consider alternative providers.
C. Selection of Other Advisers or Managers and How This
Adviser is Compensated for Those Selections
Ark Advisors, LLC does not utilize or select other advisers or third-party managers to
manage client assets. All client assets are managed directly by Ark Advisors'
management team. As a result, Ark does not receive any compensation for the selection
or recommendation of external advisers or managers.
Item 11: Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading
A. Code of Ethics
Ark Advisors, LLC has established a written Code of Ethics designed to promote ethical
conduct, integrity, and compliance with applicable laws and regulations. The Code of
Ethics covers, but is not limited to, the following areas:
Insider Trading
• Prohibited Purchases and Sales
•
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• Personal Securities Transactions
• Exempted Transactions
• Prohibited Activities
• Conflicts of Interest
• Gifts and Entertainment
• Confidentiality
• Service on a Board of Directors
• Compliance Procedures
• Compliance with Laws and Regulations
• Procedures for Reporting Violations
• Certification of Compliance
• Reporting Violations
• Compliance Officer Duties
• Training and Education
• Recordkeeping
• Annual Review
• Sanctions
Our Code of Ethics is available, free of charge, to any client or prospective client upon
request. It is designed to ensure that the actions of our personnel reflect the highest
ethical standards and safeguard the interests of our clients.
B. Recommendations Involving Material Financial
Interests
Ark Advisors, LLC does not recommend that clients buy or sell any security in which a
related person to Ark or Ark itself has a material financial interest. We are committed to
avoiding any conflicts of interest that could arise from such financial relationships and
ensure that all recommendations are made with the best interests of our clients in mind.
C. Investing Personal Money in the Same Securities as Clients
From time to time, representatives of Ark Advisors, LLC may buy or sell securities for
their personal accounts that they also recommend to clients. This creates the potential
for representatives to engage in transactions involving the same securities either before
or after recommending them to clients, which could result in personal profit derived
from client recommendations.
This situation presents a conflict of interest. To address this, Ark Advisors ensures that all
personal transactions that could be perceived as conflicts of interest are thoroughly
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documented. Additionally, Ark has implemented procedures to ensure that client
transactions are executed before any personal transactions involving similar securities.
D. Trading Securities At/Around the Same Time as Clients’
Securities
From time to time, representatives of Ark Advisors, LLC may buy or sell securities for
their personal accounts at or around the same time as they recommend these securities
to clients. This creates the potential for representatives to engage in personal
transactions before or after recommending the same securities to clients, potentially
resulting in personal profit from client recommendations.
This situation presents a conflict of interest. To mitigate this, Ark Advisors ensures that
client transactions are executed before any personal transactions involving similar
securities. Ark is committed to safeguarding client interests by adhering to this practice
and maintaining transparency in all transactions.
Conflict Mitigation Policies
1. Client Priority: Client transactions are always executed first. Representatives are
prohibited from executing personal trades in a security until all pending trades in the
same security have been completed.
2. Monitoring and Oversight: Ark Advisors maintains a comprehensive record of all
securities transactions made by representatives.
a. These records are reviewed regularly by the Chief Compliance Officer (CCO)
to ensure compliance with the firm’s policies and fiduciary obligations.
3. Trade Restrictions: Representatives are restricted from trading in securities where
they have material non-public information or where their transactions could result in
a conflict of interest.
4. Annual Certification: All representatives are required to annually certify their
compliance with the firm’s Code of Ethics, which includes these trading policies.
Transparency and Client Assurance
Ark Advisors is committed to maintaining transparency in all transactions and
safeguarding client interests. Clients may request a copy of the firm’s Code of Ethics,
which outlines the complete policies and procedures related to personal trading, at
any time.
By adhering to these policies, Ark Advisors ensures that all trading activities prioritize
client interests and align with our fiduciary obligations.
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Item 12: Brokerage Practices
A. Factors Used to Select Custodians and/or Broker/Dealers
Ark Advisors, LLC has established relationships with several qualified custodians to
ensure that client accounts are securely held and managed. The selection of a qualified
custodian for your account is based on the type of advisory services Ark provides to you.
Ark does not receive any compensation, either directly or indirectly, from any of the
qualified custodians used.
Each qualified custodian may charge separate fees for the custody services it provides,
and the terms and fees for such services will be outlined in the agreement between the
client and the custodian. Ark Advisors evaluates custodians based on factors such as
reliability, financial strength, cost-effectiveness, technology, and the level of service
provided to clients.
Current Custodians/Broker Dealers:
1. Trade-PMR, Inc., Member FINRA/SIPC
2. American Fund Distributors, Inc., Member FINRA/SIPC
a. DBA Capital Group
3. Nationwide Securities, LLC., Member FINRA/SIPC
4. Wells Fargo Clearing Services, Member FINRA/SIPC
Factors Used when selecting Custodians:
1. Security and Custody Services: The custodian should provide secure storage
and custody services for the firm’s clients’ assets, including stocks, bonds,
mutual funds, ETFs, and/or other financial instruments. Ark Advisors is
committed to seeking ‘best execution’ for client transactions, as defined by the
Investment Advisers Act of 1940. Best execution means obtaining the most
favorable terms reasonably available under the circumstances, considering
factors such as price, execution speed, transaction costs, and the financial
stability of the broker-dealer or custodian.
2. Financial Stability: The financial stability and reputation of the custodian.
3. Regulatory Compliance: The custodian must comply with relevant regulations.
This helps Ark maintain compliance with industry standards and protect our
clients’ interests.
4. Technology and Reporting Capabilities: The custodian’s technology platform
and reporting capabilities are important for seamless integration with Ark’s
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systems. Efficient reporting and technology support contribute to streamlined
operations.
5. Transaction Execution and Settlement: The ability of the custodian to execute
trades efficiently and settle transactions in a timely manner is crucial.
6. Costs and Fees: The fee structure of the custodian, including transaction costs
and custody fees, is a significant consideration.
9.
7. Range of Investment Options: The custodian should offer a broad range of
investment options, including various asset classes and investment vehicles.
8. Customer Service and Support: Responsive and reliable customer service is
essential. The custodian should provide support for any operational issues or
client inquiries promptly.
Integration with Portfolio Management Systems: Seamless integration with
Ark’s portfolio management systems is critical for efficient operations and
accurate reporting.
Ark will never charge a premium or commission on transactions, beyond the actual cost
imposed by the custodian.
1. Research and Other Soft-Dollar Benefits
Ark Advisors, LLC does not accept any "soft-dollar" benefits, including research, products,
or services provided by broker-dealers in exchange for client securities transactions. Ark
Advisors is committed to prioritizing best execution for all client trades, ensuring that trade
execution decisions are made in the best interests of our clients, free from any conflicts of
interest associated with soft-dollar arrangements.
2. Brokerage for Client Referrals
Ark Advisors, LLC does not receive any client referrals from broker-dealers or third parties
in exchange for using their services. We do not enter into any arrangements where referrals
are exchanged for the use of a particular broker-dealer or third party.
3. Clients Directing Which Broker/Dealer/Custodian to Use
Ark Advisors, LLC may require clients to use a specific broker-dealer or custodian to
execute transactions.
Ark conducts periodic reviews of its recommended custodians to ensure compliance with
best execution obligations. These reviews evaluate factors such as trade execution
quality, transaction costs, and the competitiveness of services offered. The results of
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these reviews are documented and serve as a basis for future recommendations to
ensure clients receive the best possible service.
B. Aggregating (Block) Trading for Multiple Client Accounts
Ark Advisors, LLC has the ability to aggregate (block) trades across multiple client
accounts. Block trading may benefit a large group of clients by allowing Ark to purchase
larger blocks of securities, which can result in reduced transaction costs for each client.
In cases where block trading is not utilized, the cost of executing individual transactions
may be higher, leading to potentially more expensive trades for clients. Ark aims to use
block trading in a way that maximizes efficiency and minimizes transaction costs,
ensuring that it serves the best interests of all clients involved.
C. Cybersecurity Practices and Data Protection
Ark Advisors, LLC is committed to safeguarding client data through comprehensive
cybersecurity measures. Our Information Security Policy is based on the National
Institute of Standards and Technology (NIST) Cybersecurity Framework, ensuring
alignment with industry best practices.
Key Elements of Our Cybersecurity Program
1. Risk Management:
o Regular risk assessments to identify, evaluate, and address vulnerabilities.
o Annual evaluations of non-public information, including Personally
Identifiable Information (PII), against confidentiality, integrity, and availability
standards.
2. Data Security and Encryption:
o Sensitive client data is encrypted during storage and transmission using
industry-standard protocols.
o Local storage of sensitive information is prohibited; data is stored in secure,
cloud-based environments.
3. Incident Response:
o A formal incident response plan is in place to promptly address cybersecurity
incidents, including containment, remediation, and client notifications where
applicable.
4. Access Controls and Authentication:
o Multi-factor authentication and role-based access controls are mandatory for
all systems accessing client data.
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o Regular audits ensure adherence to least-privilege principles, limiting access
to necessary data.
5. Training and Awareness:
o All personnel undergo annual cybersecurity training, including phishing
awareness and secure data handling practices.
6. Third-Party Management:
o All vendors and service providers are vetted to ensure they adhere to
stringent security practices.
7. Monitoring and Updates:
o Continuous monitoring for anomalies and vulnerabilities through antivirus
software, intrusion detection systems, and penetration testing.
8. Cybersecurity Insurance:
o Maintains cybersecurity insurance, including coverage for data incident
response and social engineering, ensuring financial preparedness in the event
of a breach.
Clients may request a copy of our full Information Security Policy for detailed
information. Despite all precautions, no system is immune to risk, and Ark Advisors
encourages clients to practice vigilance in protecting their own data.
Item 13: Reviews of Accounts
A. Frequency and Nature of Periodic Reviews and Who Makes
Those Reviews
Client accounts are reviewed at least quarterly by Patrick Andrew Vance and Brad Richard
Metz, Managing Members of Ark Advisors, LLC. As the chief advisors, Patrick Andrew
Vance and Brad Richard Metz are responsible for reviewing client accounts to ensure
alignment with clients' investment policies, risk tolerance levels, and overall goals. All
accounts at Ark are assigned to these reviewers for periodic evaluation.
For financial planning accounts, reviews occur upon the creation and delivery of the
financial plan. Patrick Andrew Vance and Brad Richard Metz conduct the comprehensive
review necessary for the development of the financial plan, and there is only one level of
review, which is the total review done during the plan creation process.
B. Factors That Will Trigger a Non-Periodic Review of Client
Accounts
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Non-periodic reviews of client accounts may be triggered by material market, economic,
or political events, or by significant changes in a client’s personal financial situation. Such
changes may include, but are not limited to, retirement, termination of employment,
relocation, inheritance, or other major life events. These reviews ensure that client accounts
remain aligned with their financial goals and risk tolerance in light of changing
circumstances.
C. Content and Frequency of Regular Reports Provided to
Clients
Each client will receive at least quarterly a written report or statement from their
custodian. These reports will detail the client’s account, including the assets held and their
current value. The reports are provided directly by the custodian and offer clients a
comprehensive overview of their account and holdings.
Item 14: Client Referrals and Other Compensation
A. Economic Benefits Provided by Third Parties for Advice
Rendered to Clients (Includes Sales Awards or Other Prizes)
Ark Advisors, LLC does not receive any economic benefit, directly or indirectly, from any
third party for advice rendered to clients. This includes, but is not limited to, sales awards,
prizes, or any other form of compensation from third parties in exchange for providing
advice to clients.
B. Compensation to Non – Advisory Personnel for Client
Referrals
Ark Advisors, LLC does not directly or indirectly compensate any individual who is not
part of the advisory personnel for referring clients to the firm.
Item 15: Custody
Ark Advisors, LLC does not maintain physical custody of client funds or securities.
However, we are deemed to have “limited custody” as defined under SEC Rule 206(4)-2
due to our authority to directly deduct advisory fees from client accounts or other
limited arrangements explicitly authorized by the client.
Definition of Limited Custody
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Limited custody refers to instances where the adviser has the ability to access or control
client funds or securities but does not hold them directly. Examples of limited custody
include:
• The authority to deduct advisory fees directly from client accounts with the client’s
prior written consent.
• Acting as an agent on behalf of a client to facilitate certain transfers, only where
explicit written authorization and procedural safeguards are in place.
Client Safeguards
To protect client assets and comply with regulatory requirements:
1. Third-Party Custodians: All client funds and securities are held by qualified
custodians, such as broker-dealers, banks, or trust companies, in accounts titled in
the client’s name. Ark Advisors does not serve as the custodian for any client account.
2. Statements and Records: Clients receive account statements directly from the
qualified custodian on at least a quarterly basis. These statements reflect all
transactions, holdings, and fees deducted. Clients are encouraged to review these
statements carefully and compare them to any reports provided by Ark Advisors.
3. Written Authorization: Advisory fees are deducted only with prior written
authorization from the client. This authorization is included in the advisory
agreement signed at the onset of the relationship.
4. No Commingling of Assets: At no point are client funds commingled with the
assets of Ark Advisors or its personnel.
Audits and Compliance
Ark Advisors undergoes routine compliance reviews to ensure adherence to SEC custody
rules. While the firm is not required to obtain an independent audit of client assets, we
implement strict internal controls to safeguard client accounts and meet regulatory
standards.
Item 16: Investment Discretion
For client accounts where Ark Advisors, LLC has investment discretion, the client grants
Ark written authority to make decisions regarding the securities to be bought or sold
and the amount of securities to be traded. This discretionary authority is explicitly
detailed and disclosed to the client before any advisory relationship begins.
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The client provides Ark with discretionary authority through a discretionary investment
management clause in the Investment Advisory Agreement and/or a limited power of
attorney clause in the agreement between the client and the custodian.
Please note that retirement plan services are provided on a non-discretionary basis only.
For further details, please refer to Item 4 – Advisory Business – Retirement Plan (401k)
Services.
Item 17: Voting Client Securities (Proxy Voting)
Ark Advisors, LLC does not ask for, nor accept, voting authority for client securities. Clients
will receive proxies directly from the issuer of the security or their custodian. Any questions
regarding proxies should be directed to the issuer of the security.
Item 18: Financial Information
A. Balance Sheet
Ark Advisors, LLC does not require or solicit prepayment of more than $1200 in fees per
client, six months or more in advance. As a result, Ark is not required to include a balance
sheet with this brochure.
B. Financial Conditions Reasonably Likely to Impair Ability to
Meet Contractual Commitments to Clients
Neither Ark Advisors, LLC nor its management have any financial conditions that are
reasonably likely to impair our ability to meet our contractual commitments to clients.
C. Bankruptcy Petitions in Previous Ten Years
Ark Advisors, LLC has not been the subject of a bankruptcy petition in the last ten years.
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