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Part 2A of Form ADV: Firm Brochure
ASL Financial, LLC
987 University Avenue, Suite 8
Los Gatos, CA 95032
Telephone: 408∙283∙7256
Facsimile: 408.286.9403
Email: rsnow@osaicwealth.com
January 05, 2026
This brochure provides information about the qualifications and business practices of
ASL Financial, LLC (hereinafter ʺASLF,ʺ the ʺfirm,ʺ or ʺweʺ). If you have any questions
about the contents of this brochure, please contact us at 408∙283∙7256 or
rsnow@osaicwealth.com. The information in this brochure has not been approved or
verified by the United States Securities and Exchange Commission or by any state
securities authority.
It should be noted that registration of an investment adviser does not imply a certain
level of training or skill.
Additional information about ASLF also is available on the SEC’s website at
www.adviserinfo.sec.gov. You can search this site by a unique identifying number,
known as a CRD number. Our firmʹs CRD number is 115479.
Item 2 Material Changes
This Brochure dated January 05, 2026, represents the annual amendment to the Brochure for ASL
Financial, LLC.
Since the filing of the last annual update Brochure amendment dated January 10, 2025, we have
made various minor updates, but no material changes were made.
Pursuant to regulatory requirements, we will deliver to you a summary of any material changes to
this and subsequent Brochures within 120 days of the close of our fiscal year. We may further
provide other ongoing disclosure information about material changes as necessary. All such
information will be provided to you free of charge.
Currently, our Brochure may be requested by contacting us at (408) 283‐7256.
Additional information about ASL Financial, LLC is also available via the SEC’s web site
www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated
with the ASL Financial, LLC who are registered as investment adviser representatives of the firm.
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Item 3 Table of Contents
Page
Fees and Compensation
Performance‐Based Fees and Side‐By‐Side Management
Types of Clients
Investment Discretion
Item 1 Cover Page
Item 2 Material Changes
Table of Contents
Item 3
Item 4 Advisory Business
Item 5
Item 6
Item 7
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
Item 9 Disciplinary Information
Item 10 Other Financial Industry Activities and Affiliations
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Item 12 Brokerage Practices
Item 13 Review of Accounts
Item 14 Client Referrals and Other Compensation
Item 15 Custody
Item 16
Item 17 Voting Client Securities
Item 18 Financial Information
Item 19 Requirements for State‐Registered Advisers
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Attachment:
Brochure Supplement: Renée M. Snow
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Item 4 Advisory Business
ASLF is an SEC registered investment adviser with its principal place of business located in San Jose,
California. It should be noted that registration as an investment adviser does not require and should
not be interpreted to imply any particular level of skill or training. ASLF began conducting advisory
business in 2002.
Listed below are the firmʹs principal shareholders (i.e., those individuals and/or entities controlling
25% or more of this company).
Renée M. Snow, Managing Member and sole owner
The Managing Member of ASLF is separately licensed as a registered representative of Osaic Wealth,
Inc. (hereinafter ʺOsaicʺ), a SEC registered investment adviser and broker‐dealer, and a member of
FINRA. (Prior to September 5, 2023, the aforementioned broker‐dealer affiliation was with SagePoint
Financial, Inc., which was an independent broker dealer operating under the Advisors Group
umbrella of independent broker‐dealers. Advisors Group restructured and subsequently began
operating under the Osaic Wealth, Inc. consolidated entity.)
ASLF offers the following advisory services to our clients:
PORTFOLIO MANAGEMENT SERVICES
VISION2020 Wealth Management Platform: ADVISOR MANAGED PORTFOLIOS PROGRAM
Our firm provides continuous advice to a client regarding the investment of client funds based on the
individual needs of the client. ASLF manages client accounts utilizing the VISION2020 Wealth
Management Platform – Advisory Managed Portfolios Program (ʺAdvisor Managed Portfoliosʺ or the
ʺProgramʺ).
The Wealth Management Platform – Advisor Managed Portfolios Program (“Advisor Managed
Portfolios”) provides comprehensive investment management of your assets through the application
of asset allocation planning software as well as the provision of execution, clearing and custodial
services through Pershing, LLC (“Pershing”).
Advisor Managed Portfolios provides risk tolerance assessment, efficient frontier plotting, fund
profiling and performance data, and portfolio optimization and re‐balancing tools. Utilizing these
tools, and based on your responses to a risk tolerance questionnaire (“Questionnaire”) and discussions
that we have together regarding, among other things, investment objective, risk tolerance, investment
time horizon, account restrictions, and overall financial situation, we construct a portfolio of
investments for you. This portfolio may consist of mutual funds, exchange traded funds, equities,
options, debt securities, variable life, variable annuity sub‐accounts (certain restrictions may apply)
and other investments. ASLF manages these client accounts on a discretionary or non‐discretionary
basis.
Each portfolio is designed to meet your individual needs, stated goals and objectives. Additionally,
you have the opportunity to place reasonable restrictions on the types of investments to be held in the
portfolio.
We offer Advisor Managed Portfolios as an account where no separate transactions charges apply and
a single fee is paid for all advisory services and transactions (ʺWrap Accountʺ). For further Advisor
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Managed Portfolios details please see the Advisor Managed Portfolios Wrap Fee Program Brochure.
We provide this brochure to you prior to or concurrent with your enrollment in Advisor Managed
Portfolios. Please read it thoroughly before investing.
The Program is offered through Osaic, which sponsors the Advisor Managed Portfolios Program and
provides certain software and other services to ASLF to operate the Program. Pershing provides all
custodial and clearing services for Program Accounts.
Our investment recommendations will generally include advice regarding the following securities:
Exchange‐listed securities
• Securities traded over‐the‐counter
Certificates of deposit
• Commercial paper
Mutual fund shares
• Exchange‐traded funds
Municipal securities
• U. S. governmental securities
Variable life insurance
• Variable annuities
Corporate debt securities (other than commercial paper)
Although recommendations for new investments will typically be limited to these items, we may
render investment advice on other types of investments held by a client at the start of the advisory
relationship. Furthermore, clients may impose reasonable restrictions on investing in certain
securities, types of securities, or industry sectors.
Because some types of investments involve certain additional degrees of risk, they will only be
implemented/recommended when consistent with the clientʹs stated investment objectives, tolerance
for risk, liquidity and suitability.
FINANCIAL PLANNING SERVICES
ASLF provides project oriented and ongoing financial planning services. Financial planning is a
comprehensive evaluation of a client’s current and future financial state by using currently known
variables to predict future cash flows, asset values and withdrawal plans. Through the financial
planning process, all questions, information and analysis are considered as they impact and are
impacted by the entire financial and life situation of the client.
Clients purchasing this service will generally receive a written report which provides the client with a
detailed financial plan designed to assist the client achieve his or her financial goals and objectives.
In general, the financial plan can address any or all of the following areas:
PERSONAL: We review family records, budgeting, personal liability, estate information and
financial goals.
TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past,
current and future years; then illustrate the impact of various investments on the clientʹs
current income tax and future tax liability.
INVESTMENTS: We analyze investment alternatives and their effect on the clientʹs portfolio.
INSURANCE: We review existing policies to ensure proper coverage for life, health, disability,
long‐term care, liability, home and automobile.
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RETIREMENT: We analyze current strategies and investment plans to help the client achieve
his or her retirement goals.
DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving
dependents, estate planning and disability income.
ESTATE: We assist the client in assessing and developing long‐term strategies, including as
appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans,
nursing homes, Medicaid and elder law.
We gather required information through in‐depth personal interviews. Information gathered includes
the clientʹs current financial status, tax status, future goals, returns objectives and attitudes towards
risk. We carefully review documents supplied by the client, including a questionnaire completed by
the client, and prepare a written report. Should the client choose to implement the recommendations
contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance
agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the clientʹs
discretion.
We also provide general non‐securities advice on topics that may include tax and budgetary planning,
estate planning and business planning.
Typically, the financial plan is presented to the client within 90 days of the contract date, provided all
information needed to prepare the financial plan has been promptly provided by the client.
CONSULTING SERVICES
Clients can also receive one‐time or ongoing investment advice on a more focused basis. This may
include advice on only an isolated area(s) of concern such as estate planning, retirement planning, or
any other specific topic. We also provide specific consultation and administrative services regarding
investment and financial concerns of the client.
Additionally, ASLF provides advice on non‐securities matters. Generally, this is in connection with
the rendering of tax planning, insurance, and/or annuity advice.
GENERAL SERVICE INFORMATION
Tax Preparation Services: ASLF also offers tax preparation services to the firm’s advisory clients for
separate and customary compensation. These services are provided by Ms. Snow in her separate
capacity as an Enrolled Agent. Please refer to Item 10 of this document for important additional
information concerning these activities.
Limitations: As previously disclosed, the Managing Member of ASLF is a registered representative of
Osaic. Accordingly, advisory recommendations include those products offered by this company.
However, if a product is not offered through Osaic, other companies offering the products will be
recommended.
Fiduciary Disclosure: Because ASLF is a registered investment adviser, we are required to meet
certain fiduciary standards when providing investment advice to clients. Additionally, when we
provide investment advice related to a retirement plan account or an individual retirement account,
we are considered fiduciaries within the meaning of Title I of the Employee Retirement Income
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Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. As such, we are required to act in your best interest and not put our interest ahead of
yours, even though our compensation creates some conflicts with your interests in that the more you
have us manage, the more we can earn. Our clients however are under no obligation to use services
recommended by our associated persons. Furthermore, we believe that our recommendations are in
the best interests of our clients and are consistent with our clients’ needs.
AMOUNT OF MANAGED ASSETS
As of 12/31/2025, ASLF had approximately $178,973,028 in discretionary assets under
management, and $7,765,235 in non‐ discretionary assets under management, for a total of
$186,708,263 in assets under management.
Item 5
Fees and Compensation
INVESTMENT MANAGEMENT SERVICES
VISION2020 ADVISOR MANAGED PORTFOLIOS PROGRAM
ASLFʹs annualized fee for portfolio management services is charged as a percentage of assets under
management, according to the following schedule:
Assets under Management
Maximum Annual Fee
$50,000 to $99,999.99
$100,000 ‐ $249,999.99
$250,000 ‐ $499,999.99
$500,000 ‐ $749,999.99
$750,000 ‐ $1,249,999.99
$1,250,000 ‐ $1,999,999.99
$2,000,000 ‐ $4,999,999.99
$5,000,000 ‐ $24,999,999.99
2.50% per annum
2.30% per annum
2.05% per annum
1.80% per annum
1.55% per annum
1.30% per annum
1.05% per annum
0.80% per annum
The minimum account size to initiate and maintain an Advisor Managed Portfolios Program account
is $50,000; which may be deposited in the form of cash, stocks, bonds, no‐load or load‐waived mutual
funds or securities. The advisory fee and minimum account size may be negotiable under certain
circumstances. ASLF may group certain related client accounts for the purposes of achieving the
minimum account size and determining the annualized fee.
Our fees are billed quarterly, in advance, at the beginning of each calendar quarter based upon the
value (market value or fair market value in the absence of market value), of the clientʹs account at the
end of the previous quarter. Fees will be debited from the account in accordance with the client
authorization in the Client Agreement.
The initial fee is payable when the VISION2020 Advisor Managed Portfolios Program is established,
pro‐rated for the first partial quarter, if any. Additional deposits to the account are subject to the same
fee procedures.
Notwithstanding the foregoing, no advisory fees will be charged on any mutual funds, unit
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investment trusts or annuities transferred to the VISION2020 Advisor Managed Portfolios Program
which were purchased within the past two years if a commission was paid to ASLF in its role as a
broker‐dealer or to clientʹs IAR at another broker‐dealer.
Transaction charges and other administrative fees are charged by Osaic which directly withholds such
amounts from the advisory fees clients pay to ASLF. These transaction charges are paid to Pershing
and are primarily retained by Pershing, although a portion may be re‐allowed to Osaic. These
transaction charges represent payment to Osaic and Pershing for brokerage services and to Osaic for
execution supervisory services and administrative services. Clients are not separately charged these
fees.
FINANCIAL PLANNING and CONSULTING SERVICES FEES
Financial Planning and/or Consulting Services fees will be charged in one or both of the two ways
listed below, upon mutual agreement with the advisory client:
1. As a fixed fee, typically ranging from $500 to $5,000, depending on the nature and complexity
of each clientʹs circumstances; and/or
2. On an hourly basis, ranging from $300 to $500 per hour, depending on the nature and
complexity of each clientʹs circumstances. An estimate for total hours will be determined at the
start of the advisory relationship.
ASLFʹs fee is determined based on the nature of the services being provided and the complexity of
each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client.
We may request a retainer upon completion of our initial fact‐finding session with the client; however,
advance payment will never exceed $500 for work that will not be completed within six months. The
balance is due upon completion of the plan for projects or are due periodically for ongoing services. If
services are terminated, fees will be pro‐rated based on the amount of work completed and any
unearned fees paid in advance will be refunded.
Fees Offset By Commissions: If a Financial Planning or Consulting Services client executes
recommended securities transactions through associated persons of our firm in their separate
capacities as registered representatives of a broker‐dealer, these individuals will earn commissions
which are separate and distinct from fees charged for advisory services. In some instances, depending
on the size of the transaction, advisory fees will be discounted, at our discretion, for commissions
earned. Commissions will not be credited towards future advisory fees.
Tax Preparation Services: Tax preparation fees typically range from $600 to $2,000 and are
determined based on time factors and complexity. All fees are agreed upon prior to the engagement.
GENERAL INFORMATION
Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either
party, for any reason upon receipt of 30 days written notice. The client has the right to terminate an
agreement without penalty within five business days after entering into the agreement.
As disclosed above, certain fees are paid in advance of services provided. Upon termination of any
account, any prepaid, unearned fees will be promptly refunded. In calculating a client’s
reimbursement of fees, we will pro rate the reimbursement according to the number of days
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remaining in the billing period.
Limited Negotiability of Advisory Fees: Although ASLF has established the aforementioned fee
schedule(s), we retain the discretion to negotiate alternative fees on a client‐by‐client basis. Client
facts, circumstances and needs are considered in determining the fee schedule. These include the
complexity of the client, assets to be placed under management, anticipated future additional assets;
related accounts; portfolio style, account composition, reports, among other factors. The specific
annual fee schedule is identified in the contract between the adviser and each client.
Mutual Fund Fees: All fees paid to ASLF for investment advisory services are separate and distinct
from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees
and expenses are described in each fundʹs prospectus. These fees will generally include a management
fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client
may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without
our services.
In that case, the client would not receive the services provided by our firm which are designed, among
other things, to assist the client in determining which mutual fund or funds are most appropriate to
each clientʹs financial condition and objectives. Accordingly, the client should review both the fees
charged by the funds and our fees to fully understand the total amount of fees to be paid by the client
and to thereby evaluate the advisory services being provided.
Cash Sweeps. In addition, money market mutual funds may be used to ʹsweepʹ unused cash balances
until they can be appropriately invested. Once again, clients should recognize that all fees paid to
ASLF for investment advisory services are separate and distinct from the fees and expenses charged
by mutual funds to their shareholders. These fees and expenses are described in each fundʹs
prospectus. These fees will generally include a management fee, other fund expenses, and a possible
distribution fee.
Other Fees and Expenses. Clients may incur charges for other account services provided not directly
related to the execution and clearing of transactions, including, but not limited to, IRA custodial fees,
safekeeping fees, wire transfer fees, interest charges on margin loans, exchange fees, and fees for
transfers of securities.
Grandfathering of Minimum Account Requirements: Pre‐existing advisory clients are subject to
ASLFʹs minimum account requirements and advisory fees in effect at the time the client entered into
the advisory relationship. Therefore, our firmʹs minimum account requirements will differ among
clients.
ERISA Accounts: ASLF is deemed to be a fiduciary to advisory clients that are employee benefit plans
or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income Security Act
(ʺERISAʺ), and regulations under the Internal Revenue Code of 1986 (the ʺCodeʺ), respectively. As
such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue
Code that include among other things, restrictions concerning certain forms of compensation. To
avoid engaging in prohibited transactions, ASLF may only charge fees for investment advice about
products for which our firm and/or our related persons do not receive any commissions or 12b‐1 fees,
or conversely, investment advice about products for which our firm and/or our related persons
receive commissions or 12b‐1 fees, however, only when such fees are used to offset ASLFʹs advisory
fees.
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Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in
excess of $500 more than six months in advance of services rendered.
Item 6
Performance‐Based Fees and Side‐By‐Side Management
ASLF does not charge performance‐based fees (i.e., fees based on a share of capital gains or capital
appreciation of the clientʹs assets).
Item 7 Types of Clients
ASLF provides advisory services to the following types of clients:
Individuals (other than high net worth individuals)
High net worth individuals
Corporations or other businesses
As previously disclosed in Item 5, our firm has established certain initial minimum account
requirements, based on the nature of the service(s) being provided and the types of accounts used. For
a more detailed understanding of those requirements, please review the disclosures provided in each
applicable service. Additionally, the firm requires a minimum of $500,000 for new client engagements
which may be waived in limited cases at the firm’s discretion.
Item 8 Methods of Analysis, Investment Strategies and Risk of Loss
METHODS OF ANALYSIS
We use the following methods of analysis in formulating our investment advice and/or managing
client assets:
Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic
and financial factors (including the overall economy, industry conditions, and the financial condition
and management of the company itself) to determine if the company is underpriced (indicating it may
be a good time to buy) or overpriced (indicating it may be time to sell).
Fundamental analysis does not attempt to anticipate market movements. This presents a potential
risk, as the price of a security can move up or down along with the overall market regardless of the
economic and financial factors considered in evaluating the stock.
Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the
companies whose securities we purchase and sell, the rating agencies that review these securities, and
other publicly‐available sources of information about these securities, are providing accurate and
unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that
our analysis may be compromised by inaccurate or misleading information.
INVESTMENT STRATEGIES
We use the following strategy(ies) in managing client accounts, provided that such strategy(ies) are
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appropriate to the needs of the client and consistent with the clientʹs investment objectives, risk
tolerance, and time horizons, among other considerations:
Long‐term purchases. We purchase securities with the idea of holding them in the clientʹs account for
a year or longer. Typically we employ this strategy when:
we believe the securities to be currently undervalued, and/or
we want exposure to a particular asset class over time, regardless of the current projection for
this class.
Short‐term purchases. When utilizing this strategy, we purchase securities with the idea of selling
them within a relatively short time (typically a year or less). We do this in an attempt to take
advantage of conditions that we believe will soon result in a price swing in the securities we purchase.
Trading. We purchase securities with the idea of selling them very quickly (typically within 30 days or
less). We do this in an attempt to take advantage of our predictions of brief price swings.
Short sales. We borrow shares of a stock for your portfolio from someone who owns the stock on a
promise to replace the shares on a future date at a certain price. Those borrowed shares are then sold.
On the agreed‐upon future date, we buy the same stock and return the shares to the original owner.
We engage in short selling based on our determination that the stock will go down in price after we
have borrowed the shares. If we are correct and the stock price has gone down since the shares were
purchased from the original owner, the client account realizes the profit.
Margin transactions. We will purchase stocks for your portfolio with money borrowed from your
brokerage account. This allows you to purchase more stock than you would be able to with your
available cash, and allows us to purchase stock without selling other holdings.
Option writing. We may use options as an investment strategy. An option is a contract that gives the
buyer the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific
price on or before a certain date. An option, just like a stock or bond, is a security. An option is also a
derivative, because it derives its value from an underlying asset.
The two types of options are calls and puts:
A call gives us the right to buy an asset at a certain price within a specific period of time. We
will buy a call if we have determined that the stock will increase substantially before the
option expires.
A put gives us the holder the right to sell an asset at a certain price within a specific period of
time. We will buy a put if we have determined that the price of the stock will fall before the
option expires.
We will use options to speculate on the possibility of a sharp price swing. We will also use options to
ʺhedgeʺ a purchase of the underlying security; in other words, we will use an option purchase to limit
the potential upside and downside of a security we have purchased for your portfolio.
We use ʺcovered calls,ʺ in which we sell an option on security you own. In this strategy, you receive a
fee for making the option available, and the person purchasing the option has the right to buy the
security from you at an agreed‐upon price.
We use a ʺspreading strategy,ʺ in which we purchase two or more option contracts (for example, a call
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option that you buy and a call option that you sell) for the same underlying security. This effectively
puts you on both sides of the market, but with the ability to vary price, time and other factors.
Risk of Loss. Securities investments are not guaranteed and you may lose money on your
investments. We ask that you work with us to help us understand your tolerance for risk.
Item 9 Disciplinary Information
We are required to disclose any legal or disciplinary events that are material to a clientʹs or
prospective clientʹs evaluation of our advisory business or the integrity of our management.
Our firm and our management personnel have no reportable disciplinary events to disclose.
Item 10 Other Financial Industry Activities and Affiliations
As previously disclosed, Renée Snow, the Managing Member of ASLF is separately licensed as a
registered representative of Osaic Wealth, Inc. (ʺOsaicʺ), an unaffiliated SEC‐registered investment
adviser and broker‐dealer, as well as a member of FINRA and various other regulatory bodies. (Prior
to September 5, 2023, the aforementioned broker‐dealer affiliation was with SagePoint Financial, Inc.,
which was an independent broker dealer operating under the Advisors Group umbrella of
independent broker‐dealers. Advisors Group restructured and subsequently began operating under
the Osaic Wealth, Inc. consolidated entity.) In her separate capacity as a registered representative,
Ms. Snow can effect securities transactions for which she will receive separate, yet customary
compensation. For brokerage programs provided by Osaic, it furnishes certain materials and forms
for the programs, including account agreement forms to be used by representatives of Osaic when
opening client accounts.
Osaic reviews and, if applicable, approves the material solely in its capacity as broker‐dealer for the
account.
In order to fulfill its obligation, Osaic has established a list of custodian and brokerage firms which it
has arranged to obtain the required cooperation, and which therefore may be utilized for custody of
accounts directly advised either by registered representatives of Osaic who are investment advisers or
other investment adviser entities which are affiliated with registered representatives of Osaic. In
certain instances, Osaic will collect, as paying agent for ASLF, the investment advisory fee remitted to
ASLF by the account custodian, and Osaic will retain a portion as a charge to ASLF (not the client) for
the functions Osaic is required to carry out by FINRA. This fee will not increase execution or
brokerage charges to the client or the fee the client has agreed to pay ASLF pursuant to the client’s
advisory agreement. A portion of the fee retained by Osaic may be re‐allowed to other registered
representatives of Osaic who, as registered representatives of Osaic are responsible for the
supervision of other representatives and assist Osaic with the functions described above.
Additionally, Ms. Snow is designated a Certified Divorce Financial Analyst® (ʺCDFA®ʺ) providing
specialized focus related to the financial issues of divorce. With this designation, she is able to help
both the Client and their lawyer assess how the financial decisions made about short and long‐term
effects of property division, tax issues, pension and/or retirement plan issues, insurance needs,
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inflation and rates of return projections, among other considerations, could impact the Clientʹs
financial future, based on various assumptions. Advisory clients are under no obligation to engage
Ms. Snow for these services.
Ms. Snow, in her individual capacity, is also an agent for various insurance companies. As such, she is
able to receive separate, yet customary commission compensation resulting from implementing
product transactions on behalf of advisory clients. Clients, however, are not under any obligation to
engage her when considering implementation of advisory recommendations. The implementation of
any or all recommendations is solely at the discretion of the client.
The life insurance companies for which Ms. Snow is an agent for also charge certain fees in association
with their products, such as: mortality and expense, administrative fees and management fees. These
variable annuities may be purchased in advisory accounts solicited by ASLF, but only on a non‐
discretionary basis after the client has received a prospectus disclosing all terms of the annuities. In
addition, clients of ASLF may purchase variable annuities with non‐advisory account assets.
Separately, Ms. Snow is, in her individual capacity, an Enrolled Agent (EA). EAs are the only federally
licensed tax practitioners who specialize in taxation and also have unlimited rights to represent
taxpayers before the IRS. In this role, she is able to advise, represent, and prepare tax returns for
individuals, partnerships, corporations, estates, trusts, and any entities with tax‐reporting
requirements for which she will receive separate yet customary compensation.
Advisory clients, however, are under no obligation to engage Ms. Snow for these services.
Clients should be aware that the receipt of additional compensation by ASLF and its management
persons or employees creates a conflict of interest that may impair the objectivity of our firm and these
individuals when making advisory recommendations. ASLF endeavors at all times to put the interest
of its clients first as part of our fiduciary duty as a registered investment adviser, we take the
following steps to address this conflict:
we disclose to clients the existence of all material conflicts of interest, including the potential
for our firm and our employees to earn compensation from advisory clients in addition to our
firmʹs advisory fees;
we disclose to clients that they are not obligated to purchase recommended investment
products from our employees or affiliated companies;
we collect, maintain and document accurate, complete and relevant client background
information, including the client’s financial goals, objectives and risk tolerance;
we conduct regular reviews of each client account to verify that all recommendations made to
a client are suitable to the client’s needs and circumstances.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
Code of Ethics
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ASLF has adopted a Code of Ethics expressing the firmʹs commitment to ethical conduct. The ASLF
Code of Ethics describes the firmʹs fiduciary duties and responsibilities to clients, and details practices
for reviewing the personal securities transactions of supervised persons with access to client
information. The Code also requires compliance with applicable securities laws, addresses insider
trading, and details possible disciplinary measures for violations. ASLF will provide a complete copy
of its Code of Ethics to any client upon request to the Chief Compliance Officer.
Trading Conflicts of Interest
Individuals associated with ASLF are permitted to buy or sell securities for their personal accounts
identical to or different than those recommended to clients. However, no person employed by ASLF is
allowed to favor his or her own interest over that of a client or make personal investment decisions
based on the investment decisions of advisory clients.
In order to address potential conflicts of interest, ASLF requires that associated persons with access to
advisory recommendations provide annual securities holdings reports and quarterly transaction
reports to the firmʹs Chief Compliance Officer. ASLF also requires prior approval from the Chief
Compliance Officer for investing in any IPOs or private placements (limited offerings).
Item 12 Brokerage Practices
ASLF does not have any soft‐dollar arrangements and does not receive any soft‐dollar benefits.
As our firm does not have the discretionary authority to determine the broker‐dealer to be used or the
commission rates to be paid, clients must direct ASLF as to the broker‐dealer to be used.
As previously disclosed, the Managing Member of ASLF is separately registered as a representative of
Osaic Wealth, Inc., a broker‐dealer and FINRA member firm. Osaic is required to supervise the
securities trading activities of its representatives. Clients may request that brokerage transactions be
directed to a particular broker or dealer. However, if Osaic believes that the use of that broker‐ dealer
would hinder it in meeting its supervisory obligations, ASLF will not be able to accept the account.
VISION2020 ADVISOR MANAGED PORTFOLIOS PROGRAM
As a condition for participating in the VISION2020 Advisor Managed Portfolios Program, clients are
required to direct the use of Pershing, LLC as clearing broker‐dealer and custodian. Program clients
should understand that ASLF will not have authority to negotiate commissions or obtain volume
discounts, and best execution may not be achieved. In addition, a disparity in commission charges
may exist between the commissions charged to other clients. The charges may be higher or lower
than the amount payable in the absence of the Advisor Managed Portfolios Program Agreement. As
to other aspects of best execution, ASLF will seek to obtain best execution for the clientʹs transaction.
ASLF may aggregate trades for various accounts in order to obtain better execution.
ASLF will block trades where possible and when advantageous to clients. This blocking of
trades permits the trading of aggregate blocks of securities composed of assets from multiple
clientsʹ accounts so long as transaction costs are shared equally and on a pro‐rated basis
between all accounts included in any such block. Block trading allows us to execute equity
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trades in a more timely, equitable manner and to reduce overall commission charges to
clients.
ASLFʹs block trading policy and procedures are as follows:
1. Transactions for any client account may not be aggregated for execution if the practice is
prohibited by or inconsistent with the clientʹs advisory agreement with ASLF, or our firmʹs
order allocation policy.
2. The trading desk in concert with the portfolio manager must determine that the purchase or
sale of the particular security involved is appropriate for the client and consistent with the
clientʹs investment objectives and with any investment guidelines or restrictions applicable to
the clientʹs account.
3. The portfolio manager must reasonably believe that the order aggregation will benefit, and
will enable ASLF to seek best execution for each client participating in the aggregated order.
This requires a good faith judgment at the time the order is placed for the execution. It does
not mean that the determination made in advance of the transaction must always prove to
have been correct in the light of a ʺ20‐20 hindsightʺ perspective. Best execution includes the
duty to seek the best quality of execution, as well as the best net price.
4. Prior to entry of an aggregated order, a written order ticket must be completed which
identifies each client account participating in the order and the proposed allocation of the
order, upon completion, to those clients.
5. If the order cannot be executed in full at the same price or time, the securities actually
purchased or sold by the close of each business day must be allocated pro rata among the
participating client accounts in accordance with the initial order ticket or other written
statement of allocation. However, adjustments to this pro rata allocation may be made to
participating client accounts in accordance with the initial order ticket or other written
statement of allocation. Furthermore, adjustments to this pro rata allocation may be made to
avoid having odd amounts of shares held in any client account, or to avoid excessive ticket
charges in smaller accounts.
6. Generally, each client that participates in the aggregated order must do so at the average price
for all separate transactions made to fill the order, and must share in the commissions on a pro
rata basis in proportion to the clientʹs participation. Under the client’s agreement with the
custodian/broker, transaction costs may be based on the number of shares traded for each
client.
7. If the order will be allocated in a manner other than that stated in the initial statement of
allocation, a written explanation of the change must be provided to and approved by the Chief
Compliance Officer no later than the morning following the execution of the aggregate trade.
8. ASLFʹs client account records separately reflect, for each account in which the aggregated
transaction occurred, the securities which are held by, and bought and sold for, that account.
9. Funds and securities for aggregated orders are clearly identified on ASLFʹs records and to the
broker‐dealers or other intermediaries handling the transactions, by the appropriate account
numbers for each participating client.
10. No client or account will be favored over another.
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FINANCIAL PLANNING and CONSULTING SERVICES
Clients will be required to select their own broker‐dealers and insurance companies for the
implementation of financial planning and/or consulting recommendations. ASLF may recommend
any one of several brokers (including, but not limited to Osaic). ASLF clients must independently
evaluate these brokers before opening an account.
The factors we considered when making this recommendation are the brokerʹs ability to provide
professional services, our experience with the broker, the brokerʹs reputation, and the brokerʹs
financial strength, among other factors. ASLF financial planning and/or consulting clients may use
any broker or dealer of their choice.
In general, ASLF may recommend the use of Osaic and Ms. Snow to clients for implementation of
financial planning and/or consulting recommendations, provided this recommendation is consistent
with our fiduciary duty to the client.
Any commissions or other compensation received from the implementation of advisory
recommendations is separate and distinct from ASLFʹs advisory fee. No advisory client is obligated to
use Osaic to implement any recommended transactions.
Clients should be aware that best execution and lower commissions may not necessarily be achieved if
recommended transactions are placed through these individuals, in their separate capacities as
registered representatives or insurance agents.
Item 13 Review of Accounts
PORTFOLIO MANAGEMENT
VISION2020 ADVISOR MANAGED PORTFOLIOS PROGRAM
REVIEWS: While the underlying securities within VISION2020 Advisor Managed Portfolios Program
accounts are continuously monitored, these accounts are reviewed at least monthly by Renée Snow,
Managing Member of ASLF. Accounts are reviewed in the context of each clientʹs stated investment
objectives and guidelines. More frequent reviews may be triggered by material changes in variables
such as the clientʹs individual circumstances, or the market, political or economic environment.
REPORTS: In addition to the monthly statements and confirmations of transactions that VISION2020
Advisor Managed Portfolios Program clients receive from their broker‐dealer, ASLF will provide
detailed written quarterly account performance reports.
FINANCIAL PLANNING and CONSULTING:
REVIEWS: These client accounts will be reviewed as contracted for at the inception of the advisory
relationship.
REPORTS: These client accounts will receive written reports as contracted for at the inception of the
advisory relationship.
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Item 14 Client Referrals and Other Compensation
CLIENT REFERRALS
It is ASLFʹs policy not to engage solicitors or to pay related or non‐related persons for referring
potential clients to our firm.
OTHER COMPENSATION
ASLF does not receive any compensation for its services other than that which has been disclosed in
Item 5 above.
Item 15 Custody
ASLF does not hold client assets but instead requires that assets be held by a qualified custodian. We
may however have limited control in some instances to trade on your behalf, to deduct advisory fees
from your account with your authorization, or to request distributions to you or outside parties
(although various types of written authorizations are required depending on the type of
disbursements).
As part of our billing process, the clientʹs custodian is notified by us of the amount of the fee to be
deducted from that clientʹs account. On at least a quarterly basis, the custodian is required to send to
the client a statement showing all transactions within the account during the reporting period
including this fee deduction amount.
Because the custodian does not calculate the amount of the fee to be deducted, it is important for
clients to carefully review their custodial statements to verify the accuracy of the calculation, among
other things. Clients should contact us directly if they believe that there may be an error in their
statement.
Item 16
Investment Discretion
Clients may hire us to provide discretionary asset management services, in which case we place trades
in a clientʹs account without contacting the client prior to each trade to obtain the clientʹs permission.
Our discretionary authority includes the ability to do the following without contacting the client:
determine the security to buy or sell; and/or
determine the amount of the security to buy or sell
Clients give us discretionary authority when they sign a discretionary agreement with our firm, and
may limit this authority by giving us written instructions. Clients may also change/amend such
limitations by once again providing us with written instructions.
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Item 17 Voting Client Securities
We do not vote proxies or process class action claims on behalf of clients. However, clients may
receive proxies or other solicitations directly from their custodian and can contact us with questions.
Item 18 Financial Information
Under no circumstances do we require or solicit payment of fees in excess of $500 per client more than
six months in advance of services rendered. Therefore, we are not required to include a financial
statement with this disclosure document.
As an advisory firm that maintains discretionary authority for client accounts, we are also required to
disclose any financial condition that is reasonable likely to impair our ability to meet our contractual
obligations. ASLF has no such financial circumstances to report.
ASLF has never been the subject of a bankruptcy petition.
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Part 2B of Form ADV: Brochure Supplement
Renée M. Snow, Ph.D., CFP®, CDFA®, EA
ASL Financial, LLC
987 University Avenue, Suite 8
Los Gatos, CA 95032
Telephone: 408∙283∙7256
January 05, 2026
This brochure supplement provides information about Renée M. Snow that
supplements the ASL Financial, LLC (hereinafter ʺASLFʺ) brochure. You should
have received a copy of that brochure. Please contact Renée Snow if you did not
receive ASLFʹs brochure or if you have any questions about the contents of this
supplement.
Additional information about Ms. Snow is available on the SEC’s website at
www.adviserinfo.sec.gov.
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Item 2. Educational, Background and Business Experience
Full Legal Name: Renée M. Snow, Ph.D., CFP®, CDFA®, EA Born: 1972
Education
(cid:31)
Graduated from the University of Santa Cruz in 1994 with a Bachelor of Arts
degree in Economics.
Graduated from San Jose State University in 1997 with a Master’s degree in
Accountancy.
Graduated from the University of Santa Monica in 2007 with a Master’s
degree in Psychology
(cid:31)
Awarded a Doctor of Philosophy (PhD) from the Institute of Transpersonal
Psychology in 2010.
Professional Designations
Ms. Snow has earned the following professional designations and is in good
standing with the granting authorities:
Certified Financial Planner™ (CFP®); certification was awarded in 2002
The program is administered by the Certified Financial Planner Board of Standards
Inc. Those with the CFP® designation have demonstrated competency in all areas
of finance related to financial planning. Candidates complete studies on over 100
topics, including stocks, bonds, taxes, insurance, retirement planning and estate
planning. In addition to passing the CFP certification exam, candidates must also
complete qualifying work experience and agree to adhere to the CFP Boardʹs code
of ethics and professional responsibility and financial planning standards.
Certified Divorce Financial Analyst (CDFA®); certification was awarded in 2018.
The CDFA® (Certified Divorce Financial Analyst) designation is granted by the
Institute for Divorce Financial Analysts. To attain the designation an individual
must have at least 2 years of experience in a financial services capacity. The
individual must also complete a four‐part examination and agree to adhere to a
Code of Ethics. In addition, to maintain the right to continue to use the
designation, an individual must complete 20 hours of continuing education every
two years.
(cid:31)
Enrolled Agent (EA), awarded by the Internal Revenue Service in 2012
Licensing as an EA may be accomplished by (i) passing a comprehensive
examination which covers all aspects of the tax code, or (ii) having worked at the
IRS for five years in a position which regularly interpreted and applied the tax
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code and its regulations. All candidates are subjected to a rigorous background
check conducted by the IRS.
In addition to the stringent testing and application process, the IRS requires
enrolled agents to complete 72 hours of continuing education, reported every three
years, to maintain their enrolled agent status.
Business Experience
(cid:31)
ASL Financial, LLC; Managing Member and Investment Adviser Representative
from 09/2001 to Present
(cid:31)
Registered Representative, Registered Principal of Osaic Wealth, Inc.
(formerly known as “SagePoint Financial Advisors, Inc.”) 05/1997 to
present.
Item 3. Disciplinary Information
Ms. Snow has no history of any disciplinary events.
Item 4. Other Business Activities
A.
Investment‐Related Activities
Ms. Snow is separately licensed as a registered representative of Osaic Wealth,
Inc. (hereinafter ʺOsaicʺ), a SEC registered investment adviser and broker‐
dealer, and a member of FINRA.
Ms. Snow is also a licensed insurance agent with several life and health insurance
companies.
ASLF advisory clients are under no obligation to engage Ms. Snow in any of her
separate capacities. The implementation of any or all financial planning or
consulting recommendations is solely at the discretion of the client.
B. Non Investment‐Related Activities
Ms. Snow is separately licensed as an Enrolled Agent (EA); a federally licensed tax
practitioner specializing in taxation with unlimited rights to represent taxpayers
before the IRS. In this capacity she provides tax preparation services through
ASLF, for which she receives separate and customary compensation.
ASLF advisory clients are under no obligation to engage Ms. Snow for tax
preparation services.
Ms. Snow is also an Associate Professor at Sofia University and UCSC‐extension
Program Chair for the Personal Financial Planning Program, as well as an Adjunct
Professor at California Institute of Integral Studies
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Item 5. Additional Compensation
Ms. Snow does not receive any additional compensation from third parties for providing
investment advice to ASLF clients. Ms. Snow may receive 12b‐1 distribution fees in
connection to transactions for commission clients; clients are reimbursed for these fees.
Item 6. Supervision
Renée Snow does not have a Supervisor as she is the sole owner and Managing Member of
ASLF, with full responsibility for the determination and implementation of all investment
advisory services provided to clients of ASLF.
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