ASSUREDPARTNERS INVESTMENT ADVISORS, LLC

FORM ADV PART 2A Item 1 – Cover Page September 2, 2025 This brochure provides information about the qualifications and business practices of AssuredPartners Investment Advisors, LLC . If you have any questions about the contents of this brochure, please contact us at (407) 815-6774 or by email at: apiacompliance@apadvisors.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. Additional information about AssuredPartners Investment Advisors, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. AssuredPartners Investment Advisors, LLC ’s CRD number is: 309550. 4600 W. Cypress Street, Suite 405 Tampa, Florida 33607 APAdvisors.com  Item 2 – Material Changes Each year, AssuredPartners Investment Advisors (APIA) will provide our clients with either a free updated brochure that includes a summary of material changes or a summary of material changes with an offer to receive a copy of the updated brochure. You may request a copy of our brochure by contacting us at (407) 815-6774 or by email at: apiacompliance@apadvisors.com. Below are the material changes to this brochure since the last annual updating amendment of the brochure filed on March 17, 2025. We have made additional non-material changes to better describe our advisory business and to modify formatting. Item 4 Updated ownership information to indicate that APIA is a wholly owned subsidiary of Arthur J. Gallagher & Co., a publicly traded company. Item 5 Removed disclosure stating that Clients may terminate the advisory agreement within five days of signing without penalty. Clients may terminate the agreement at any time upon written notice to APIA and fees will be pro-rated at the point of termination. Item 10 Removed reference to Justin Callaham as he is no longer affiliated with APIA. Updated disclosure to indicate that APIA is affiliated with other investment adviser firms and broker-dealer firms also under Gallagher’s ownership. Updated to disclose that APIA dba Benefits Plus provides third party administrator services and receives separate compensation for those services. Receipt of this compensation from an advisory client is a conflict of interest. Page 2 of 18  Item 3 - Table of Contents Item 1 – Cover Page ...................................................................................................................................................... 1 Item 2 – Material Changes ............................................................................................................................................ 2 Item 3 - Table of Contents ............................................................................................................................................ 3 Item 4 – Advisory Business ........................................................................................................................................... 5 Description of the Advisory Firm .............................................................................................................................. 5 Types of Advisory Services ........................................................................................................................................ 5 Portfolio Management. ......................................................................................................................................... 5 Financial Planning and Consulting ........................................................................................................................ 6 Advisory Services for Employee Benefit Plan Clients and Plan Participants ......................................................... 6 Educational Workshops and Seminars.................................................................................................................. 7 Services Limited to Specific Types of Investments ................................................................................................... 7 Written Acknowledgement of Fiduciary Status ........................................................................................................ 7 Client Tailored Services and Client Imposed Restrictions ......................................................................................... 7 Wrap Fee Programs .................................................................................................................................................. 7 Assets Under Management ...................................................................................................................................... 8 Item 5 – Fees and Compensation ................................................................................................................................. 8 Fees for Portfolio Management Advisory Services. .................................................................................................. 8 Financial Planning and Consulting Fees .................................................................................................................... 8 Fees for Employee Benefit Plan Advisory Services. .................................................................................................. 9 Client Responsibility for Third-Party Fees ................................................................................................................. 9 Advance Payment of Fees and Refunds .................................................................................................................... 9 Outside Compensation for the Sale of Investment Products to Clients ................................................................... 9 Item 6 – Performance-Based Fees and Side-by-Side Management ............................................................................. 9 Item 7 – Types of Clients ............................................................................................................................................. 10 Methods of Analysis and Investment Strategies ........................................................................................................ 10 Methods of Analysis and Investment Strategies .................................................................................................... 10 Material Risks Involved ........................................................................................................................................... 10 Risks of Specific Securities Utilized ......................................................................................................................... 11 Item 9 – Disciplinary Information ............................................................................................................................... 12 Item 10- Other Financial Industry Activities and Affiliations ...................................................................................... 13 Other Financial Industry Affiliations ....................................................................................................................... 13 Recommendation/Selection of Other Advisers ...................................................................................................... 13 Item 11- Code of Ethics ............................................................................................................................................... 13 Page 3 of 18  Code of Ethics Summary ......................................................................................................................................... 14 Personal Trading by Supervised Persons ................................................................................................................ 14 Item 12 – Brokerage Practices .................................................................................................................................... 14 Factors Used to Select and/or Recommend Broker/Dealers .................................................................................. 14 Research and Other Soft Dollar Benefits ................................................................................................................ 14 Brokerage for Client Referrals ................................................................................................................................ 14 Directed Brokerage ................................................................................................................................................. 15 Aggregating (Block) Trading for Multiple Client Accounts ...................................................................................... 15 Item 13 – Review of Accounts .................................................................................................................................... 15 Item 14 – Client Referrals and Other Compensation .................................................................................................. 15 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ...................................................................................................................................................................... 15 Compensation to Non-Advisory Personnel for Client Referrals ............................................................................. 16 Item 15 - Custody ........................................................................................................................................................ 17 Item 16 - Discretion .................................................................................................................................................... 17 Item 17 – Voting Client Securities ............................................................................................................................... 17 Item 18 – Financial Information .................................................................................................................................. 17 Balance Sheet .......................................................................................................................................................... 18 Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients .............. 18 Bankruptcy Petitions in Previous Ten Years ........................................................................................................... 18 Page 4 of 18  Item 4 – Advisory Business Description of the Advisory Firm AssuredPartners Investment Advisors, LLC (“APIA”) was organized and formed as a limited liability company under the laws of the State of Delaware on January 9, 2020, and is wholly owned through subsidiaries by Arthur J. Gallagher & Co, a publicly traded company (NYSE:AJG). Effective May 1, 2020, and pursuant to a succession by amendment, APIA became a successor to the investment advisory business of the predecessor registered investment adviser, AssuredPartners Financial Services, LLC (“APFS”). The succession transferred the advisory activities of APFS, formerly a dually registered broker-dealer and investment adviser entity, to APIA, an investment adviser registered with the SEC. APIA provides investment advisory services to individuals and entities as detailed in Item 7 (each a “client”). The nature and scope of APIA’s services will be described in an investment advisory agreement or similar document entered by APIA and the client. Types of Advisory Services Portfolio Management. APIA provides personalized portfolio management services to clients on a discretionary or non-discretionary basis pursuant to an investment advisory agreement. When a client grants us discretionary authority, we will select securities or third-party managers/strategists for a client’s portfolio and execute transactions or change managers for the client without prior permission from the client. If a client does not grant us discretionary authority, we will manage the client’s portfolio on an on-going and continuous basis but will obtain the client’s permission prior to entering orders for transactions in the client’s portfolio or making changes to third-party managers recommended for the client’s portfolio. When a client engages us to provide portfolio management services, we will gather information from the client and create an investment profile outlining the client’s current financial situation, investment objectives, time horizon, liquidity and other needs, and risk tolerance. We then construct a portfolio tailored to each client's investment profile. In constructing client portfolios, we will employ model portfolios or create a custom portfolio to meet the specific needs of the client. We continuously monitor the asset allocation within our model portfolios and rebalance client portfolios as needed. We also regularly evaluate the current investments of each client with respect to the client’s investment profile and update client portfolios as necessary if the client’s profile changes. As part of our portfolio management services, APIA may select or recommend the services of third-party investment advisers to manage all or a portion of a client’s portfolio. When a third-party investment adviser provides services to a client, the client may enter into a separate agreement with the third-party adviser and will be limited to investing in securities included in the third-party adviser’s investment strategies. APIA will monitor each third-party investment adviser for adherence to the stated strategy and portfolio performance but will have no control over the management of these portfolios. APIA may also refer clients to third-party investment advisers. Clients will, after such referral by APIA, enter into a separate advisory agreement with the third-party investment adviser and receive any required disclosures from the third-party investment adviser. APIA will not monitor the performance or strategy implemented by such third-party investment advisor. APIA will typically receive a fee from third-party advisers to which it refers clients. See Item 10, below. Page 5 of 18  When selecting, recommending, or referring clients to third party investment advisers, APIA will verify that the third-party advisers are properly registered, notice filed or exempt from registration. Clients are reminded to promptly inform us of any changes to their investment profile or if they wish to place any restrictions on the management of their portfolio. As noted below, APIA may agree to reasonable restrictions that do not interfere with our management of the client’s portfolio. is to seek fair and equitable allocation of In all cases, APIA provides investment decisions in accordance with the fiduciary duties owed to its clients and without consideration of our economic or other financial interests. To meet our fiduciary obligations, APIA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios. Accordingly, APIA’s policy investment opportunities/transactions among its clients to avoid favoring one client over another over time. Our policy is to allocate investment opportunities and transactions that we identify as appropriate and prudent among our clients on a fair and equitable basis over time. Financial Planning and Consulting APIA offers financial planning and consulting services which may include but are not limited to investment planning, estate planning guidance; life insurance, retirement planning, college planning, investment due diligence, and cash flow planning. Financial planning and consulting services may be offered as part of APIA’s portfolio management services or as a separate engagement depending on the client’s needs. Generally, financial planning services will include preparing a financial plan or providing consultation on one or more of the areas noted above. Clients are not obligated to implement the financial plan or other recommendations through APIA. Advisory Services for Employee Benefit Plan Clients and Plan Participants APIA provides ongoing investment advisory services to pension or other employee benefit plans, including but not limited to 401(k) plans, on a non-discretionary basis as an ERISA 3(21) fiduciary or on a discretionary basis as an ERISA 3(38) investment manager. We provide advice with respect to such matters as: (1) identifying with plan fiduciaries the plan’s investment objectives and restrictions; (2) recommending or selecting money managers to manage plan assets; (3) recommending, in the case of non-discretionary services, or selecting, in the case of discretionary services, investments (e.g. mutual funds, ETFs or other investment vehicles) available to plan participants; (4) monitoring performance of money managers and investments and making recommendations for changes; (5) advising on the selection of other service providers, such as record keeper, custodian, administrator and/or broker-dealer; and (6) providing participant financial education, including webinars, newsletters and, where requested, virtual or in person access to advisors. In addition, when providing discretionary services, APIA will select investments for the plan, replace and rebalance investments, and manage model portfolios, if any, available through the plan. APIA also offers on-going investment advisory services to plan participants and provides participants with the choice to have APIA manage their plan account. Participants who elect to have APIA manage their plan account must enter into an advisory agreement with APIA for this service. Depending on the engagement, we may manage the participant account on a discretionary or non-discretionary basis and may provide only one-time or periodic advice regarding the participant account with the participant remaining responsible for executing any transactions in their account. Page 6 of 18  Educational Workshops and Seminars APIA provides educational workshops and seminars for groups desiring general advice on investments and personal finance. Topics may include issues related to financial planning, educational and estate planning, or various other economic and investment topics. Information presented will not be personalized to any one person’s needs and APIA does not provide individualized investment advice to attendees during our general sessions. Services Limited to Specific Types of Investments When managing client portfolios, APIA generally limits its investment advice to mutual funds, fixed income securities, equities, ETFs, and treasury inflation protected/inflation linked bonds. However, we may use other securities when we determine they will help diversify a portfolio and when consistent with a client’s investment profile. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Because we will receive fees if you roll over your retirement assets to an account under our management, we have a financial incentive to recommend to a rollover to you. You always have other options and are never under any obligation to roll over retirement assets to an account managed by us. Client Tailored Services and Client Imposed Restrictions APIA will tailor its investment advisory services for each client by providing personalized recommendations based on the client’s investment profile. While APIA may use “model portfolios” when providing portfolio management services, we manage each client’s portfolio based on the client’s unique investment profile and in accordance with any reasonable restrictions imposed by the client. We will periodically contact our clients to determine whether there have been any changes in the client’s investment profile information and give the client the opportunity to impose or modify restrictions on the management of their portfolio. At any time, a client may impose reasonable restrictions on the management of their portfolio such as prohibiting the inclusion of certain types of securities or prohibiting the sales of certain securities held in the portfolio or modifying existing restrictions. Clients should be aware though that any restrictions they impose may adversely affect the performance of their portfolio and APIA may decline to accept such restrictions if we believe the restrictions will unreasonably interfere with our management of the client’s portfolio. Wrap Fee Programs A wrap fee program is an investment program in which the client pays one bundled fee that includes investment advisory fees and transaction costs. APIA does not participate in any wrap fee programs. Page 7 of 18  Assets Under Management As of December 2024, APIA manages client assets of $3,251,947,155 on a discretionary basis. In addition, APIA provides fiduciary advice to retirement plans with assets of $1,157,029,641. Item 5 – Fees and Compensation Fees for Portfolio Management Advisory Services. APIA’s annual advisory fee for portfolio management services is negotiable and is usually charged as a percentage of assets under our management. Each APIA office determines and negotiates is own fee arrangements in consultation with APIA’s executive officers and subject to a maximum annual fee rate of 2.5%. Our advisory fee varies based on the size of the client’s portfolio and household, requirements of the client, complexity of the investment advice, and nature and scope of the advisory relationship. The advisory fee is shared between APIA and its investment adviser representatives. In the case of clients using third-party investment advisors, APIA and the third-party adviser share the total advisory fee. In some cases, clients will sign a separate agreement with the third-party advisor setting forth that advisor’s fee. Please see additional disclosure in Item 10 - Selection of Other Advisers and Item 14 – Client Referrals and Other Compensation. Our fee is described in the advisory agreement and clients should carefully review the fee information. APIA or the client may terminate the advisory agreement with written notice to the other and APIA may amend the agreement with written notice to the client. As indicated below, the advisory fee does not include brokerage commissions, transaction fees, mutual fund fees, and other related costs and expenses which shall be separately charged to the client by the broker-dealer or custodian. Asset-based portfolio management fees are typically withdrawn directly from the client’s account with the client’s written authorization or, in limited cases, may be invoiced and billed directly to the client on a periodic basis. Fees are paid monthly or quarterly in advance or in arrears as specified in the advisory agreement with each client. Financial Planning and Consulting Fees APIA’s fee for financial planning and consulting is negotiable and is charged as a fixed annual fee or an hourly rate. The fixed annual fee for financial planning and consulting is between $500 and $20,000. The client will be provided an initial estimate but should be aware that the initial estimate may change depending on the scope and complexity of the engagement. The client will be notified of any changes to the total fee in writing prior to completion of the engagement. The hourly rate for financial planning and consulting services is up to $250 per hour. The length of time it will take to complete the advisory service will depend on the nature and complexity of the client’s personal circumstances. An estimate for total hours will be determined at the start of the advisory relationship. Financial planning and consulting fees are invoiced and billed directly to the client to be paid monthly or quarterly in advance or in arrears as specified in the advisory agreement. Typically, a portion of the fee is due upon inception of the advisory relationship, with the balance payable upon completion of the services or in periodic installments. Page 8 of 18  Fees for Employee Benefit Plan Advisory Services. APIA’s annual advisory fee for retirement plan advisory services is negotiated on a client-by-client basis depending on the services to be provided. The negotiated fee will be described in the advisory agreement. The fee is typically either a percentage of total plan assets or a flat annual fee or a combination of the two. APIA or the client may terminate the agreement with written notice to the other and APIA may amend the agreement with written notice to the client. Asset-based and annual flat fees are either withdrawn directly from the plan assets at the record keeper and/or custodian with client's written authorization or are invoiced and billed directly to the client. Asset-based fees will be paid monthly or quarterly in advance or in arrears as specified in the Agreement or pursuant to the Client’s instructions to the recordkeeper. Flat fees will typically be assessed quarterly on the last day of the calendar quarter or as specified in the Agreement. Client Responsibility for Third-Party Fees Clients are responsible for the payment of all third-party fees such as custodian fees, brokerage fees, mutual fund fees, and transaction fees. These fees are separate and distinct from the fees charged by APIA. Advance Payment of Fees and Refunds In some cases, APIA collects fees in advance but will not collect fees more than six months in advance of providing services. Refunds for fees paid in advance will be promptly returned to the client via ACH, wire transfer, or return deposit back into the client’s account. When an advisory agreement is terminated before the end of a billing period, APIA will refund asset-based fees collected in advance based on the balance of the fees collected in advance minus the daily rate times the number of days elapsed in the billing period up to and including the day of termination. The daily rate is calculated by dividing the annual asset-based fee rate by 365. Similarly, APIA will refund fixed and hourly fees collected in advance based on the prorated amount of work completed at the point of termination. Outside Compensation for the Sale of Investment Products to Clients As further described in Item 10 below, certain supervised persons of APIA are licensed insurance agents and broker- dealer representatives. In these separate capacities, those persons receive commission compensation for the sale of insurance and securities products to clients of APIA except that supervised persons will not receive commission compensation for securities transactions in an advisory account. This presents a conflict of interest and gives supervised persons an incentive to recommend products based on the commission compensation they will receive rather than on the client’s needs. When a supervised person recommends products for which they will receive commission compensation, APIA and/or the supervised person will inform the client of the compensation and resulting conflict of interest. Clients always have the right to decide whether to purchase recommended products and have the right to purchase those products through other agents or representatives that are not affiliated with APIA. Item 6 – Performance-Based Fees and Side-by-Side Management APIA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Page 9 of 18  Item 7 – Types of Clients APIA provides advisory services to individuals, trusts, charitable organizations, pension and profit-sharing plans, and corporations or business entities. Item 8 - Methods of Analysis and Investment Strategies Methods of Analysis and Investment Strategies APIA’s methods of analysis include fundamental analysis, technical analysis, and modern portfolio theory. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. In general, APIA uses a long-term investment approach guided by the client’s goals, objectives, time horizon, and risk tolerance. INVESTING IN SECURITIES INVOLVES A RISK OF LOSS THAT YOU, AS A CLIENT, SHOULD BE PREPARED TO BEAR. Material Risks Involved Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Long-term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during Page 10 of 18  the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Concentrated portfolios are an aggressive and highly volatile approach to trading and investing. Concentrated portfolios hold fewer different stocks than a diversified portfolio and are much more likely to experience sudden dramatic prices swings. In addition, the rise or drop in price of any given holding is likely to have a larger impact on portfolio performance, than a more broadly diversified portfolio. Selection of Other Advisers: Although APIA will seek to select only money managers who will invest clients' assets with the highest level of integrity, APIA's selection process cannot ensure that money managers will perform as desired, and APIA will have no control over the day-to-day operations of any of its selected money managers. APIA would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breach or fraud. In monitoring and analyzing the third-party advisers, APIA uses benchmarking analysis, assessing whether the adviser’s performance has met, exceeded, or fallen short of comparable benchmarks (e.g., Russell 2000, S&P 500, etc.), together with comparison against any stated benchmarks the adviser has set for itself. Model portfolios are designed to capture return and risk at market rates. This seeks to provide clients with diversification benefits to help smooth returns, reduce volatility and decrease asset-class and single-strategy risks. Risks specific to using model portfolios include the possibility that the model portfolio will underperform the market and the possibility that the model will not be able take advantage of opportunities that a non-model portfolio management approach might capture. Model portfolios entail inflation (purchasing power) risk, interest rate risk, economic risk, market risk, political/regulatory risk, and asset allocation risk – meaning that any given asset allocation strategy does not guarantee any specific result or profit nor protect against a loss. INVESTING IN SECURITIES INVOLVES A RISK OF LOSS THAT YOU, AS A CLIENT, SHOULD BE PREPARED TO BEAR. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature or both. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and/or the general economic environment. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); Page 11 of 18  however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long- range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Real Estate funds (including REITs) face several types of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Derivatives gain their value from another instrument and therefore can result in large losses because of the use of leverage or borrowing. Derivatives allow investors to earn large returns from small movements in the underlying asset's price. However, investors could lose large amounts if the price of the underlying moves against them significantly. PAST PERFORMANCE IS NOT INDICATIVE OF FUTURE RESULTS. INVESTING IN SECURITIES INVOLVES A RISK OF LOSS THAT YOU, AS A CLIENT, SHOULD BE PREPARED TO BEAR. Item 9 – Disciplinary Information APIA is required to disclose any legal or disciplinary events that would be material to a client’s evaluation of its advisory business or the integrity of its management. Neither APIA nor its management persons have been involved in a criminal or civil action, administrative proceeding, self-regulatory proceeding, or other legal or disciplinary event that is material to a client’s evaluation of its advisory business or the integrity of its management. Page 12 of 18  Item 10- Other Financial Industry Activities and Affiliations Other Financial Industry Affiliations While APIA itself is not registered as broker-dealer and does not have an application pending as a broker-dealer, it is under common control with AssuredPartners Financial Services, LLC (APFS) which is a registered broker-dealer (CRD #304454). Both APIA and APFS are direct subsidiaries of AssuredPartners Capital, Inc. APIA is also affiliated with other investment adviser firms and broker-dealer firms under the ownership of Arthur J. Gallagher & Co. Neither APFS nor the broker-dealer firms under Gallagher’s ownership provide any services to APIA investment advisory clients. In addition, as described below, certain of APIA’s supervised persons are registered representatives of unaffiliated broker-dealer firms. Neither APIA nor its management persons are registered as or have pending applications to become a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. APIA is under common control with various insurance agencies. Other than being under common control with these insurance agencies, APIA does not have any direct relationship or arrangement with any insurance company or agency. Under the business name of Benefits Plus, APIA provides third party administrator (TPA) services to retirement plans including plans that are advisory clients of APIA. APIA receives compensation for its TPA services that is separate and in addition to its fees for investment advisory services. This is a conflict of interest since APIA receives additional compensation if selected as the TPA for the plan client. A supervised person of APIA is an accountant and realtor although does not provide accounting or real estate services through APIA. In addition, certain supervised persons of APIA are licensed insurance agents and registered representatives of broker-dealers not affiliated with APIA. These persons will, from time to time, recommend and sell insurance and securities products to advisory clients in these separate capacities. Clients should be aware that these separate services pay commission compensation which provides an incentive for the supervised persons to recommend products based on the commissions they will receive rather than the needs of the client. Our supervised persons will disclose the capacity in which they are acting, how they are compensated, and conflicts of interest related to any advice or service provided. No client is ever under any obligation to purchase any insurance or securities product from a supervised person acting in their separate capacity. Clients may obtain products recommended by APIA’s supervised persons from other persons on more favorable terms. Recommendation/Selection of Other Advisers APIA recommends or selects third party advisors for its clients and, in some cases, we receive a referral fee from the third party advisor. While we will only recommend a third-party advisor if we believe their services are in the best interest of our client, we only recommend those advisors with which we have a relationship and there may be other third-party advisors that may charge lower fees to clients. Item 11- Code of Ethics Page 13 of 18  Code of Ethics Summary APIA has a written Code of Ethics that embodies the fiduciary duty that APIA owes to its clients as an investment adviser and sets forth the ideals for ethical conduct in the performance of our advisory services. APIA strives to maintain the highest standards of ethics in all of its business relationships. Because corporate behavior begins with the individual behavior of its personnel, APIA’s Code instructs its supervised persons on the individual ethical, legal, and moral standards expected of them. Our Code requires that we along with our supervised persons comply with both the letter and the spirit of the laws that apply to our investment advisory operations, provide advisory services with integrity and competence, and avoid conflicts of interest whenever possible. Specific provisions in our Code place limitations on giving and receiving gifts, providing or accepting entertainment, borrowing money from or loaning money to a client, and require certain of our supervised persons to report their personal securities transactions and holdings. Clients and prospective clients may request a copy of APIA’s Code of Ethics by calling 407-815-6774 or emailing apiacompliance@apadvisors.com. Personal Trading by Supervised Persons To avoid conflicts with recommendations made to our clients and to prevent unethical or unlawful trading activity, APIA’s Code of Ethics requires that certain of our supervised persons report their personal holdings and transactions in some types of securities and requires that APIA review of those reports for inappropriate activity. In some cases, those persons must obtain prior approval from APIA before engaging in particular securities transactions. APIA permits supervised persons to trade in the same securities for their own accounts that they recommend, buy, or sell for clients; however, supervised persons are not permitted to trade in any manner that places their interest before a client or that disadvantages any client. Moreover, supervised persons may not engage in any trading activity that benefits them or others to the detriment of any client. Item 12 – Brokerage Practices Factors Used to Select and/or Recommend Broker/Dealers APIA will recommend certain broker-dealers to clients to maintain custody of the clients’ accounts and to effect trades in their accounts. We recommend these broker-dealers based on our duty to seek “best execution” of client transactions which is the obligation to seek execution of securities transactions for a client on the most favorable overall terms for the client under the circumstances. This does not mean that clients will pay the lowest commission or commission equivalent but that the client’s total cost is the most favorable under the circumstances. In evaluating total cost, APIA may consider the market expertise and research access provided by the broker-dealer, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in APIA's research efforts. Research and Other Soft Dollar Benefits APIA does not receive products or services other than execution (“soft dollar benefits”) from a broker-dealer or third-party for generating commissions but does receive additional economic benefits described in Item 14. Brokerage for Client Referrals APIA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Page 14 of 18  Directed Brokerage We routinely require that clients direct us to execute transactions through broker-dealers we recommend to our clients although we are not affiliated with any of those broker-dealers. Not all advisers require their clients to direct use of a particular broker-dealer. We generally do not permit clients to direct transactions to a particular broker- dealer outside of our recommendations. If APIA does permit a client to direct brokerage, then this may result in higher commissions, which may result in a disparity between non-directed and directed accounts; the client may be unable to participate in block trades (unless APIA is able to engage in “step outs”); and trades for the client and other directed accounts may be executed after trades for non-directed accounts. This may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. Aggregating (Block) Trading for Multiple Client Accounts If APIA buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, APIA would place an aggregate order with the broker on behalf of all such clients to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. Item 13 – Review of Accounts APIA’s investment adviser representatives review accounts of portfolio management clients at least annually. Representatives will review accounts to assess consistency with the clients’ respective investment profiles. Representatives review financial plans upon plan creation and delivery to the client. Additional reviews may be triggered by material market, economic or political events, or by changes in a client’s financial situation (such as retirement, termination of employment, marriage, divorce, or inheritance). It is very important for clients to notify us of such changes. At least quarterly, the custodians of client accounts provide statements to clients reflecting the positions including current pricing as well as transactions and fees paid in the account. Account custodians will also provide confirmations of trading activity. Clients may receive these statements and confirmations electronically from the custodians. Item 14 – Client Referrals and Other Compensation Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) APIA participates in the advisor programs (the "Programs") offered by the broker-dealers, custodians, and third- party portfolios managers it recommends to its clients. While there is no direct link between APIA's participation in the Programs and the investment advice it gives to its clients, APIA receives economic benefits through its participation in the Programs that are typically not available to retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate client statements and Page 15 of 18  confirmations; research related products and tools; consulting services; access to a trading desk serving APIA participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to client accounts); the ability to have APIA's fees deducted directly from client accounts; access to an electronic communications network for client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to APIA by third-party vendors. The broker-dealers and custodians may also pay for business consulting and professional services received by APIA's related persons. Some of the products and services made available through the Programs may benefit APIA but may not benefit its client accounts. These products or services may assist APIA in managing and administering client accounts, including accounts not maintained at the broker-dealers or custodians. Other services made available through the Programs are intended to help APIA manage and further develop its business enterprise. The benefits received by APIA or its personnel through participation in the Programs do not depend on the amount of brokerage transactions directed to the broker-dealers, but APIA may be required to maintain a minimum amount of its client assets at the broker-dealer to receive the Program benefits. As part of its fiduciary duties to clients, APIA endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by APIA or its related persons in and of itself creates a conflict of interest and may indirectly influence the APIA's choice of the broker-dealer or custodian for custody and brokerage services. APIA may also, from time to time, receive expense reimbursement for travel and/or marketing expenses from distributors of investment and/or insurance products. Travel expense reimbursements are typically a result of attendance at due diligence and/or investment training events hosted by product sponsors. Marketing expense reimbursements are typically the result of informal expense sharing arrangements in which product sponsors may underwrite costs incurred for marketing such as client appreciation events, advertising, publishing, and seminar expenses. Although receipt of these travel and marketing expense reimbursements are not predicated upon specific sales quotas, the product sponsor reimbursements are typically made by those sponsors for which sales have been made or for which it is anticipated sales will be made. This creates a conflict of interest in that there is an incentive to recommend certain products and investments based on the receipt of this compensation instead of what is in the best interest of our clients. We attempt to control for this conflict by always basing investment decisions on the individual needs of our clients. In addition, as detailed in Item 4, APIA uses third-party investment advisers to manage individual client portfolios or provide services to employee benefit plan clients. APIA receives economic benefits from referring client to such providers. Specifically, APIA receives a portion of the advisory fees collected by such third-party investment advisers. Clients should be aware that the receipt of economic benefits by APIA or its related persons in and of itself creates a conflict of interest and may indirectly influence the APIA’s recommendation of third-party investment advisers. APIA attempts to control this conflict by basing investment advice on the needs of individual clients, without regard to possible referral fees. Compensation to Non-Advisory Personnel for Client Referrals APIA compensates other persons (“promoters”) for referring prospective clients to APIA but does so in accordance with the requirements of state and federal securities laws. APIA will pay promoters a portion of its advisory fee although the referred client shall not be charged higher fees as a result of the referral. If APIA receives a referral from a person who it not affiliated with APIA, then the client will be informed of the terms of the referral fee and any conflicts of interest related to the referral arrangement. Page 16 of 18  Item 15 - Custody When APIA’s advisory fee is deducted from client accounts at a qualified custodian upon our instruction to the custodian, APIA will be deemed under state and federal securities laws to have custody of client assets. In these cases, we will have written authorization from the client to deduct our advisory fee from their account held by a qualified custodian. In addition, we will verify that the qualified custodian sends an account statement to the client at least quarterly. Clients should carefully and promptly review these statements and compare them with any statements they receive from APIA. APIA is also deemed to have custody because certain clients have granted APIA with standing authority to instruct their account custodian to make transfers from their account to a third party. In these cases, APIA adheres to safeguards imposed by the SEC which require that: 1) the client provide specific written instructions to the custodian for the authority, 2) the client authorize APIA to direct transfers to the third-party, 3) the custodian verifies the instruction and promptly notifies the client after each disbursement, 4) the client has the ability to change the authorization at any time, 5) APIA does not have any ability to change any information about third party, 6) APIA keeps records showing the third party is not related to APIA and does not have the same address as APIA, and 7) the custodian sends the client an initial and annual notice of the authority. Item 16 - Discretion APIA provides both discretionary and non-discretionary investment advisory services to clients. The Agreement established with each client sets forth the discretionary authority, if any, granted by the client to APIA. When a client grants investment discretion to APIA, then APIA generally manages the client’s account and makes investment decisions without consultation with the client as to when securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, and/or the manager/strategist for the client’s portfolio. In some instances, APIA’s discretionary authority in making these determinations may be limited by conditions imposed by a client in investment guidelines or objectives, or other instructions a client provides to APIA. Item 17 – Voting Client Securities APIA will accept authority to vote client securities when requested by a client. APIA has proxy voting policies and procedures that require it to vote in the best interest of the client holding the applicable securities. When exercising its proxy voting authority, APIA considers factors that it believes relate to the client’s investments and factors, if any, that are forth in written instructions from the client. If we perceive a conflict of interest, we will notify affected clients so that they may choose the course of action that they deem most appropriate. We will provide our complete proxy voting policies and procedures as well as a record of how we voted a client’s securities upon request from a client. Item 18 – Financial Information Page 17 of 18  Balance Sheet APIA neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither APIA nor its management has any financial condition that is likely to reasonably impair the firm’s ability to meet contractual commitments to clients. Bankruptcy Petitions in Previous Ten Years APIA has not been the subject of a bankruptcy petition in the last ten years. Page 18 of 18