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Part 2A of Form ADV: Firm Brochure
Attentive Investments, LLC
5345 N. El Dorado St.
Suite 5
Stockton, CA 95207
Telephone: 209-636-4931
Facsimile: 209-370-9095
Email: athena@attentiveinv.com
Web Address: www.attentiveinv.com
February 12, 2026
This brochure provides information about the qualifications and business practices of Attentive
Investments, LLC. If you have any questions about the contents of this brochure, please contact us at
209-636-4931 or athena@attentiveinv.com. The information in this brochure has not been approved or
verified by any State Securities Authority or the United States Securities and Exchange Commission.
Additional information about Attentive Investments, LLC 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 firm's CRD number is 315478.
Registration as an investment adviser does not imply a certain level of skill or training.
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Item 2 Material Changes
This Firm Brochure is our disclosure document prepared according to the requirements and rules.
Consistent with the rules, we will ensure that you receive a summary of any material changes to this
and subsequent Brochures within 120 days of the close of our business’ fiscal year. Furthermore, we
will provide you with other interim disclosures about material changes as necessary.
Since our last annual filing on March 18, 2025, Attentive Investments, LLC. has not made any material
amendments.
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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
Item 3
Table of Contents
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
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Item 4 Advisory Business
Attentive Investments, LLC is a SEC registered investment adviser with its principal place of business
located in Stockton, CA. Attentive Investments, LLC began conducting business in 2021 and prior to
that doing business as Attentive Investment Managers, Inc. conducting business since 2004.
Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling
25% or more of this company).
• Athena K. Stone, President and Chief Compliance Officer
Attentive Investments, LLC offers the following advisory services to our clients:
INVESTMENT SUPERVISORY SERVICES ("ISS")
INDIVIDUAL PORTFOLIO MANAGEMENT
Our firm provides continuous advice to a client regarding the investment of client funds based on the
individual needs of the client. Through personal discussions in which goals and objectives, based on a
client's particular circumstances, are established we create and manage a portfolio. During our data-
gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and
liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well
as family composition and background.
We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision
is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or
growth and income), as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of securities, or
industry sectors.
Our investment recommendations are not limited to any specific product or service offered by a broker-
dealer or insurance company and will generally include advice regarding the following securities:
• Exchange-listed securities
• Securities traded over-the-counter
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States governmental securities
Because some types of investments involve certain additional degrees of risk, they will only be
implemented/recommended when consistent with the client's stated investment objectives, tolerance for
risk, liquidity and suitability.
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FINANCIAL PLANNING
We provide 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 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 client's current
income tax and future tax liability.
INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio.
•
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INSURANCE: We review existing policies to ensure proper coverage for life, health, disability,
long-term care, liability, home and automobile.
• 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 client's 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 client's
discretion.
We also provide general non-securities advice on topics that may include tax and budgetary planning,
estate planning and business planning.
• Exchange-listed securities
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• Securities traded over-the-counter
• Foreign issuers
• Corporate debt securities (other than commercial paper)
• Certificates of deposit
• Municipal securities
• Variable life insurance
• Variable annuities
• Mutual fund shares
• United States governmental securities
Typically the financial plan is presented to the client within six months of the contract date, provided
that all information needed to prepare the financial plan has been promptly provided.
Financial Planning recommendations are not limited to any specific product or service offered by a
broker-dealer or insurance company. All recommendations are of a generic nature.
AMOUNT OF MANAGED ASSETS
As of December 31, 2025, Attentive Investments, LLC has $197,494,206 in assets under management,
of which $189,486,618 were managed on a discretionary basis and $8,007,588 were managed on a non-
discretionary basis.
Item 5
Fees and Compensation
INVESTMENT SUPERVISORY SERVICES
INDIVIDUAL PORTFOLIO MANAGEMENT FEES
Fees for investment supervisory services are charged based on the value of the invested assets held in
clients’ accounts. Accounts with a value of less than $50,000 are billed a management fee of 1% of the
invested net asset value of the account annually based on the quarter nearest to the anniversary date the
client’s account was opened, payable in arrears. Accounts with a value of $50,000 and more are billed
at the end of each calendar quarter, calculated on the value of assets under management as of the last
day of the calendar quarter. Fees are based on the following schedule:
Account Value
On the first $500,000
On the next $500,000
On amounts over $1,000,000
Annual Fee
1.00%
0.75%
0.50%
There is no charge for Certificates of Deposit or cash held within the account.
Fees may be negotiable under certain circumstances.
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Clients or the Firm may terminate on 10 days written notice. Upon termination, fees will be prorated to
the date of termination.
Our fees are billed in arrears at the end of each calendar quarter based upon the value (market value or
fair market value in the absence of market value), of the client's account at the end of the previous
quarter. Fees will be debited from the account in accordance with the client authorization in the Client
Services Agreement.
Limited Negotiability of Advisory Fees: Although Attentive Investments, LLC 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 will be 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 will be identified in the contract between the adviser and each client.
We may group certain related client accounts for the purposes of achieving the minimum account size
requirements and determining the annualized fee.
Discounts, not generally available to our advisory clients, may be offered to family members and
friends of associated persons of our firm.
Attentive Investments, LLC (“Attentive”) provides financial planning services in addition to
discretionary and non-discretionary investment management services.
Attentive provides individualized investment service to every client. Varying differences in age,
income and risk tolerance all affect the recommendations. Recommendations are also based upon
communication, education, information, client feedback and input.
FINANCIAL PLANNING FEES
Attentive Investments, LLC's Financial Planning fee will be 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.
Financial planning services are charged on an hourly basis according to the following schedule:
Certified Financial Planner
Clerical Associate
$250.00 per hour
$102.50 per hour
Although the length of time it will take to provide a Financial Plan will depend on each client's
personal situation, we will provide an estimate for the total hours at the start of the advisory
relationship. The client will be billed upon completion of the plan and quarterly thereafter in arrears
based on actual hours accrued.
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An invoice for financial planning services is issued on completion of the written analysis. The invoice
is payable on receipt. Clients may terminate the Financial Planning Agreement, without penalty, at any
time on written notice. Upon termination, any fees will be prorated to the date of termination.
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 10 days written notice. As disclosed above, no fees are paid or
billed in advance of services provided.
Mutual Fund Fees: All fees paid to Attentive Investments, LLC 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 fund's prospectus. These fees will
generally include a management fee, other fund expenses, and a possible distribution fee. 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 client's 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.
Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the
fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to,
any transaction charges imposed by a broker dealer with which an independent investment manager
effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item
12) of this Form ADV for additional information.
Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to
Attentive Investments, LLC's minimum account requirements and advisory fees in effect at the time the
client entered into the advisory relationship. Therefore, our firm's minimum account requirements will
differ among clients.
Advisory Fees in General: Clients should note that similar advisory services may (or may not) be
available from other registered (or unregistered) investment advisers for similar or lower fees.
Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in
excess of $1,200 more than six months in advance of services rendered.
Item 6
Performance-Based Fees and Side-By-Side Management
Attentive Investments, LLC does not charge performance-based fees.
Item 7 Types of Clients
Attentive Investments, LLC provides advisory services to the following types of clients:
• Individuals (other than high net worth individuals)
• High net worth individuals
• Pension and profit sharing plans(other than plan participants)
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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.
Technical Analysis. We analyze past market movements and apply that analysis to the present in an
attempt to recognize recurring patterns of investor behavior and potentially predict future price
movement.
Technical analysis does not consider the underlying financial condition of a company. This presents a
risk in that a poorly-managed or financially unsound company may underperform regardless of market
movement.
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 strategies in managing client accounts, provided that such strategy(ies) are
appropriate to the needs of the client and consistent with the client's investment objectives, risk
tolerance, and time horizons, among other considerations:
Long-term purchases. We purchase securities with the idea of holding them in the client's 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.
A risk in a long-term purchase strategy is that by holding the security for this length of time, we may
not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions
are incorrect, a security may decline sharply in value before we make the decision to sell.
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.
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A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are
then left with the option of having a long-term investment in a security that was designed to be a short-
term purchase, or potentially taking a loss.
In addition, this strategy involves more frequent trading than does a longer-term strategy, and will
result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment
of short-term capital gains.
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.
Utilizing a trading strategy creates the potential for sudden losses if the anticipated price swing does
not materialize. Moreover, under those circumstances, we are left with few options:
• having a long-term investment in a security that was designed to be a short-term purchase, or
the potential of having to taking a loss.
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In addition, because this strategy involves more frequent trading than does a longer-term strategy, there
will be a resultant increase in brokerage and other transaction-related costs, as well as less favorable tax
treatment of short-term capital gains.
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.
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 client's or prospective
client's 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
Our firm and our related persons are not engaged in other financial industry activities and have no other
industry affiliations.
Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that
we require of our employees, including compliance with applicable federal securities laws.
Attentive Investments, LLC and our personnel owe a duty of loyalty, fairness and good faith towards
our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics
but to the general principles that guide the Code.
Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions
reports as well as initial and annual securities holdings reports that must be submitted by the firm’s
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access persons. Among other things, our Code of Ethics also requires the prior approval of any
acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our
code also provides for oversight, enforcement and recordkeeping provisions.
Attentive Investments, LLC's Code of Ethics further includes the firm's policy prohibiting the use of
material non-public information. While we do not believe that we have any particular access to non-
public information, all employees are reminded that such information may not be used in a personal or
professional capacity.
A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may
request a copy by email sent to athena@attentiveinv.com, or by calling us at 209-636-4931.
Attentive Investments, LLC and individuals associated with our firm are prohibited from engaging in
principal or agency cross transactions.
Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests
of our employees will not interfere with (i) making decisions in the best interest of advisory clients and
(ii) implementing such decisions while, at the same time, allowing employees to invest for their own
accounts.
Our firm and/or individuals associated with our firm may buy or sell for their personal accounts
securities identical to or different from those recommended to our clients. In addition, any related
person(s) may have an interest or position in a certain security(ies) which may also be recommended to
a client.
It is the expressed policy of our firm that no person employed by us may purchase or sell any security
prior to a transaction(s) being implemented for an advisory account, thereby preventing such
employee(s) from benefiting from transactions placed on behalf of advisory accounts.
We may aggregate our employee trades with client transactions where possible and when compliant
with our duty to seek best execution for our clients. In these instances, participating clients will receive
an average share price and transaction costs will be shared equally and on a pro-rata basis. In the
instances where there is a partial fill of a particular batched order, we will allocate all purchases pro-
rata, with each account paying the average price. Our employee accounts will be included in the pro-
rata allocation.
1. As these situations represent actual or potential conflicts of interest to our clients, we have
established the following policies and procedures for implementing our firm’s Code of Ethics,
to ensure our firm complies with its regulatory obligations and provides our clients and
potential clients with full and fair disclosure of such conflicts of interest:
2. No principal or employee of our firm may put his or her own interest above the interest of an
advisory client.
3. No principal or employee of our firm may buy or sell securities for their personal portfolio(s)
where their decision is a result of information received as a result of his or her employment
unless the information is also available to the investing public.
4. It is the expressed policy of our firm that no person employed by us may purchase or sell any
security prior to a transaction(s) being implemented for an advisory account. This prevents such
employees from benefiting from transactions placed on behalf of advisory accounts.
5. Our firm requires prior approval for any IPO or private placement investments by related
persons of the firm.
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6. We maintain a list of all reportable securities holdings for our firm and anyone associated with
this advisory practice that has access to advisory recommendations ("access person"). These
holdings are reviewed on a regular basis by our firm's Chief Compliance Officer or his/her
designee.
7. We have established procedures for the maintenance of all required books and records.
8. Clients can decline to implement any advice rendered, except in situations where our firm is
granted discretionary authority.
9. All of our principals and employees must act in accordance with all applicable Federal and
State regulations governing registered investment advisory practices.
10. We require delivery and acknowledgement of the Code of Ethics by each supervised person of
our firm.
11. We have established policies requiring the reporting of Code of Ethics violations to our senior
management.
12. Any individual who violates any of the above restrictions may be subject to termination.
Item 12 Brokerage Practices
Attentive Investments, LLC does not have any soft-dollar arrangements and does not receive any soft-
dollar benefits.
Attentive Investments, LLC 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 client 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 may allow us to execute equity trades in a timelier, more equitable manner, at an average
share price. Attentive Investments, LLC will typically aggregate trades among clients whose accounts
can be traded at Schwab. Attentive Investments, LLC's 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 client's advisory agreement with Attentive Investments,
LLC, or our firm's 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 client's
investment objectives and with any investment guidelines or restrictions applicable to the
client's account.
3) The portfolio manager must reasonably believe that the order aggregation will benefit, and will
enable Attentive Investments, LLC 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 "20-20 hindsight" perspective. Best
execution includes the duty to seek the best quality of execution, as well as the best net price.
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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 client's 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) Attentive Investments, LLC's 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 Attentive Investments,
LLC's 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.
Attentive Investments, LLC participates in the institutional customer program offered through Schwab
Advisor Services, a division of Charles Schwab & Co., Inc. (“Schwab”). Schwab is an unaffiliated
SEC-registered broker-dealer and FINRA member. Schwab offers services to independent investment
advisers which include custody of securities, trade execution, clearance and settlement of transactions.
Attentive Investments, LLC receives some benefits from Schwab through our participation in the
program.
Attentive Investments, LLC participates in Schwab's Institutional customer program and we
recommend Schwab to our clients for custody and brokerage services. There is no direct link between
our firm's participation in the program and the investment advice we give to our clients, although we
receive economic benefits through our participation in the program that are typically not available to
Schwab retail investors.
These benefits include the following products and services (provided without cost or at a discount):
duplicate client statements and confirmations; research related products and tools; consulting services ;
access to a trading desk serving adviser 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 advisory 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
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to Attentive Investments, LLC by third party vendors. Schwab may also pay for business consulting
and professional services received by Attentive Investments, LLC's related persons and may also pay or
reimburse expenses (including meals [and entertainment] expenses) for Attentive Investments, LLC's
personnel to attend conferences or meetings relating to the program or to Schwab’s adviser custody and
brokerage services generally.
Some of the products and services made available by Schwab through the program may benefit
Attentive Investments, LLC but may not benefit our client accounts. These products or services may
assist us in managing and administering client accounts, including accounts not maintained at Schwab.
Other services made available by Schwab are intended to help us manage and further develop our
business enterprise. The benefits received by Attentive Investments, LLC or our personnel through
participation in the program do not depend on the amount of brokerage transactions directed to
Schwab. Clients should be aware, however, that the receipt of economic benefits by Attentive
Investments, LLC or our related persons in and of itself creates a potential conflict of interest and may
indirectly influence our choice of Schwab for custody and brokerage services.
Attentive Investments, LLC also receives from Schwab certain additional economic benefits
("Additional Services") that may or may not be offered to any other independent investment advisers
participating in the program. Specifically, the Additional Services include discounts for services from
affiliated vendors such as Morningstar, Portfolio Director and various other financial planning tools
and software. Schwab provides the Additional Services to our firm in its sole discretion and at its own
expense, and Attentive Investments, LLC does not pay any fees to Schwab for the Additional Services.
Attentive Investments, LLC and Schwab have entered into a separate agreement ("Additional Services
Addendum") to govern the terms of the provision of the Additional Services.
Attentive Investments, LLC's receipt of Additional Services raises potential conflicts of interest. In
providing Additional Services to our firm, Schwab most likely considers the amount and profitability to
Schwab of the assets in, and trades placed for, our client accounts maintained with Schwab. Schwab
has the right to terminate the Additional Services Addendum with Attentive Investments, LLC, in its
sole discretion, provided certain conditions are met. Consequently, in order to continue to obtain the
Additional Services from Schwab, we may have an incentive to recommend to our clients that the
assets under management by us be held in custody with Schwab and to place transactions for client
accounts with Schwab.
Attentive Investments, LLC's receipt of Additional Services does not diminish our duty to act in the
best interests of our clients, including seeking best execution of trades for client accounts.
Item 13 Review of Accounts
INVESTMENT SUPERVISORY SERVICES
INDIVIDUAL PORTFOLIO MANAGEMENT
REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts
are continually monitored, these accounts are reviewed at least quarterly and monthly or as needed
based upon financial market conditions. Accounts are reviewed in the context of each client's stated
investment objectives and guidelines. More frequent reviews may be triggered by material changes in
variables such as the client's individual circumstances, or the market, political or economic
environment.
These accounts are reviewed by: Athena K. Stone
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REPORTS: In addition to the monthly statements and confirmations of transactions that clients receive
from their broker-dealer, we provide quarterly reports summarizing account performance, balances and
holdings.
FINANCIAL PLANNING SERVICES
REVIEWS: While reviews may occur at different stages depending on the nature and terms of the
specific engagement, typically no formal reviews will be conducted for Financial Planning clients
unless otherwise contracted for.
REPORTS: Financial Planning clients will receive a completed financial plan. Additional reports will
not typically be provided unless otherwise contracted for.
All accounts are reviewed periodically by Mrs. Stone for overall adherence with the
investment philosophy employed by Attentive and any specific requirements of the
client. Account holdings will also be reviewed at any time changing market conditions
warrant.
Item 14 Client Referrals and Other Compensation
CLIENT REFERRALS
It is Attentive Investments, LLC's policy not to engage solicitors or to pay related or non-related
persons for referring potential clients to our firm.
It is Attentive Investments, LLC's policy not to accept or allow our related persons to accept any form
of compensation, including cash, sales awards or other prizes, from a non-client in conjunction with the
advisory services we provide to our clients.
Item 15 Custody
Our firm does not have actual custody of client accounts. We previously disclosed in the "Fees and
Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from
client accounts.
As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted
from that client's 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.
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 client's account without contacting the client prior to each trade to obtain the client's 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
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may limit this authority by giving us written instructions. Clients may also change/amend such
limitations by once again providing us with written instructions.
Item 17 Voting Client Securities
As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm
may provide investment advisory services relative to client investment assets, clients maintain
exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities
beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers,
acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s
investment assets. Clients are responsible for instructing each custodian of the assets, to forward to the
client copies of all proxies and shareholder communications relating to the client’s investment assets.
We do not offer any consulting assistance regarding proxy issues to clients.
Item 18 Financial Information
Attentive Investments, LLC has no additional financial circumstances to report.
Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more
than six months in advance of services rendered. Therefore, we are not required to include a financial
statement.
Attentive Investments, LLC has not been the subject of a bankruptcy petition at any time during the
past ten years.
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