AUERBACH INVESTMENT SERVICES, LLC

Auerbach Investment Services, LLC 207 Avon Road Narberth, Pa 19072 Phone: (610) 529-3000 www.auerbachinvestment.com March 26, 2026 FORM ADV PART 2A BROCHURE Form ADV, Part 2; our "Disclosure Brochure" or "Brochure" as required by the Investment Advisers Act of 1940 is a very important document between our clients and Auerbach Investment Services, LLC. This brochure provides information about the qualifications and business practices of Auerbach Investment Services, LLC. If you have any questions about the contents of this brochure, please contact Kevin Auerbach, Chief Compliance Officer at 610-529-3000, or kevin@auerbachinvestment.com. The information in this Brochure has not been approved nor verified by the United States Securities and Exchange Commission (SEC) nor by any State Securities Authority. Additional information about Auerbach Investment Services, LLC is available at the SEC's website www.adviserinfo.sec.gov (click on the link, select "Investment Adviser Firm search" and type in "Auerbach Investment Services"). Results will provide you both Part 1 and 2 of the Form ADV. If you would like another copy of this Brochure, please download it from the SEC Website as indicated above or you may contact our Chief Compliance Officer, Kevin Auerbach at 610- 529-3000 or kevin@auerbachinvestment.com.  Item 2 Summary of Material Changes March 20, 2026 – Item 1 was amended for a new principal office address. The material changes discussed above are only those changes that have been made to this brochure since the firm’s last annual update of the brochure. The date of the last annual update of the brochure was February 9, 2026. 2  Item 3 Table of Contents Item 2 Summary of Material Changes ............................................................................................................ 2 Item 3 Table of Contents ................................................................................................................................ 3 Item 4 Advisory Business ............................................................................................................................... 4 Item 5 Fees and Compensation ..................................................................................................................... 5 Item 6 Performance-Based Fees and Side-By-Side Management ................................................................. 7 Item 7 Types of Clients .................................................................................................................................. 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ............................................................ 8 Item 9 Disciplinary Information ..................................................................................................................... 11 Item 10 Other Financial Industry Activities and Affiliations ........................................................................... 11 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................. 12 Item 12 Brokerage Practices ........................................................................................................................ 12 Item 13 Review of Accounts ......................................................................................................................... 14 Item 14 Client Referrals and Other Compensation ...................................................................................... 14 Item 15 Custody ........................................................................................................................................... 15 Item 16 Investment Discretion ...................................................................................................................... 15 Item 17 Voting Client Securities ................................................................................................................... 16 Item 18 Financial Information ....................................................................................................................... 16 3  Item 4 Advisory Business Firm Background Founded by its President, Managing Member and Principal Owner, Kevin Auerbach, Auerbach Investment Services, LLC (“AIS”) was formed in 2017 and provides investment management services to its clients. Prior to engaging AIS to provide the foregoing investment advisory services, the client is required to enter into one or more written agreements with the firm setting forth the terms and conditions under which AIS renders its services (collectively the “Agreement”). Investment Management and Wealth Management Services Investment advisory clients may receive investment management through AIS. AIS tailors its advisory services to the individual needs of clients. The firm consults with clients initially and on an ongoing basis to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. AIS ensures that clients’ investments are suitable for their investment needs, goals, objectives and risk tolerance. AIS may provide services on a discretionary or non-discretionary basis. If AIS's services are provided on a discretionary basis, AIS may purchase and sell securities and other investments in the client's account without the client's prior consent. Non-discretionary advisory services requires the client to consent to investment transactions in the account prior to execution. AIS primarily invests clients in one of two general portfolio models: (1) Traditional Portfolio Models with the following objectives: • Moderate • Growth • Aggressive (2) AIS Prime Portfolio Pension Consulting Services AIS offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • identifying investment objectives and restrictions; • providing guidance on various assets classes and investment options; • recommending money managers to manage plan assets in ways designed to achieve objectives; • monitoring performance of money managers and investment options and making recommendations for changes; 4  • recommending other service providers, such as custodians, administrators and broker- dealers; and • creating a written pension consulting plan Pension consulting services are offered on a non-discretionary basis unless otherwise agreed by AIS and the plan administrator/sponsor. These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Pension Consulting services are not available in the State of Alabama. Assets Under Management As of January 30, 2026 , we provide continuous management services for $150,199,000 in client assets, including $146,427,000 on a discretionary, and $3,772,000 on a non-discretionary basis. Types of Investments We do not primarily recommend one type of security or contract over another. We generally recommend various types of securities and contract types as your circumstance requires. Item 5 Fees and Compensation Fees for Separate Accounts Pursuant to an investment advisory contract signed by each client, the client will pay AIS an annual management fee, payable quarterly in arrears, based on the value of portfolio assets of the account on the last business day of the quarter. New account fees will be prorated from the inception of the account to the end of the first quarter. Our standard fee schedule for separately managed investment advisory services is determined as a percentage of assets under management and is calculated as follows: Assets Under Management Management Fee $0-$750,000 1.50% Next $1,000,000 1.25% Next $3,250,000 1.00% Over $5,000,000 A mutually agreed upon flat fee These fees may be negotiated by AIS at its sole discretion. The client will give written authorization permitting the AIS to be paid directly from their account held by the custodian. The custodian will send a statement at least quarterly to the client and the Advisor will also send an invoice to the client outlining the fee calculation and time period covered, and the amount withdrawn from the client account each time the fee deduction invoice is sent to the qualified custodian. Fees for Pension Consulting AIS charges consulting fees of between .2% to 1.0% depending upon the size and complexity 5  of the plan and required service to be rendered. Subscription services are not available in the State of Alabama. Investment management fees are collected quarterly in arrears by directly debiting the client's account. While it is our general policy to charge the stated fees above, your fees may be subject to negotiation or modification depending upon the nature of the services offered or your particular circumstances. Unless otherwise arranged, we bill in arrears based upon the value of the assets in your account(s) on the last business day of the quarter as our agreement specifies. Fees Due Upon Termination Either party may terminate the investment management agreement for any reason upon 30- days' written notice to the other which will be effective upon receipt. You will incur a pro rata charge for services rendered until the termination of the investment management agreement. This means you will incur advisory fees only in proportion to the number of days in the billing period during which you remain a client. Unless you notify us otherwise in writing, we will cease to open new positions for the account as of notification to terminate date. There is no assurance the account will retain its value from the notification date to termination date to the actual withdrawal date. Notwithstanding the foregoing, when a copy of this Brochure is not provided to the client at least 48 hours prior to the execution of the investment advisory agreement, the client has five (5) business days in which to cancel the agreement without charge or penalty. Additional Fees and Expenses You may also incur some or all of the following fees and/or expenses. You or your account pay these charges to third parties and they are not shared by us. Some of these fees are charged regardless of whether or not there is activity in your account(s). These expenses may be imposed at the fund level, the subadvisory level, and/or the broker-dealer/custodian level and usually include line items such as: • Advisory fees and administrative fees charged by Mutual Funds (MFs), Exchange Traded Funds (ETFs), Hedge Funds, or other commingled products, if any are used for your account; • Brokerage commissions; • Transaction fees; • Exchange fees; • United States Securities and Exchange Commission and Options Clearing Corporation fees; • Margin Interest, including "hard to borrow" charges • Custodian and/or Safekeeping Fees; • Deferred sales charges (on e.g. MFs or annuities); • Odd-Lot differentials on certain stock and bond transactions; • Transfer taxes; • Wire and/or ACH transfer and other electronic fund processing fees; • Commissions, spreads, or mark-ups/mark-downs on security transactions. 6  Broker-dealers or custodians may charge your account transaction fees based upon the trading and/or clearing services they provide. The charges and fees may be either explicit, hard dollar levies or implicit, soft dollar levies such as price and volatility spreads. We do not share in any portion of the brokerage fees/transaction charges imposed by broker-dealers or custodians. To understand fully the total cost you will incur for investing your funds, you should review all the fees charged by mutual funds, exchange traded funds, hedge funds, or other commingled products, brokerages, banks, trust companies and others in addition to the fees you pay AIS. For information on our brokerage practices, please refer to the "Brokerage Practices" section of this Disclosure Brochure. Performance Fees For Qualified Clients only, AIS may charge a performance fee of 50% of all net gains in the account following the first 10% of returns on the account. That is, Qualified Clients may be charged a 50% performance fee on returns in excess of the first 10% net return. By way of example, if a Qualified Client's account has $1 million in principal on January 1, and the value of that account increases by $110,000 on December 31 of the same year, net of fees, costs and subsequent deposits of capital, AIS's performance fee will be $5,000 (50% of net appreciation over 10%). Performance fees may be negotiated with each Qualified Client and terms may vary. Item 6 Performance-Based Fees and Side-By-Side Management We charge some accounts performance-based fees ("PBF") while at the same time managing accounts (perhaps with similar objectives) that are not charged a PBF. This is called "side-by- side management". PBFs and side-by-side management may create conflicts of interest. We identify and describe some of these conflicts in the following paragraphs. PBFs are only charged to accounts of Qualified Clients. The term "Qualified Client" means: a natural person or company that, immediately prior to entering the PBF contract, has at least $1.1 million of assets under management with AIS; or (2) a natural person or company that, immediately prior to entering the PBF contract, has at least $2,200,000 in net worth. PBFs may create an incentive for our firm to make investments that are riskier or more speculative than would be the case absent a PBF. In order to address this potential conflict of interest, a senior officer of our firm periodically reviews client accounts to ensure that investments are suitable and that the account is being managed according to the client's investment objectives and risk tolerance. PBFs may also create an incentive for our firm to overvalue investments which lack a market quotation. In order to address such conflict, it is the policy of our firm to "fairly value" any investments, which do not have a readily ascertainable value and as such we generally defer to the custodians' appraised value of assets where there is no readily available market price quotation. Side-by-side management might provide an incentive for our firm to favor accounts for which we receive a PBF. For example, we may have an incentive to allocate limited investment opportunities to clients who are charged PBFs over clients who are charged asset based fees only. To address this conflict of interest, we first attempt to segregate those accounts that are 7  most closely aligned by objective and should this be inefficient or unfeasible, our policy is to allocate investment opportunities (if they are suitable) in an effort to avoid favoritism among our clients pro rata based upon the Net Liquidation Value of the accounts, regardless of fee agreement in place for each account. Item 7 Types of Clients We provide our services to a number of Clients: • Individuals, including High Net Worth Individuals • Corporations or other business entities • Pension/profit sharing plans The Advisor’s cumulative minimum account requirement for opening and maintaining an account is $1 million. However, the Advisor may at its sole discretion, accept accounts with a lower value. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Investment Strategies and Methods of Analysis AIS conducts an initial assessment with clients to determine risk tolerance, time horizon and other factors that may impact the clients’ investment needs. AIS may utilize a variety of investments including, but not limited to, individual common and preferred stock, ETF’s, bonds, mutual funds, options, futures, crypto, and other derivatives in accordance with the client’s investment objectives. The firm conducts ongoing reviews of client accounts and offers regular communication with clients throughout the year to review managers’ performance. One of the most difficult determinations to be made by an investor is when to terminate a manager relationship. The firm communicates with its clients throughout the year to objectively make a decision about the status of the relationship. Account performance is measured relative to market statistics, indices and other managers offering similar investment disciplines and strategies. The firm acknowledges that performance delivered to clients is often influenced by client-established constraints and risk tolerance. All such factors are considered when making an initial recommendation of an investment strategy or during subsequent periods. General Risks Investing in securities always involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives can or will be met. Past performance is in no way an indication of future performance. We also cannot assure that third parties will satisfy their obligations in a timely manner or perform as expected or marketed. General Market Risk. Each strategy's value and investment return will fluctuate based upon changes in the value of its portfolio securities. Certain securities held may be worth less than the price originally paid for them, or less than they were worth at an earlier time. 8  Common Stocks. Each strategy's investments in common stocks, both directly and indirectly through investment in shares of ETFs, may fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject certain strategies to potential losses. During temporary or extended bear markets, the value of common stocks will decline, which could also result in losses for each strategy. Trading Strategies based on Volatility. Trading strategies based on volatility, such as realized or implied, are difficult to implement and require successful monitoring, modeling, and sometimes rather immediate interpretation of market conditions. Trading opportunities may be short-lived or limited as a result of a low trading volume in exchange-traded options. Due to a lack of opportunity or market liquidity, there may be extended periods of time in which accounts hold elevated cash balances or experience no trading activity. Transaction costs and taxes can have a significant impact on the profitability of these trading strategies. Portfolio Turnover Risk. Under normal circumstances, the anticipated portfolio turnover rate for most of AIS’ strategies is expected to be more than 100%. High rates of portfolio turnover could lower performance of the strategy due to increased costs and may result in the realization of capital gains. If the strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains and under current tax law you would be taxed on short-term capital gains at ordinary income tax rates, if held in a taxable account. Non-Diversified Strategy Risk. Because some of AIS’ strategies are non-diversified, it will invest a greater percentage of its assets in a particular issuer and will own fewer securities than a diversified strategy. Accordingly, each strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller positions sizes. Model Risk. Financial and economic data series are subject to regime shifts, meaning past information may lack value under future market conditions. Models are based upon assumptions that may prove invalid or incorrect under many market environments. AIS uses certain model outputs to help identify market opportunities and/or to make certain asset allocation decisions. There is no guarantee any model will work under all market conditions. For this reason, we include model related results as part of our investment decision process but we often weigh professional judgment more heavily in making trades or asset allocations. ETF Risks, including Net Asset Valuations and Tracking Error. An ETF's performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depository Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited 9  or inaccurate. Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory compensation – advisory fees charged by AIS plus any advisory fees charged by the issuer of the ETF. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a Client purchased the ETF directly. An ETF typically includes embedded expenses that may reduce the ETF's net asset value, and therefore directly affect the ETF's performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the ETF may include investment advisor management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Leveraged and Inverse ETF/ETPs. Most inverse and leveraged exchange-traded funds or exchange-traded products ("ETPs") “reset” daily, meaning that they are designed to achieve their stated objectives on a daily basis. Due to various effects (i.e. fees, compounding, negative roll yield) some ETFs performance can differ materially from the performance (or inverse of the performance) of their underlying index or benchmark over longer periods of time. In leveraged ETFs, the performance leakage is magnified. Inverse and leveraged ETFs that are reset daily should not be expected to exactly replicate the performance of the underlying index, or its inverse, if held for longer time periods. We may make use of both inverse and leveraged inverse ETFs for clients - either to hedge other portfolio exposure, or as an active attempt to achieve positive returns in a market downturn. We may hold these securities for longer than a few days at a time, accepting the afore-mentioned performance leakage in order to achieve our broader performance aims. The potential for performance leakage when holding a leveraged inverse ETF over a long holding period should be acknowledged as reducing its effectiveness as a hedge. Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar-denominated assets primarily managed by AIS may be affected by the risk that currency devaluations affect Client purchasing power. Correlation Risk. Correlation measures how much one asset moves in connection with another asset. Correlations are typically calculated using historical relationships. There is no assurance the historical relationship will persist. As correlations change, the integrity of hedging and diversification strategies becomes suspect. Your account may buy or sell options based upon a given correlation with an underlying asset(s). This relationship may not hold and can result in adverse financial consequences. Option prices may move more or less than the price of your asset or portfolio. This failure to track your asset or portfolio may result in a loss or greater loss than was expected. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, 10  because of the lack of purchasers willing to convert your investment to cash or other assets. Legislative and Tax Risk. Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for options, swaps, master limited partnerships, Real Estate Investment Trust, Exchange Traded Products/Funds/Securities. AIS does not engage in tax planning, and in certain circumstances a Client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for how the transactions in their account are reported to the IRS or any other taxing authority. Item 9 Disciplinary Information Neither our firm nor any of our associated persons has any reportable disciplinary information. Item 10 Other Financial Industry Activities and Affiliations Insurance Business Certain of AIS’ Supervised Persons, in their individual capacities, are also licensed insurance agents with various insurance companies, and in such capacity, may recommend, on a fully- disclosed commission basis, the purchase of certain insurance products. While AIS does not sell such insurance products to its investment advisory clients, AIS does permit its Supervised Persons, in their individual capacities as licensed insurance agents, to sell insurance products to its investment advisory clients. A conflict of interest exists to the extent that AIS recommends the purchase of insurance products where AIS’ Supervised Persons receive insurance commissions or other additional compensation. AIS’ Supervised Persons currently devote less than fifteen percent (15%) of their time to insurance sales. Narbitrader, LLC AIS’s principal, Kevin Auerbach, has invested and assumed a management role in Narbitrader, LLC (“Narbitrader”). Narbitrader is a technology company established to develop trading algorithms for the purchase and sale of securities in certain investment portfolios. Narbitrader will not execute transactions, manage portfolios or otherwise exercise discretion over any investment account. Narbitrader’s algorithm receives data alert feeds from research outfits like Bloomberg. Narbitrader created a software to interpret the research alerts and determine whether to trade the security mentioned in the alert. If the alert is actionable, and a trade results, the software automatically inputs sell targets and trailing stop losses. The algorithm is NOT used by any trading professionals and will only be used (potentially) in one AIS portfolio (which has not been created yet). Trade signals issued by Narbitrader may be consistent or inconsistent with recommendations made by AIS to clients in separately managed accounts, depending upon the portfolios recommended in clients’ accounts. AIS has established procedures to ensure that Narbitrader’s trade signals do not disadvantage AIS’s clients or otherwise usurp trading opportunities for AIS 11  managed account clients. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading AIS is registered with the SEC and maintains a Code of Ethics pursuant to SEC rule 204A-1 that sets forth the basic policies of ethical conduct for all managers, officers, and employees of the Advisor. In addition, the Code of Ethics governs personal trading by each employee of AIS deemed to be an Access Person and is intended to ensure that securities transactions effected by Access Persons of AIS are conducted in a manner that avoids any conflict of interest between such persons and clients of the Advisor or its affiliates. AIS collects and maintains records of securities holdings and securities transactions effected by Access Persons. These records are reviewed to identify and resolve conflicts of interest. AIS will provide a copy of the Code of Ethics to any client or prospective client upon request. AIS does not recommend to clients, or buy or sell for client accounts, securities in which the firm or a related person has a material financial interest. AIS and/or its investment advisor representatives may from time to time purchase or sell products that they may recommend to clients. This practice creates conflicts of interest in that personnel of AIS can take advantage of the advance knowledge of firm securities trading and trade their personal accounts ahead of the client trades or recommend trades in client accounts that may affect the price of the securities owned by the Investment Advisor Representatives. To mitigate these conflicts, AIS has adopted a Code of Ethics as noted above. AIS’ Code of Ethics is available upon request. Finally, supervised persons of registered investment advisors are fiduciaries by law and are required to put the client’s interest before those of the firm and themselves. AIS requires that its investment advisor representatives follow its basic policies and ethical standards as set forth in its Code of Ethics. Investment Advisor Representatives of AIS may trade for their own accounts securities that are being traded for client accounts at or about the same time. To mitigate the conflict of interest in such circumstances, AIS’ policy is to require the trading of all relevant client accounts prior to the trading of their own accounts. The Chief Compliance Officer examines personal trading activities of AIS’ personnel to verify compliance with this policy. Item 12 Brokerage Practices If requested by the client, AIS may suggest brokers or dealers to be used based on execution and custodial services offered, cost, quality of service and industry reputation. AIS will consider factors such as commission price, speed and quality of execution, client management tools, and convenience of access for both the Advisor and client in making its suggestion. AIS may receive products or services, such as direct fee deduction, as a result of recommending a particular broker which may result in the client paying higher commissions than those obtainable through other brokers. If AIS does receive such products or services, it will follow procedures which ensure compliance with Section 28(e) of the Securities Exchange Act of 1934 or applicable state securities rules. 12  The firm seeks to obtain the most favorable net results for clients’ price, execution quality, services and commissions. Although the firm seeks competitive commission rates, it may pay commissions on behalf of clients which may be higher than those available from other brokers in order to receive other services. The firm may enter into such transactions so long as it determines in good faith that the amount of commission paid was reasonable in relation to the value of the brokerage and research services provided by the broker. The services that may be considered in this determination of reasonableness may include (1) advice, either directly or through publications or writing, as to the value of securities, the advisability of investing in, purchasing or selling securities, and the availability of securities or purchasers or sellers of securities; (2) analysis and reports concerning issuers, industries, securities, economic factors and trends, portfolio strategy, and the performance of accounts; or (3) effecting securities transactions and performing functions incidental thereto. Such research furnished by broker- dealers may be used to service any or all of AIS’ clients and may be used in connection with accounts other than those that pay commissions to the broker-dealers providing the research. In particular, third-party research provided by broker-dealers may be used to benefit all of the firm’s clients. This creates a conflict of interest in that the firm has an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on the clients’ interest in receiving most favorable execution. Benefits received may be used as soft dollars provided that: • The service is primarily for the benefit of AIS’ clients • The commission rates are competitive with rates charged by comparable broker-dealers; and • AIS does not guarantee a minimum amount of commissions to any broker-dealer. AIS does not receive client referrals from any broker-dealer or third party as a result of the firm selecting or recommending that broker-dealer to clients. AIS recommends that clients use a particular broker-dealer for execution and/or custodial services. The broker-dealer is recommended based on criteria such as, but not limited to, reasonableness of commissions charged to the client, tools and services made available to the client and the Advisor, and convenience of access to the account trading and reporting. The client will provide authority to AIS to direct all transactions through that broker-dealer in the investment advisory agreement. As an investment advisory firm, AIS has a fiduciary duty to seek best execution for client transactions. While best execution is difficult to define and challenging to measure, there is some consensus that it does not solely mean the achievement of the best price on a given transaction. Rather, it appears to be a collective consideration of factors concerning the trade in question. Such factors include the security being traded, the price of the trade, the speed of the execution, apparent conditions in the market, and the specific needs of the client. FIRM’s primary objectives when placing orders for the purchase and sale of securities for client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker. FIRM may not necessarily pay the lowest commission or commission equivalent as specific transactions may involve specialized services on the part of the broker. AIS does not permit clients to direct brokerage except for choosing the custodian at the outset 13  of the relationship. AIS may combine orders into block trades when more than one account is participating in the trade. This blocking or bunching technique must be equitable and potentially advantageous for each such account (e.g. for the purposes of reducing brokerage commissions or obtaining a more favorable execution price). Block trading is performed when it is consistent with the duty to seek best execution and is consistent with the terms of AIS’ investment advisory agreements. Equity trades are blocked based upon fairness to client, both in the participation of their account, and in the allocation of orders for the accounts of more than one client. Allocations of all orders are performed in a timely and efficient manner. All managed accounts participating in a block execution receive the same execution price (average share price) for the securities purchased or sold in a trading day. Any portion of an order that remains unfilled at the end of a given day will be rewritten on the following day as a new order with a new daily average price to be determined at the end of the following day. Due to the low liquidity of certain securities, broker availability may be limited. Open orders are worked until they are completely filled, which may span the course of several days. If an order is filled in its entirety, securities purchased in the aggregated transaction will be allocated among the accounts participating in the trade in accordance with the allocation statement. If an order is partially filled, the securities will be allocated pro rata based on the allocation statement. AIS may allocate trades in a different manner than indicated on the allocation statement (non-pro rata) only if all managed accounts receive fair and equitable treatment. Item 13 Review of Accounts Investment Management Services A qualified representative of our firm will monitor your accounts on an ongoing basis and will conduct account reviews at least annually, to ensure that the investment management services provided to you and the portfolio's composition is consistent with your stated investment needs and objectives. Your account may warrant additional reviews based on various circumstances, including, but not limited to: • contributions and withdrawals, • market moving events, • security specific events, and/or, • changes in your risk/return objectives. Upon request and in cooperation with your custodian we will provide you with reports summarizing account activity and performance. In addition, you will receive trade confirmations, monthly or quarterly statements, and year-end tax statements from your account custodian(s). Several custodians now offer electronic only statement delivery and recall. Item 14 Client Referrals and Other Compensation We do not receive direct compensation from any third party in connection with providing investment advice to you. However, please refer to the "Brokerage Practices" section above for disclosures on research and other benefits we may receive resulting from our relationships with various brokers or custodians. We do not compensate non-employee individuals or entities for client referrals. 14  Item 15 Custody We may directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees from your account(s) causes our firm to exercise limited custody over your funds or securities. To obtain limited custody for purposes of directly debiting the client account, AIS must comply with the following requirements: (1) AIS must receive written authorization from the client to deduct advisory fees from the account held by the qualified custodian; (2) AIS must send the qualified custodian written notice of the amount of the fee to be deducted from the client account; and (3) AIS must send a written invoice to the client itemizing the fees deducted, including the calculation, the time period for the fee deduction, and the amount of assets under management subject to the fee. We do not have physical custody of any of your funds and/or securities. A bank, broker-dealer, or other independent, qualified custodian holds your funds and securities. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. If applicable, the reports we provide to you also reflect the amount of advisory fee deducted from your account. We also send you an invoice reflecting the advisory fee. You should compare our reports/invoices with the statements from your account custodian(s) to reconcile the information reflected on each statement. If you have a question regarding your account statement or if you did not receive a statement from your custodian, please contact Kevin Auerbach, Chief Compliance Officer at 610-529-3000. Item 16 Investment Discretion Before we can buy or sell securities on your behalf, you must first sign our discretionary management agreement and/or trading authorization form. You may grant our firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. You may specify investment objectives, guidelines, and/or impose certain conditions or investment parameters for your account(s). For example, you may specify that the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in the securities of a specific industry or security. Please refer to the "Advisory Business" section in this Brochure for more information on our discretionary management services. If you enter into non-discretionary arrangements with our firm, we will obtain your approval prior to the execution of any transactions for your account(s). 15  Item 17 Voting Client Securities For individually managed accounts, we will not vote proxies on behalf of your advisory accounts. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. Item 18 Financial Information We are not required to provide financial information to our clients because we do not: • require the prepayment of more than $500 in fees and six or more months in advance, or • take custody of client funds or securities, or • have a financial condition that is reasonably likely to impair our ability to meet our commitments to you. 16