Overview

Headquarters
Woburn, MA
Average Client Assets
$3.5 million
Minimum Account Size
$5,000,000
SEC CRD Number
173392

Fee Structure

Primary Fee Schedule (AUOUR PART 2A BROCHURE)

MinMaxMarginal Fee Rate
$0 $1,000,000 1.00%
$1,000,001 $5,000,000 0.75%
$5,000,001 and above 0.50%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million Below minimum client size
$5 million $40,000 0.80%
$10 million $65,000 0.65%
$50 million $265,000 0.53%
$100 million $515,000 0.52%

Clients

HNW Share of Firm Assets
62.54%
Total Client Accounts
833
Discretionary Accounts
813
Non-Discretionary Accounts
20

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Regulatory Filings

Additional Brochure: AUOUR PART 2A BROCHURE (2026-03-25)

View Document Text
Form ADV Part 2A: Firm Brochure Firm Brochure Part 2A of Form ADV (Item 1) Auour Investments 400 Tradecenter, Suite 3990, Woburn, MA 01801 978-338-4830 www.auour.com March 25, 2026 This brochure provides information about the qualifications and business practices of Auour Investments. If you have any questions about the contents of this brochure, please contact the Compliance Department at 978-338-4830. 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 the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov Auour Investments Brochure ITEM: 2 MATERIAL CHANGES ANNUAL UPDATE The purpose of Item 2 is to discuss specific, material changes that have been made relative to the prior Disclosure Brochure and to provide Clients with a summary of such changes. MATERIAL CHANGES SINCE THE LAST UPDATE Since the last distribution of this Disclosure Brochure, the firm has had the following changes: 1. (At Item 4 – Advisory Business) Auour has updated its assets under management. 2. (At Item 12 – Brokerage Practices) Auour has established a relationship with Altruist Financial LLC as another custodial option for clients. 3. (At Item 14 – Custody) Auour has updated its Custody item to disclose that Joseph Hosler, a Managing Principal of the firm, began serving as trustee of a client revocable trust in January 2026. As a result, the firm is deemed to have custody of certain client assets under SEC rules. Auour has engaged an independent public accounting firm to conduct the required annual surprise examination. FULL BROCHURE AVAILABLE If you would like to receive a complete copy of our Firm Brochure, please call (978) 338-4830 or email info@auour.com. 2 Auour Investments Brochure TABLE OF CONTENTS ITEM: 2 MATERIAL CHANGES .................................................................................... 2 ANNUAL UPDATE ...................................................................................................... 2 MATERIAL CHANGES SINCE THE LAST UPDATE ....................................................................... 2 FULL BROCHURE AVAILABLE ......................................................................................... 2 ITEM 4: ADVISORY BUSINESS .................................................................................... 4 ASSETS UNDER MANAGEMENT ....................................................................................... 4 PRINCIPAL OWNERS ................................................................................................... 4 FIRM DESCRIPTION .................................................................................................... 4 TYPES OF SERVICES ................................................................................................... 4 ITEM 5: FEES AND COMPENSATION ............................................................................ 5 FEE SCHEDULE .......................................................................................................... 6 WRITTEN AGREEMENT ................................................................................................ 7 ITEM 6: PERFORMANCE 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 DISCLOSURES ....................................................................... 10 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................... 10 ITEM 11: CODE OF ETHICS, RECOMMENDATIONS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ................................................................. 11 IRA ROLLOVER RECOMMENDATION ................................................................................. 12 PARTICIPATION OR OTHER INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ........................ 12 ITEM 12: BROKERAGE PRACTICES ........................................................................... 12 SOFT DOLLARS OR ECONOMIC BENEFITS ............................................................................ 13 BROKERAGE FOR CLIENT REFERRALS ............................................................................... 14 TRADE AGGREGATION ............................................................................................... 14 TRADE ROTATION POLICY ........................................................................................... 14 ITEM 13: REVIEW OF ACCOUNTS AND REPORTS .......................................................... 15 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION (SOLICITOR ARRANGEMENTS) 15 ITEM 15 CUSTODY ................................................................................................. 15 ITEM 16 INVESTMENT DISCRETION .......................................................................... 16 ITEM 17 VOTING CLIENT SECURITIES ....................................................................... 16 ITEM 18 FINANCIAL INFORMATION .......................................................................... 17 3 Auour Investments Brochure ITEM 4: ADVISORY BUSINESS Being registered does not mean any regulatory authority endorses Auour or implies any level of skill or training. The Adviser is headquartered in Woburn, MA. Auour’s services involve portfolio management and investment advisory services. ASSETS UNDER MANAGEMENT Total assets under management (“AUM”) as of December 31, 2025: Non-Discretionary $23,393,103 Discretionary $ 354,945,961 Total $ 378,339,064 PRINCIPAL OWNERS Auour Investments, a Massachusetts limited liability company founded in 2013, is owned directly by its managing principals, Joseph Hosler, Robert Kuftinec, and Kenneth Doerr. The managing principals hold 100% of the firm. FIRM DESCRIPTION Auour Investments uses proprietary asset allocation investment processes and models to help guide investment decisions, aiming to manage portfolio risk to best protect and grow clients’ future purchasing power. Client assets are generally invested in a passive exchange-traded fund (“ETF”) strategy but may also include stocks, bonds, mutual funds, and other securities. The firm’s investment strategies are offered as described below. TYPES OF SERVICES Directly Managed Separate Accounts investment management services on a discretionary basis Auour provides customized to individuals, family offices, family & charitable trusts, and high net-worth clients through our investment advisor representatives (“IAR”). After discussions on risk tolerance, investment time horizon, asset allocation, and income requirements, among other things, Auour, through our IARs, will discuss options appropriate to the client’s investment needs. Account supervision is guided by the client’s stated objectives (i.e., capital appreciation, growth, income, etc.), and all managed accounts will be maintained with an independent, qualified custodian. 4 Auour Investments Brochure Auour accounts are managed on a discretionary or non-discretionary basis as indicated in the Auour Investment Advisory Agreement. Sub-Advisor or Co-Advisor to Managed Separate Accounts The Firm also provides discretionary investment advisory services to separate account clients as a subadvisor or co-advisor to other registered investment advisers (outside RIAs). The RIA's investment adviser representative (IAR) selects an investment strategy for their client after consulting with them and providing the risk profile to Auour to substantiate the selection. The RIA is responsible for providing updates to Auour as and when applicable. Clients utilizing Auour as a subadvisor or co-advisor will pay higher fees than clients in Directly Managed Separate Accounts. Strategy Signal Service Auour offers a strategy signal service whereby it enters into a non-discretionary advisory agreement with unaffiliated third parties. This offers a broader distribution of the Auour strategies to non-clients unrelated to service providers. Through this service, Auour uploads holdings and trade instructions to the various third parties’ platforms which may then utilize the information as a component of the allocation process for their clients that subscribe to the Auour strategies. The third parties and their clients may choose to follow (or not) the signals Auour provided. Auour does not manage any accounts under the strategy signal service and is not responsible for the trade execution or reconciliation of these accounts. Any assets that rely on the signals are not included in AUM and will be identified as Assets Under Advisement (“AUA”). ITEM 5: FEES AND COMPENSATION Auour receives fees for its advisory services based on assets under management. For directly managed separate accounts, some assets in a managed account may not be included in the client’s advisory fee calculation if those assets are deemed non-discretionary investments. The fee Auour charges is generally established in the client’s written agreement with Auour. Auour may bill its fees monthly or quarterly. Clients pay fees in arrears as specified in the advisory agreement. For subadvisor and co-advisor relationships, Auour charges its portion of the advisory fee and, in addition, charges a fee that is paid to the outside RIA. As such, the costs associated with a program are more than those of Auour’s Direct Managed Separate Accounts. The client generally pays for ongoing investment and planning advice and portfolio management from the outside RIA and Auour. The fee paid to the outside RIA may be more than what the outside RIA would receive if the client participated in another program. As a result, the outside RIA may be financially incentivized to recommend Auour’s program or service over other programs or services. For directly managed separate accounts, co-advisor, and subadvisor relationships, the Qualified Custodian generally deducts advisory fees from the client account upon instruction from Auour. The Custodian will 5 Auour Investments Brochure send statements directly to the client reflecting the deduction of these fees. Clients are encouraged to contact Auour or the Custodian with any questions or concerns related to the fees. In addition to the investment advisory fees and transaction charges, accounts may also incur certain charges imposed by third parties in connection with investments made through the program. These may include, but are not limited to, the following: mutual fund or money market 12b-1 fees, mutual fund, money market or ETF management fees and administrative expenses, mutual fund transaction fees, other transaction charges and service fees, IRA and qualified plan fees, processing and handling fees or other charges on a fully disclosed basis. Further information regarding charges and fees assessed by a mutual fund is available in the appropriate prospectus, which is delivered to the client by the Custodian under a contractual arrangement with Auour. Mutual funds and exchange-traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees, and commissions are exclusive of and in addition to Auour’s fee. Auour shall not receive any portion of these commissions, fees, and costs. Clients may avoid additional fees by purchasing funds directly from a fund family and not receiving investment advice. Compensation for the Sale of Securities or Other Investment Products Persons providing investment advice on behalf of our firm are licensed as independent insurance agents. These persons will earn commission-based compensation for selling insurance products, including those they sell to you. Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm, who are insurance agents, have the incentive to recommend insurance products to you to generate commissions rather than solely based on your needs. You are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with our firm. FEE SCHEDULE Auour Investments For Directly Managed Separate Accounts, Auour charges a fee (the “Fee”) for investment supervision and management of the Account(s) based on the current market value assets in the Account(s) (including cash and equivalent items) according to the following schedule: Assets Under Management Annual Fee On the first $1 Million 1.00% On the next $4 Million 0.75% Above $5 Million 0.50% Fees are payable in arrears in either 1) quarterly installments or 2) monthly installments, based on the account’s average daily market value (s). The custodian will typically deduct payment at the end of the period. For sub-advisory and co-advisory clients, fees charged by outside RIAs are in addition to those charged 6 Auour Investments Brochure by Auour, resulting in higher total fees. All fees are negotiable and agreed upon among the outside RIA, Auour, and Client and are disclosed in the Investment Advisory Agreement and, when applicable, a separate Tri-Party Addendum. Fees are payable in arrears in monthly installments based on the account’s average daily market value (s). The custodian will typically deduct payment at the end of the period. For the strategy signal service, Auour negotiates fees directly with third parties. For all relationships, if the Agreement starts at a date other than the beginning of a calendar quarter (or month for clients paying monthly), the Fee for that partial quarter/month shall be prorated accordingly. In the event of any termination of this Agreement, the Adviser’s Fees will be calculated pro-rata through the termination date. The firm relies on third-party resources such as the custodian for valuations of publicly traded securities based on our assessment of their reliability. The Client will be responsible for all other expenses, such as broker commissions, fund loads, fund management fees, and custody fees. Those fees are separate, apart, and in addition to the fees to Auour. Auour does not earn any portion of the fees described in this paragraph. All advisory fees are subject to negotiation. WRITTEN AGREEMENT All clients are required to sign an advisory agreement with Auour. The client or Auour may terminate or assign the advisory relationship in accordance with the provisions of those agreements. It is noted that Auour will not assign the advisory agreement without the client’s consent. Additionally, a client may terminate its advisory relationship with Auour at any time without penalty. Auour encourages clients to carefully review the terms outlined in the agreement before signing it. ITEM 6: PERFORMANCE FEES AND SIDE -BY-SIDE MANAGEMENT Auour does not charge performance-based fees (based on a share of capital gains on or appreciation of a client’s assets). Auour offers separately managed accounts and sub-advisory services to third-party advisors. Some of these offerings include portfolios of investments that may be substantially identical, which could create conflicts of interest. As the investment funds will be managed concurrently, all transactions will be executed in accordance with Auour's trade allocation procedures. These procedures, among other things, ensure that all trades allocated to advisory clients fulfill Auour's fiduciary duty to each client and that securities are otherwise allocated on a fair and non-discriminatory basis. In determining a fair allocation, Auour considers several factors, including, among other things, the Adviser’s fiduciary duty to each client, any potential conflicts of interest, the size of the transaction, the relative value of a client’s portfolio, cash available for investment, suitability as well as each client’s investment objectives. Auour 7 Auour Investments Brochure has in place several controls to manage this risk, including independent monitoring of portfolio risk, performance, and exposure and periodic compliance monitoring reviews. ITEM 7: TYPES OF CLIENTS Auour Investments primarily provides investment advisory services to individuals, high-net-worth individuals, trusts, estates, and charitable organizations. Auour does impose a minimum relationship size of $5,000,000 for Directly Managed Separate Account clients. This is negotiable depending on the client relationship. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Auour’s investment strategy combines global strategic asset allocations with disciplined tactical adjustments driven through our proprietary multi-factor model that assesses the risk appetite of the global markets. Auour offers investors five globally diversified portfolios constructed using proprietary asset allocation strategies. Shifts, both strategic and tactical, to the strategies, will be based on our quantitative model (“Auour Regime Model,” or “ARM”), which analyzes macroeconomic factors such as geographically-based return diffusions, style-based return diffusions, credit market conditions, pricing momentum, market valuations, and market volatility. We will also consider political events and country-specific dynamics in our investment decision-making process. Auour believes in and employs several investment biases in portfolio construction. These include: (a) passive management generally outperforms active management. (b) investment returns are primarily driven by asset allocation versus stock selection, (c) avoiding major market corrections drives investment returns, and (d) asset class returns revert to the mean over time. These beliefs influence the design of the Auour investment processes. The Auour Investment Committee regularly (but no less frequently than weekly) monitors each strategy's strategic and tactical allocations. The monitoring includes reviewing each strategy's asset class, sector, and geographical exposures while evaluating the liquidity and construction of the underlying securities. We rebalance when market conditions dictate to our asset class exposure while also adjusting this exposure based on our model’s risk regime calculation. Auour believes that the best investment vehicles to implement our globally diversified asset allocation model are exchange-traded funds (“ETFs”). ETFs provide liquidity, transparency, tax efficiency, and diversification in a low-cost investment vehicle. The Auour Investment Committee routinely evaluates each ETF investment based on liquidity, capitalization, transparency, relative cost, investment objective, tax implications, tracking error and premium/discount. The strategy may include the limited use of 8 Auour Investments Brochure Exchange Traded Notes (“ETNs”) and other investment vehicles that assist in producing the desired outcome. Our investment process does not anticipate using margin, leverage, or derivatives but uses levered ETFs within our most aggressive strategy. The strategy does not include direct shorting of securities but may employ selective use of inverse ETFs. Auour manages seven distinct investment strategies to a broad audience. Each strategy aims to reduce risk through diversification and mitigate losses in the financial markets. Ultra Low Duration Fixed Income strategy provides exposure to global income and liquid alternative investments. The primary investment objective is maintaining the principal with current dividend and interest income. Municipal Fixed Income strategy provides exposure to tax-advantaged income and liquid alternative investments. The primary investment objective is national tax-advantaged current dividend and interest income, although income and capital growth is considered. Instinct Global Fixed Income strategy provides exposure to global income and liquid alternative investments. The primary investment objective is current dividend and interest income, although capital growth is considered. Instinct Multi-Asset Income strategy provides exposure to global equities, global income, and liquid alternative investments. The primary investment objective is current dividend and interest income, although the growth of income and capital is considered. Instinct Global Balanced strategy provides exposure to global equities, global income, and liquid alternative investments. The primary investment objective is a combination of capital growth with current income. Instinct Global Equity strategy provides broad exposure to domestic/international, value/growth, small/large, sectors/country, and liquid alternative investments. The primary investment objective is long- term capital growth, with current income a secondary consideration. strategy provides broad exposure to a combination of Instinct Global Equity Levered domestic/international, value/growth, small/large, sectors/country, and liquid alternative investments and “ultra” ETFs to provide leverage to market returns. The primary investment objective is long-term capital growth. Current income is not considered. Each Auour portfolio typically owns between 5 and 20 separate securities, and no individual security will represent >50% of total portfolio assets except within extreme market conditions. Investing in Auour portfolios involves risks, including the potential for capital loss. Auour’s investment strategies focus on investments in exchange-traded funds (ETFs) that hold domestic and international equities, fixed income, real estate, commodities, precious metals, currencies, derivatives, cash, and other instruments. The returns generated by these ETFs are subject to numerous risks, including economic, social, and political uncertainty, market volatility, foreign currency exchange rate volatility, and tracking error versus an underlying index. ETFs holding fixed-income securities are also subject to default and 9 Auour Investments Brochure interest rate risks. There can be no assurance that the investment objectives of any portfolio managed by Auour will be achieved. The firm may use various quantitative, analytical, and software tools, including applications that incorporate artificial intelligence or machine learning capabilities, to assist with research, data analysis, and administrative functions. These tools are used to supplement, but not replace, the judgment of the firm’s investment professionals. All investment decisions and client communications remain subject to review and oversight by firm personnel. ITEM 9: DISCIPLINARY DISCLOSURES Auour must disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Auour or the integrity of Auour’s management. Auour has no information applicable to this item. Although Auour must and will make separate disclosure if disciplinary disclosure information changes, clients are encouraged to review publicly available information about the entity and the individuals and www.adviserinfo.sec.gov. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Arrangements with Affiliated Investment Adviser We are affiliated with Integrity Financial Advisors, LLC, through common control and ownership. Integrity is distinct from Auour in that its advisers focus on risk protection and financial planning. In most situations, Integrity will utilize Auour for investment management and account servicing. Those clients enter into a tri-party agreement with both Auour and Integrity and pay fees that include those for their financial adviser services and Auour's investment management services. Auour relies on Integrity advisers to direct Auour on the risk tolerance of the client and the positioning within the Auour strategies that best fit the client’s needs. Conflicts of interest may arise because Auour has an ownership interest in Integrity. Integrity advisers may have an incentive to recommend Auour’s investment management services because Auour benefits financially when assets are managed by the firm. Receipt of Insurance Commission Certain persons associated with our firm are also licensed insurance agents with various insurance companies and, in that capacity, may receive commissions or other compensation in connection with the sale of these products. Please refer to Item 5, Fees and Compensation, for more information. Trustee Capacity 10 Auour Investments Brochure Joseph Hosler, a Managing Principal of Auour Investments, may serve as trustee for certain client trusts. In his role as trustee, Mr. Hosler may have the authority to direct investment decisions and approve transactions involving trust assets. Although Mr. Hosler does not receive separate compensation for serving as a trustee, a conflict of interest may exist because he also serves as an investment adviser representative of Auour and receives compensation for the investment advisory services he provides in that capacity. In his trustee capacity, Mr. Hosler could select Auour as the investment adviser to the trust or influence the continuation of Auour’s services, which could result in additional advisory fees being paid to the firm. Clients are under no obligation to appoint Mr. Hosler or any other associated person of Auour as trustee. Clients may appoint an independent trustee or fiduciary if they prefer. When such arrangements exist, they are disclosed in Item 15 (Custody) of this brochure. ITEM 11: CODE OF ETHICS, RECOMMENDATIONS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Auour places significant value on ethical conduct for all advisory business. As such, Auour has adopted a Code of Ethics (“Code”) to establish and implement ethical obligations and provide rules for reviewing the personal securities transactions of its supervised persons. Auour owes a duty of loyalty, fairness, and good faith towards its clients, and it is obligated to adhere not only to the specific provisions of the Code but to the general principles that guide the Code. The Code covers a range of topics that may include general ethical principles, reporting personal securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings and private placements, reporting ethical violations, distribution of the Code, review and enforcement processes, amendments to Form ADV and supervisory procedures. The Code also includes Auour’s policy that prohibits the use of material non-public information. Any principal or associate who does not observe the provisions of the Code may be subject to discipline. As a fiduciary to their clients, an Adviser is responsible for providing professional, continuous, and unbiased investment advice. Fiduciaries owe their clients a duty of honesty, good faith, and fair dealing. To ensure that our employees strictly adhere to the highest standards of conduct and integrity in conducting business on behalf of our clients, we require that each year, every Auour associate certify that he or she: (1) has read and understood the Code, (2) recognizes that the Code applies to him or her, and (3) has complied with all of the rules and requirements of the Code. Auour will provide a copy of its Code of Ethics at no charge to any client or prospective client upon request. 11 Auour Investments Brochure IRA ROLLOVER RECOMMENDATION 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. How we make money creates conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Under this special rule’s provisions, we must: a. Meet a professional standard of care when making investment recommendations (give prudent advice). b. Never put our financial interests ahead of yours when making recommendations (give loyal advice). c. Avoid misleading statements about conflicts of interest, fees, and investments. d. Follow policies and procedures designed to ensure that we give advice that is in your best interest. e. Charge no more than is reasonable for our services; and f. Give you basic information about conflicts of interest. PARTICIPATION OR OTHER INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Occasionally, Auour may employ a security within its strategies in which the firm or an employee owns shares or has other financial interests. Although rare, when this occurs, Auour’s procedures require the firm to determine that the investment suits the client’s needs and risk profile and that any corresponding transactions in the security in the Auour employee’s account are conducted equally or more favorably to the client. If an employee of the firm wishes to buy or sell for himself/herself a model portfolio security that has also been recommended to a client, the Auour employee transaction is placed at the same time and terms as the client transaction. No agency cross transactions or principal trades will be affected in an advisory account. ITEM 12: BROKERAGE PRACTICES Auour will recommend that clients establish brokerage accounts with Fidelity Brokerage Services LLC, Member NYSE/SIPC; Charles Schwab & Co., Inc., Member FINRA/SIPC; Altruist Financial LLC, Member FINRA/SIPC; or Interactive Brokers LLC, Member NYSE/SIPC, to maintain custody of clients’ assets and to effect trades for client accounts. However, Auour does not require clients to use any particular custodian. Auour is independently owned and operated and is not affiliated with Fidelity, Schwab, Altruist, or Interactive Brokers. 12 Auour Investments Brochure These custodians provide Auour with access to institutional trading and custody services, which are typically unavailable to retail investors. These services are generally available to independent investment advisers on an unsolicited basis and are not contingent upon Auour committing to any specific amount of business. For client accounts maintained at Fidelity, Schwab, Altruist, or Interactive Brokers, Auour employs block-trading principles (see “Trade Aggregation” below). This process is designed to result in participating clients receiving approximately the same execution price for the purchase or sale of securities. Clients maintaining custody outside of these custodians may not receive the same execution prices as clients participating in aggregated trades. To promote fairness across custodians and execution venues, Auour utilizes a trade rotation policy to notify custodians of desired trades (see “Trade Rotation Policy” below). Fidelity, Schwab, Altruist, and Interactive Brokers generally do not charge separately for custody services but are compensated by account holders through commissions or other transaction-related fees associated with securities trades executed through them that settle into client accounts. A client may direct Auour in writing to use a particular broker-dealer to execute transactions for the client’s account. When a client directs brokerage in this manner, the commission rates and transaction costs are determined between the client and the broker-dealer. In such circumstances, Auour may be unable to achieve best execution or obtain commission rates as favorable as those available through broker-dealers recommended by Auour. Therefore, directing brokerage may result in higher or lower transaction costs for the client. Clients that restrict Auour from using particular broker-dealers, or direct Auour to use a specific broker- dealer, may be unable to participate in aggregated trades and may therefore not receive the potential benefits of aggregation (see “Trade Aggregation” below). SOFT DOLLARS OR ECONOMIC BENEFITS Fidelity, Schwab, Altruist, and Interactive Brokers also make available to us other products and services that benefit Auour but may not directly benefit our clients’ accounts. Some of these other products and services assist us with managing and administering clients’ accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts), provide research, pricing information, and other market data, facilitate payment of our fees from client accounts, and assist with back-office functions, recordkeeping, and client reporting. Many of these services are used to service all or a substantial number of Auour’s accounts. In addition, Fidelity, Schwab, and Interactive Brokers make available, arrange and/or pay for these services rendered to us by independent third parties. Fidelity, Schwab, and Interactive Brokers discount or waive fees they would otherwise charge for some of these services or pay all or a part of the fees of a third party providing these services to Auour. While as a fiduciary, Auour endeavors to act in its client’s best interests, our recommendation that clients maintain their assets in accounts at Fidelity, or Schwab, Altruist, or Interactive Brokers may be based in part on the benefit to Auour of the availability of some of the 13 Auour Investments Brochure foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by them, which may create a potential conflict of interest. Auour may receive services from other broker-dealers that enhance its ability to service its clients. For instance, recommended broker-dealers may provide Auour with automated or electronic access to client account information, duplicate statements, or consolidated reports. BROKERAGE FOR CLIENT REFERRALS Auour does not refer clients to brokers in exchange for referrals. TRADE AGGREGATION Auour may combine orders into block trades at either custodian when more than one account held at that custodian is participating in the trade. This blocking or bunching technique must be equitable and potentially advantageous for each account (e.g., reducing brokerage commissions or obtaining a more favorable execution price). Block trading is performed when it is consistent with the duty to seek the best execution with the terms of Auour’s investment advisory agreements. Equity trades are blocked based upon fairness to the client, both in the participation of their account and in allocating 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 on a trading day. Due to the low liquidity of certain securities, broker availability may be limited. Open orders are worked until they are filled, which may span 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. TRADE ROTATION POLICY As a fiduciary, the firm looks to institute best practices and treat all discretionary and non-discretionary clients (model delivery platforms) fairly and similarly. Auour has instituted a random trading rotation process for the dissemination of strategy holdings designed to ensure that, over time, all participants are treated equally. Auour maintains a list of trading groups, including direct clients segmented by custodian and all model delivery platforms. This list will be randomized quarterly, and the notification order will be set for that quarter. It is expected that Auour will rebalance all strategies monthly unless outside factors require immediate action. Auour will initiate the trading process when trades must be effected by notifying each group as set in the randomized list. Notification will constitute an e-mail with confirmation of receipt or uploading to a firm’s portal. 14 Auour Investments Brochure For assets under advisement, the third party, not Auour, takes responsibility for ensuring the trading of model portfolios. ITEM 13: REVIEW OF ACCOUNTS AND REPORTS The Investment Committee is responsible for the day-to-day supervision of each account. The performance of each account is reviewed on a regular basis and compared to strategy composites. Auour furnishes its client with a written quarterly portfolio review, including the following for each security: cost basis, market value, annual income, current yield, and asset class. The Investment Committee members meet with clients when and if necessary. Clients also receive account statements directly from their chosen custodian monthly. Clients are encouraged to compare the reports provided by Auour with statements received directly from their custodian. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION (SOLICITOR ARRANGEMENTS) Outside RIAs, for example, unaffiliated broker/dealers and investment advisers who are directly responsible for bringing a client to Auour Investments receive separate compensation from us for client referrals. Such arrangements comply with the requirements under the Investment Advisers Act of 1940 and/or applicable law, including an agreement between the Firm and the outside RIA. Outside RIAs must provide a copy of Auour’s Brochure and a separate outside RIA’s Disclosure Statement regarding the relationship between the outside RIA and Auour to the prospective client at the time of engagement. The prospective client must acknowledge this arrangement before accepting the account for advisory services. A conflict of interest exists due to the nature of the arrangements. As such, third-party clients are advised to pay attention to and carefully consider the separate fees earned by the outside RIA in connection with the referral to Auour. ITEM 15 CUSTODY Auour Investments does not directly maintain possession of client funds or securities. Client assets are maintained with independent qualified custodians such as Fidelity Brokerage Services LLC, Charles Schwab & Co., Inc., Altruist Financial LLC, or Interactive Brokers LLC in accounts established in the client’s name or in the name of the applicable trust. Under Rule 206(4)-2 of the Investment Advisers Act of 1940 (the “Custody Rule”), Auour is deemed to have custody of certain client assets due to a related person serving in a trustee capacity. Specifically, Joseph Hosler, a Managing Principal of Auour Investments, serves as trustee of a client’s revocable trust. Because Mr. Hosler is a control person of Auour and, in his capacity as trustee, has authority to direct the disposition or investment of trust assets, the firm is considered to have custody of those trust assets under the Custody Rule. 15 Auour Investments Brochure The qualified custodian — not Auour — maintains possession of the client’s funds and securities. The custodian maintains these assets in accounts established in the name of the client or the applicable trust. Clients receive account statements directly from the qualified custodian at least quarterly. These statements include the amount of funds and securities held in the account and all transactions affecting the account. Auour urges clients to carefully review these custodial statements and compare them with any reports provided by Auour. Auour does not send clients account statements showing custody of assets. Because Auour is deemed to have custody due to the trustee relationship described above, the firm has engaged an independent public accounting firm to conduct an annual surprise examination in accordance with Rule 206(4)-2 under the Investment Advisers Act of 1940 to verify client funds and securities. The firm currently engages Grassi & Co., CPAs, an independent registered public accounting firm, to perform this surprise examination. Certain clients may establish standing letters of authorization (“SLOAs”) or other asset transfer authorizations that permit the qualified custodian to transfer funds or securities to third parties based on instructions provided by Auour. In accordance with guidance provided in the SEC’s February 21, 2017 Investment Adviser Association No-Action Letter, these arrangements do not independently cause Auour to be deemed to have custody, provided specific safeguards and conditions described in that guidance are satisfied. Clients should notify Auour promptly if they do not receive statements from their qualified custodian at least quarterly. ITEM 16 INVESTMENT DISCRETION Auour has investment discretion over most clients’ accounts. Auour’s authority includes the discretion to determine the securities and amount to be bought and sold for a client’s account. Auour does not have the authority to disburse funds from client accounts. Clients grant us trading discretion by executing a limited power of attorney included in Auour’s advisory contract and custodian account opening documentation. Clients can place reasonable restrictions on Auour’s investment discretion if the restrictions fit within our investment strategies. For example, some clients have asked us not to sell certain securities where the client has a particularly low tax basis. Other clients, such as clients invested in self-directed 401ks, can manage their investments directly by selecting investment options that include the Auour model portfolios, among other selections. ITEM 17 VOTING CLIENT SECURITIES Auour’s policy on proxy voting with respect to client accounts is to vote proxies when requested in a manner consistent with its fiduciary duty to clients. Auour will vote proxies on behalf of clients when the client has delegated proxy voting authority to Auour. Proxy voting authority is assigned in the 16 Auour Investments Brochure Custodian’s account opening application. In cases where Auour retains full responsibility over the proxy voting activities of an account, Auour shall vote client proxies in a way that it believes will cause securities to increase the most or decline the least in value to maximize shareholder value. Consideration will be given to both the short- and long-term implications of the proposal to be voted on when considering the optimal vote. Conflicts of interest will be identified and addressed in such a manner as to benefit most clients and shareholders. Notwithstanding Auour’s discretionary authority to make investment decisions on behalf of its clients, Auour will not exercise proxy voting authority over certain clients’ accounts. Clients shall not be precluded from contacting Auour for advice or information about a particular proxy vote. ITEM 18 FINANCIAL INFORMATION The firm’s principals are not aware of any financial condition that would prevent Auour from delivering contractual services to clients. Auour and its principals have neither claimed protection from creditors nor filed bankruptcy. 17

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