AURORA INVESTMENT COUNSEL

COVER PAGE - ADV PART 2A Aurora Investment Counsel, Inc. 3350 Riverwood Parkway, Suite 2205 Atlanta, GA 30339 770.226.5323 (Phone) 678.202.0484 (Fax) www.aurora-invest.com December, 2024 This Brochure provides information about the qualifications and business practices of Aurora Investment Counsel, Inc. [“ADVISOR”]. If you have any questions about the contents of this Brochure, please contact us at 770.226.5323 or email us at dave@aurora-invest.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Aurora Investment Counsel, Inc. is a Registered Investment Advisor with the SEC. Registration of an Investment Advisor does not imply any level of skill or training. The oral and written communications of an Advisor provide you with information about which you determine to hire or retain an Advisor. Additional information about Aurora Investment Counsel, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. Item 2 - Material Changes On January 28, 2010, the United States Securities and Exchange Commission published “Amendments to Form ADV” which amends the disclosure document that we provide to clients as required by SEC Rules. This Brochure dated December 31, 2023 is a document prepared according to the SEC’s new requirements and rules. As such, this Document is materially different in structure and requires certain new information that our previous brochure did not require. In December, 2014, Lebenthal Asset Management, an SEC Registered Investment Advisor (SEC File # 801- 68831) and a 100% owned subsidiary of Lebenthal Holdings, LLC, consummated a transaction to purchase the assets of Aurora Investment Counsel. On September 1, 2017, Aurora Investment Counsel, an SEC Registered Investment Advisor (SEC File # 801- 60000) and Lebenthal Asset Management signed a Termination Agreement, which combined with other related documents separated all business connections as of August 31, 2017. Aurora Investment Counsel is now privately owned by David J. Yucius, Jr. and Michael T. Doyle, as referenced in Form ADV, Part I. This October, 2024 update removes now non-relevant Wrap Fee disclosure language. Aurora is also amending Item 9.A.1 and 9.A.2 to provide for Standing Letter of Authorization accounts as Custody Account assets. In the past we have offered or delivered information about our qualifications and business practices to clients on at least an annual basis. Pursuant to new SEC 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. We may further provide other ongoing disclosure information about material changes as necessary. Our Brochure may be requested by contacting David J. Yucius, Jr., Chief Compliance Officer at 770.226.5323 or dave@aurora-invest.com. Our Brochure(s) are also available on our web site, www.aurora-invest.com. i  Item 3 - Table of Contents Item 1 - Cover Page .............................................................................................................. i Item 2 - Material Change ....................................................................................................... i Item 3 - Table of Contents .................................................................................................... ii Item 4 - Advisory Business.................................................................................................... 1 Item 5 - Fees and Compensation .......................................................................................... 2 Item 6 - Performance-Based Fees and Side-By-Side Management .................................... 2 Item 7 - Types of Clients ....................................................................................................... 2 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ................................ 3 Item 9 - Disciplinary Information ........................................................................................... 4 Item 10 - Other Financial Industry Activities and Affiliations ................................................. 4 Item 11 - Code of Ethics ........................................................................................................ 4 Item 12 - Brokerage Practices .............................................................................................. 5 Item 13 - Review of Accounts ............................................................................................... 5 Item 14 - Client Referrals and Other Compensation ............................................................. 6 Item 15 - Custody .................................................................................................................. 6 Item 16 - Investment Discretion ............................................................................................ 6 Item 17 - Voting Client Securities .......................................................................................... 6 Item 18 - Financial Information ............................................................................................. 7 ii  Item 4 - Advisory Business Aurora Investment Counsel, Inc. is a separate account manager providing primarily US Equity investment strategies. Aurora utilizes a “bottom-up”, fundamentals based approach for its “Growth At the Right Price” discipline to equity investing. Ancillary services may include asset allocation, fixed income services and general investment guidance. The securities we use in our investment strategies and investment advice include equity securities, such as exchange listed securities, securities traded over the counter and foreign issues; preferred stock of public corporations, debt securities of corporations and similar entities; listed options securities, certificates of deposit; municipal and government securities; investment company securities such as mutual fund shares and exchange traded funds. Aurora Investment Counsel, Inc. was incorporated and became a Registered Investment Advisor on January 4, 2001, after previously doing business as Randy Seckman and Associates. In December, 2014, Lebenthal Asset Management, an SEC Registered Investment Advisor (SEC File # 801- 68831) and a 100% owned subsidiary of Lebenthal Holdings, LLC, consummated a transaction to purchase the assets of Aurora Investment Counsel. On September 1, 2017, Aurora Investment Counsel, an SEC Registered Investment Advisor (SEC File # 801- 00000) and Lebenthal Asset Management signed a Termination Agreement, which combined with other related documents separated all business connections as of August 31, 2017. Remaining stockholders of Aurora Investment Counsel are David J. Yucius, Jr. (majority owner), and Michael T. Doyle. David J. Yucius, Jr., CFA acts as Portfolio Manager for all accounts and clients, and serves as President and CCO of the firm. Types of Services Offered by Aurora Investment Counsel: Aurora Investment Counsel provides discretionary investment counseling for its clients. Typical elements of that service include:  A review of each client’s financial status and inquiry to their investment goals.  The drafting of an Investment Policy Statement which incorporates among other things: Return Objectives, Risk Tolerance, Time Horizon, Liquidity Needs, Tax Considerations and Special Constraints.  Setting of Asset Allocation targets and acceptable ranges for investment in various asset classes. Also, outlines general parameters for security selection within asset classes.  Policy implementation includes security selection across asset classes including common equities, government & corporate fixed income, municipal fixed income, mutual funds, money market mutual funds, convertible securities and closed end funds.  Constant review of recommended securities for all accounts. Ongoing client communications through written research updates, investment proposals and regularly scheduled client meetings.  Quarterly performance and status updates including account appraisals quarterly and annual performance information, and market environment commentary. When engaged to provide investment advice for separate accounts (i.e. not commingled with other portfolios), Aurora Investment Counsel, Inc. does provide clients with customized advice and recommendations. Client or Sub-Advisor consultations and Investment Policy statements are used to allow for client input regarding unique characteristics in the client’s profile that requires attention or limitation. Examples of such characteristics include the ability to restrict Aurora from purchasing particular securities and/or to restrict ownership of certain types of securities or sectors. Aurora also works with referring Advisor firms and representatives to communicate the special and individual needs of their clients, which can account for tax considerations, liquidity needs or other portfolio structure requests. 1 of 7  Financial Planning Services When directly engaged, without acting as Sub-Advisor, Aurora may offer broad based Financial Planning services. These services entail questions as to a Client’s financial details including insurance, wills, income/expenses, assets/indebtedness and retirement planning. These services are delivered in personalized settings, and do not involve the sale or use of any products with remuneration for Aurora or Aurora personnel. Fees are inclusive with the Asset Management fees and schedule otherwise mentioned in this form. Assets Under Management As of December 31, 2024, Aurora Investment Counsel, Inc. managed $237 million, with $232 million being Discretionary Assets Under Management and $4.7 million being Non-Discretionary Assets. We serve in a Sub- Advisory capacity to 11 Registered Investment Advisory firms, where clients contract for services with these intermediaries directly. Aurora then serves as a Sub-Advisor with regards to its more specialized investment services. Aurora serves clients directly as Investment Advisor for roughly 53 relationships. Wrap-Fee Programs Aurora is not currently participating in any Wrap-Fee Program. Item 5 - Fees and Compensation Fee Schedule*: .90 % of Assets Under Management from $ 1,000,000 to $ 2,999,999 .65 % of Assets Under Management from $ 3,000,000 to $ 9,999,999 .50 % of Assets Under Management from $ 10,000,000 to $99,999,999 .40 % of Assets Under Management from $100,000,000 and Above *Fees are subject to discount based upon various criteria including overall firm assets under management and average portfolio size. Minimum Quarterly Fee = $ 450 Per Account Minimum Annual Fee = $1,800 Per Account The specific manner in which fees are charged by Aurora is established in a client’s written agreement with Aurora. Aurora will bill its fees on a quarterly basis in advance. Clients may elect to be billed directly for fees or to authorize Aurora to directly debit fees from client accounts. Clients may cancel Investment Counseling services with written notice, and prorated fees will be refunded for the period beginning 30 days after receipt of such notice. Aurora’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by manager, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. While Aurora receives no remuneration from such charges, they should be considered an added cost of the investment program, which will affect client total returns. Item 6 - Performance Based Fees & Side-By-Side Management Not applicable to Aurora Investment Counsel, Inc. 2 of 7  Item 7 - Types of Clients Aurora Investment Counsel provides portfolio management services to high net worth individuals, pension and profit sharing plans, charitable organizations, foundations, trust programs, clients of referring Registered Investment Advisors and clients of Family Offices. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Aurora Investment Counsel undertakes a quantitative and then qualitative approach to selecting equity securities for investment. Our Growth At a Reasonable Price (GARP) approach involves using computer screening to identify stocks with advantaged growth attributes simultaneously with cheapness in the stock’s price (i.e. Low P/E, dividend yield, Low P/CF, etc.). Our portfolio managers then qualitatively utilize various sources including company reports and filings, fundamental analysis, publicly available media sources, and corporate rating services. Aurora typically pursues investments with a long-term perspective, and endeavor to minimize short term trading, and rarely utilize margin transactions (specific permission and client applicability would be needed from the client). Risk of Loss Investing in securities involves a risk of loss that clients should be prepared to bear, including the loss of original principal. Clients should also be aware that past performance of any security is not necessarily indicative of future results. Therefore, they should not assume that future performance of any specific investment or investment strategy will be profitable. Advisor does not provide any representation or guarantee that client goals will be achieved. Investing in securities involves risk of loss. Further, depending on the different types of investments, there may be varying degrees of other risks:  Market Risk - A market as a whole, and thus the value of an individual company, goes down, resulting in a decrease in the value of client investments. This is also referred to as systemic risk.  Equity Risk - Common stocks are susceptible to fluctuations and to volatile increases/decreases in value as their issuers’ confidence in or perceptions of the market change. Investors holding common stock (or common stock equivalents) of any issuer are generally exposed to greater risk than if they hold preferred stock or debt obligations of the issuer.  Company Specific Risk - There is always a certain level of company or industry specific risk when investment in stock positions. This is referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that a company may perform poorly or that its value may be reduced based on factors specific to it or its industry (e.g., employee strike, unfavorable media attention, management, etc.).  Fixed Income Risk - Investing in bonds involves the credit risk that the issuer will default on the bond and be unable to make payments. In addition, individuals depending on set amounts of periodically paid income face the risk that inflation will erode their spending power. Fixed-income investors receive set, regular payments that face inflation risk and re-investment risk.  ETF and Mutual Fund Risk - ETF and mutual fund investments bear additional expenses based on a pro- rata share of operating expenses, including potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities held by the ETF or mutual fund. Clients also incur brokerage costs when purchasing such vehicles.  Management Risk - Client investments also vary with the success and failure of Advisor’s investment strategies, research, analysis and determination of portfolio securities. If Advisor’s strategies do not produce the expected returns, the value of a client’s investments will decrease.  Liquidity Risks - While Aurora typically invests in liquid markets and publicly traded securities, there can be no assurance that market dislocations may temporarily impede client access to funds due to extemporaneous events or conditions. 3 of 7   Inflation Risk - When any type of inflation is present, a dollar today will not buy as much as a dollar next year because purchasing power is eroding at the rate of inflation. Should investments not rise sufficiently or lose value, purchasing power may not be maintained.  Taxes - The implementation of an investment program may involve the client incurring taxes as a result of gains or income derived from transactions. There are no assurances that these costs will be at the most favorable rates given the client’s unique standing. Various mutual fund and private fund prospectuses serve as important sources of information on risks entailed in products involving external management. Item 9 - Disciplinary Information Aurora Investment Counsel, nor any of its personnel has ever been involved in any type of disciplinary event. Item 10 - Other Financial Industry Activities and Affiliations Aurora Investment Counsel is a non-affiliated, 100% privately owned SEC Registered Investment Advisor. Item 11 - Code of Ethics Applicant or related person may buy or sell listed securities that may or may not be simultaneously recommended to client(s). Aurora has internal policies, procedures and review processes to insure fair dealings in any such instances. Policies include a three day window (before and after purchase) surrounding the purchase and sale of securities related to client accounts for Aurora Investment Counsel personnel and quarterly statement review of Aurora Investment Counsel personnel brokerage activities. Applicant has adopted a Code of Ethics, a copy of which is available upon request to any client or prospective client. (See description below) Aurora Investment Counsel Code of Ethics Aurora Investment Counsel will:  Act with integrity, competence, and dignity and in an ethical manner when dealing with the public, clients, prospects, employers and employees.  Practice and encourage others to practice in a professional ethical manner.  Strive to maintain and improve our competence and the competence of others in the profession.  Use reasonable care and exercise independent professional judgment. Aurora employees have a duty to:  Place the interests of clients first.  All personal securities transactions must be conducted in such a manner to be consistent with the Code of Ethics and other internal policies to avoid any abuse or an employee’s position of trust.  Adhere to the fiduciary principle that information concerning the identity of security holdings and financial circumstances of clients is confidential.  Accept that independence in the investment decision-making process is paramount. The goals of this Code of Ethics are to:  Protect the firm’s clients by deterring misconduct.  Educate employees regarding the firm’s expectations and the laws governing their conduct.  Remind employees that they are in a position of trust and must act with complete propriety at all times.  Guard against violations of securities laws.  Establish procedures for employees to follow so that Aurora Investment Counsel may determine whether their employees are complying with the firm’s ethical principles. 4 of 7  Item 12 - Brokerage Practices Applies to accounts under Investment Advisory: Aurora attempts to negotiate lower than market commission rates for client accounts, but cannot guarantee the availability of lower rates on client-directed trades; therefore, the commission rates may be higher. Aurora does not receive commissions derived from managed securities in client accounts. Aurora considers multiple factors in recommending brokerage firms for our clients’ transactions and in determining the reasonableness of the compensation or other remuneration paid to the brokerage firms. In no particular order, these factors include:  Rate of commissions charged by the brokerage firm.  Promptness and quality of overall execution services provided by the brokerage firm.  Financial condition, creditworthiness and business reputation of the brokerage firm.  Promptness and accuracy of all forms of trade reports of execution.  Ability to access various market centers and ability of brokerage firm to employ ECN’s to gain liquidity, price improvement, lower commission rates and anonymity.  Operational capabilities including the software and hardware utilized in engaging our transactions.  Ability and willingness to correct trade errors.  Research, if any, provided by the brokerage firm. Some of these factors may weigh more heavily than others. Research materials are used to service all clients. Aurora also receives research services both while being charged and at no charge from numerous brokers with no obligations. The client remains free to select or use the broker of their choice. Brokerage commission discounts are attempted for all clients, but not guaranteed. For client-directed trades, the commissions may be higher, the quality and speed of execution may be lower and self directed brokerage may impede Aurora’s ability to include client orders in block trades (see below). Block Trading Aurora may group or block orders from time to time for the same security for more than one client account in order to more effectively execute the orders. This is what is known as a “block transaction.” This process can create trading efficiencies, prompt attention to the order and improved price execution through various trading and market breadth extending techniques. Aurora has adopted procedures for block trading on behalf of clients and uses a Volume Weighted Average Price (VWAP) method for allocating block orders. This method insures that everyone participates proportionally in the overall execution of any given trade. In the event that this method absolutely cannot be applied, a method of random selection is used to differentiate between the sale lots or partial fills. Block security purchase allocations will primarily be based upon appropriateness for each individual’s account objectives. Item 13 - Review of Accounts On a constant and daily basis the Portfolio Manager monitors all recommended securities. On a periodic basis, each account is reviewed by the Portfolio Manager with regards to its original Investment Policy statement and goals to ensure suitability. Factors which may trigger more frequent reviews include change in client investment objectives or circumstances such as retirement or a large contribution or withdrawal to or from an account, significant developments or events specific to a particular security held in the account, or significant market, economic or political developments. 5 of 7  In addition to more frequent custodial statements, Aurora provides internally produced quarterly and annual statements showing a current appraisal of assets and overall account performance. These reports will include details of the cost basis, market value and percentage of the portfolio each security represents. Clients are urged to compare statements from their Advisor with those of their independent Custodian for accuracy and verification. Annual statements are available showing realized and unrealized gain/loss information for tax planning. Item 14 - Client Referrals and Other Compensation Not Applicable to Aurora Investment Counsel. Item 15 – Custody The custody of your account assets must be maintained at a “qualified custodian” which is typically a brokerage firm or a bank. In addition to any account statements you may receive from Aurora Investment Counsel, Inc., you will receive account statements directly from your custodian on at least a quarterly basis although you may receive them on a monthly basis. You should carefully review these statements and compare these statements to statements you receive from Aurora Investment Counsel, Inc. for any discrepancies. You should also remember that the statements you receive from your custodian are your official record of your accounts and assets for tax purposes. Item 16 - Investment Discretion Aurora will accept discretionary investment authority at the outset of a relationship over your assets if you agree to such an arrangement. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. This is typically assumed through the execution of a limited trading authority or similar written authority contained in your client agreement with us. When executing your client agreement with us, you can further limit the extent of discretionary investment authority to be granted to us although this may impact the level of services we can provide you. This limited trading authority will not extend to provide Aurora the ability to withdraw or otherwise take custody of client assets without express written consent and signatory approval. Clients may communicate special or mitigating restrictions, regulations or needs that may limit the Advisor’s discretion, in writing, such as restricting the purchase or sale of specific securities or sectors, specific order handling instructions and other unique considerations involving taxes or liquidity needs. Investment guidelines and restrictions must be provided to Aurora in writing. Item 17 - Voting Client Securities The purchase of a share brings with it ownership obligations and the right to vote on issues affecting the company in which Aurora Investment Counsel has invested. As part of our fiduciary duty to our clients, generally speaking, we will vote or abstain from voting with the intent of aligning such votes alongside the enhancement of the clients’ long term shareholder value. The Proxy Voting Policies set forth below are intended to ensure that Aurora Investment Counsel votes client securities in the best interests of the client. Aurora Investment Counsel will fulfill all fiduciary obligations set forth by providing the following services:  Development of Proxy Voting Policies  General reliance on Proxy Voting Guidelines as a point of reference  Voting (and actively abstaining) from proxy votes in a timely and consistent manner 6 of 7   Maintaining a record of proxy votes and related materials Under no circumstances shall it be implied that Aurora Investment Counsel has assumed Proxy Voting authority unless specifically called for within the Client Agreement or designated Brokerage Forms. Under no circumstances shall the Proxy Voting Policies set forth below imply that those good faith efforts and mistakes relating to carrying out these procedures subject Aurora Investment Counsel or its employees to enforcement action or client recovery demands. Aurora Investment Counsel’s Compliance Department will work with designated Portfolio Managers to carry out the Proxy Voting Policies set forth below. Effective 8/1/03, Aurora Investment Counsel has designated David J. Yucius, Jr., CFA as Portfolio Manager for all client accounts to date. Portfolio Managers retain certain responsibilities regarding voting proxy materials on behalf of our Investment Clients. Investment Clients may enquire about Proxy Voting Policies and Proxy Voting issues by contacting either the Compliance Department or their assigned Portfolio Manager. Inquiries should be directed in writing to: Aurora Investment Counsel, Inc. 3350 Riverwood Parkway, Suite 2205 Atlanta, Georgia 30339 Item 18 - Financial Information Not applicable to Aurora Investment Counsel, as we have never filed for bankruptcy nor are we subject to any financial conditions which would impair our ability to meet our obligations to clients. 7 of 7 

Item 1 - Cover Page ADV PART 2B David J. Yucius, Jr., CFA Aurora Investment Counsel, Inc. 3350 Riverwood Parkway, Suite 2205 Atlanta, GA 30339 770.226.5323 (Phone) 678.202.0484 (Fax) www.aurora-invest.com December, 2024 This Brochure Supplement provides information about David J. Yucius, Jr., which supplements the Aurora Investment Counsel, Inc. Brochure. A copy of that Brochure is available upon request. Please contact David J. Yucius, Jr., Chief Compliance Officer, at dave@aurora-invest.com or by calling 770.226.5323, if you did not receive Aurora’s Brochure or if you have any questions about the contents of this supplement. Item 2 - Educational Background & Business Experience Date of Birth: October 2, 1967 Northeastern University, Boston, MA BS Finance/Management 1990 David is the Portfolio Manager, President and CEO of Aurora Investment Counsel. David was the portfolio manager and research analyst for Randy Seckman & Associates from 1995 through December, 2000. He is a Chartered Financial Analyst who employs fundamental and quantitative analysis towards his investment recommendations. Prior to joining RS&A, David worked in the investment manager consulting business for a regional brokerage firm in Atlanta for 5 years. He also has experience with a major pension investment firm. David is a member of the CFA Institute and the Atlanta Society of Finance and Investment Professionals. Item 3 - Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary evens that would be material to your evaluation of each supervised person providing investment advice. David Yucius and Aurora Investment Counsel, Inc. have no information that is applicable to this item. Item 4 - Other Business Activities David became an employee and Investment Advisor Representative of Lebenthal Asset Management as part of an asset purchase agreement consummated in December, 2014. Aurora and LAM signed a Termination Agreement as of 8/31/17, and along with other supporting agreements have separated all business relations and David ceased being an employee of LAM as of 8/31/17. Item 5 - Additional Compensation Not applicable to Aurora Investment Counsel, Inc. Item 6 - Supervision As Chief Compliance Officer, and Chair of the Compliance Committee, David is supervised by the other members of the Compliance Committee.  Item 1 - Cover Page ADV PART 2B Michael T. Doyle, CFP® Aurora Investment Counsel, Inc. 3350 Riverwood Parkway, Suite 2205 Atlanta, GA 30339 770.226.5323 (Phone) 678.202.0484 (Fax) www.aurora-invest.com December, 2024 This Brochure Supplement provides information about Michael T. Doyle that supplements the Aurora Investment Counsel, Inc. Brochure. A copy of that Brochure is available upon request. Please contact David J. Yucius, Jr., Chief Compliance Officer, at dave@aurora-invest.com or by calling 770.226.5323, if you did not receive Aurora’s Brochure or if you have any questions about the contents of this supplement. Item 2 - Educational Background & Business Experience Date of Birth: January 11, 1977 Mike is the Director of Marketing for Aurora Investment Counsel. Prior to joining Aurora Investment Counsel, he serviced high-net-worth and intermediary clients as a portfolio manager at Vestor Capital Corporation from 2001 to 2005. Mike was an account executive at Mack and Parker, Inc., an insurance brokerage firm that consulted to mid-sized service and manufacturing companies on their property/casualty insurance programs before his employment at Vestor Capital Corporation. He is a graduate of the University of Georgia, and obtained his Certified Financial Planner (CFP®) designation in 2018. Michael became an employee and Investment Advisor Representative of Lebenthal Asset Management as part of an Asset Purchase Agreement consummated in December, 2014. Aurora and LAM signed a Termination Agreement as of 8/31/17, and along with other supporting agreements have separated all business relations and Michael ceased being an employee of LAM as of 8/31/17. Item 3 - Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary evens that would be material to your evaluation of each supervised person providing investment advice. Michael Doyle and Aurora Investment Counsel, Inc. have no information that is applicable to this item. Item 4 - Other Business Activities NA Item 5 - Additional Compensation Not applicable to Aurora Investment Counsel, Inc. Item 6 - Supervision Michael T. Doyle is supervised by David J. Yucius, Jr., CCO and the Compliance Committee. 

Form ADV, Part 3; Form CRS Advisor Name: Date: SEC Firm File Number: Aurora Investment Counsel, Inc. December 31, 2024 801-60000 January, 2000 RELATIONSHIP SUMMARY Date of Firm SEC Registration: Item 1: Introduction Aurora Investment Counsel, Inc. is a Securities and Exchange Commission (SEC) Registered Investment Advisory firm. Brokerage and Investment Advisory services differ, therefore, it is important for you to understand the differences. Free and simple tools are available to research firms and financial professionals at Investor.gov/CRS, which provide educational materials about broker/dealers, investment advisors, and investing. Item 2: Relationship and Services What investment services can you provide me? Aurora’s core business is in providing investment management and advisory services to retail investors, delivered via Separate Managed Accounts (SMA’s). Through a process of inquiry, Aurora gains an understanding of our clients’ financial goals and asks questions regarding Return Objectives, Risk Tolerances, Time Horizon of investment, Income/Growth needs, and Tax Considerations to assess a client’s investment profile and needs. We will compile this input into an Investment Policy Statement, and will recommend an asset allocation and any other relevant terms to provide a mandate for future services. In dealing with Individual Clients (as opposed to Institutional or Sub-Advisory Clients), Aurora will also build an understanding of further financial considerations, other than Investment Management. By inquiring about a client’s broader considerations (such as retirement planning, insurance, goal setting, estate planning, taxes, etc.), we endeavor to offer Financial Planning service and counsel. Aurora is typically not delivering final offerings or products in this capacity, but is typically a facilitator for such concerns. Investment Management service entails various administrative assistance such as opening new accounts with Custodian third party firms, transitioning and establishing the initial investment portfolios, on-going review of such portfolios, rebalancing, quarterly performance reporting, potentially debiting of relevant fees, trading and transaction processing, and answering client inquiries regarding portfolio status. SMA accounts typically are invested in diversified combinations of investments such as common stocks, preferred stocks, corporate bonds, government/municipal bonds, money market mutual funds, and other ETF or mutual funds, but do not include proprietary securities. We deliver a disciplined and systematic approach to our equity investment process, and utilize several information sources (Bloomberg, etc.) and technology tools (Advent, etc.) to develop and deliver our investment strategies. Financial Planning utilizes several different tools to deliver advice, including eMoney software. Client accounts are typically managed on a Discretionary basis, where clients have authorized Aurora and a chosen Custodian/Brokerage firm to make limited purchase and sales transactions within a Client’s account. Non-Discretionary management without such explicit Authority is sometimes provided given tax considerations or other reasons, but only in very limited circumstances, and Clients retain responsibility for such assets. All Investment Management services are clearly laid out in Investment Advisory Agreements, which describe our services and our Authority, any special considerations, as well as the Investment Management Fee Schedule which will apply. Generally, the opening minimum amount for beginning Aurora accounts is $250,000 or greater, although this can be subject to negotiation. Investment Advisor Representatives (IAR’s) of Aurora have years of relevant industry experience, and have passed various qualifications and exams, including Chartered Financial Analyst (CFA), Certified Financial Planner (CFP), and other various educational and regulatory exams. You should ask for a complete description of experience, certifications and exam history of your investment advisor(s). Also you can find further information at https://adviserinfo.sec.gov and at Aurora Form ADV, Part 2. Ask your financial advisor: * Given my financial situation, should I choose an investment advisory service? Why or Why Not? * How will you choose the investments that are recommended for me? * What is your relevant experience, including your licenses, education and other qualifications? What do these qualifications mean? Item 3: Fees, Costs, Conflicts of Interest, and Standard of Conduct Aurora charges clients an annual investment management fee, billed quarterly in advance, based upon the level of Assets Under Management. So, the more Assets Under Management that pertain to a Client’s Accounts, the more a Client will pay in fees, and Aurora will have an incentive to encourage the Client to increase the funds in such accounts. Third Party Custodians charge various fees in providing ancillary services ranging from brokerage trading costs, ticket charges, processing fees, wired funds fees, and optional overnight express mailing fees. Also, additional embedded costs may pertain to various investment vehicles including ETF and mutual fund 1  Form ADV, Part 3; Form CRS expenses (which are further disclosed in Prospectus documents), MLP tax form fees, trade away fees, etc. These costs are born by Clients, but are never remunerated to Aurora or its employees. You will pay fees and costs whether you make money or you lose money on your investments. Fees and costs will reduce any amount of money you make from your investments over time. Please make sure you understand what fees and costs you are paying. For further information, please click on Form ADV, Part 2, Item 5&6. Ask your financial advisor: Help me understand how these costs and fees might affect my investments? If I give you $10,000 to invest, how much will go to fees and costs, and how much will be invested for me? What are your legal obligations to me when acting as my Investment Advisor? How else does your firm make money and what conflicts of interest might you have? When Aurora acts as your Investment Advisor, we have to act in your best interest, and not put our interests ahead of yours. At the same time, the way we make money might create some conflicts of interests. You should understand and ask us about these conflicts because they could affect the investment service and recommendations we provide you. Here are some examples to help you understand what this means. Since we charge fees based on the market value of Assets Under Management, a conflict could arise in our desire to manage assets that could otherwise be invested elsewhere that would not be subject to these Aurora Management Fees. Aurora and its personnel owe a duty of loyalty, fairness, and good faith toward our clients and have an obligation to adhere not only to the specific provisions of the Aurora Code of Ethics, but to standards associated with qualifying organizations (such as the CFP Board and CFA Institute), and other professional pledges. A copy of Aurora’s Code of Ethics will be provided upon request at the contact information (see Item 5) below. While the Aurora Code of Ethics does provide parameters to mitigate potential conflicts, the Code does not restrict Aurora employees from investing in similar securities recommended as part of our Investment Management service, or following similar Financial Planning guidelines. Potentially, pursuing the same investments as clients might present a conflict between Aurora employees and Clients, though several processes are set up with the intention of putting our Client’s interests first in such instances. Ask your financial advisor: How might your Conflicts of Interest affect me, and how will you address them? How do our financial professionals make money? Aurora’s Investment Management fees represent the revenues earned by Aurora. Employees are paid a regular salary based upon various criteria including seniority, client value added, experience, scope of work and other typical criteria. Aurora employees who are also equity holders in Aurora Investment Counsel, Inc. may also share in the profits of Aurora. Aurora employees are not compensated by other professional means. To the extent that these revenues are based upon Client Assets Under Management, there is a potential for similar Conflicts as stated above. For additional information, you may also follow this link to Form ADV, Part 2, Section 5. Item 4: Disciplinary History Do you or Aurora financial professionals have a legal or disciplinary history? No. Visit www.investor.gov/CRS for a free search tool to research financial and Advisory firm personnel. Ask your financial advisor: As a financial professional, do you have a disciplinary history? For what type of conduct? Item 5: Additional Information If you have questions about the contents of this brochure, or wish to receive up to date information or request a free copy of this brochure, please contact us at (770) 226-5323, by email at mike@aurora-invest.com . This brochure and links to Aurora’s ADV Filing Parts 2 and 3 can be found at our company website: www.aurora-invest.com Ask your financial advisor: Who is my primary contact person? Is he/she a representative of a broker/dealer or investment advisor firm? Who can I talk to if I have concerns about how this person is treating me? Aurora Investment Counsel 3350 Riverwood Parkway, Suite #2205 Atlanta, GA 30339 (770) 226-5323 2