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Aurora Investment Managers, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 146325
SEC File No.: 801- 68844
02/17/2026
Aurora Investment Managers, LLC
4850 Tamiami Trail N Suite 301
Naples, FL 34103
Phone (617) 390-8001
Fax (617) 845-0385
www.Auroraim.com
02/17/2026
FORM ADV PART 2
BROCHURE
This brochure provides information about the qualifications and business practices of Aurora
Investment Managers, LLC. If you have any questions about the contents of this brochure, please
contact us at (617) 390-8001 or sdew@auroraim.com. The information in this brochure has not
been approved or verified by the United States Securities and Exchange Commission or by any
state securities authority.
Additional information about Aurora Investment Managers, LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Aurora Investment
Managers, LLC is 146325.
Aurora Investment Managers, LLC is a Registered Investment Adviser. Registration with the
United States Securities and Exchange Commission or any state securities authority does not
imply a certain level of skill or training.
i.
Item 2: Material Changes
We removed a disclosure that listed an infraction which took place in 2015, when we moved our offices
from Massachusetts to Florida. Our compliance company at the time disclosed our move to every state
where we were conducting business except for the State of Florida. The infraction resulted in a reduced
administrative fine of $4,000 on July 8, 2015.
Ashley Dewji Smith resigned from the Boys and Girls Club of Collier County Board of Directors on
10/31/2025.
Table of Contents
Item 1: Cover Page………………..…………………………………………………………..i.
Item 2: Material Changes………….……………………………………………….………..ii.
Item 3: Table of Contents…………………………………………………………..……….iii.
Item 4: Advisory Business .............................................................................................. 1
Item 5: Fees and Compensation .................................................................................... 2
Item 6: Performance-Based Fees and Side-By-Side Management ............................ 3
Item 7: Types of Clients ................................................................................................... 3
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, Participation or Interest in Client Transactions and
Personal Trading ............................................................................................................... 5
Item 12: Brokerage Practices ......................................................................................... 6
Item 13: Review of Accounts .......................................................................................... 7
Item 14: Client Referrals and Other Compensation ..................................................... 7
Item 15: Custody .............................................................................................................. 7
Item 16: Investment Discretion ....................................................................................... 8
Item 17: Voting Client Securities .................................................................................... 8
Item 18: Financial Information ........................................................................................ 8
Additional Information ...................................................................................................... 9
iii.
Item 4: Advisory Business
Form ADV Part 2A, Item 4
Description of Services and Fees
We are a registered investment adviser based in West Palm Beach, Florida. We are organized as a limited
liability company under the laws of the State of Delaware. We have been providing investment advisory
services since 2008. Mr. Shakeel Dewji is our firm’s principal owner. We are a fee-only independent financial
adviser offering investment portfolio management services personalized to each individual client.
The following paragraphs describe our services and fees. Please refer to the description of our investment
advisory services for information on how we tailor our advisory services to your individual needs.
Portfolio Management Services
We offer discretionary portfolio management services to our clients and prospective clients. Our investment
advice is tailored to meet our clients’ needs and investment objectives. If you retain our firm for portfolio
management services, we will meet with you to determine your investment objectives, risk tolerance, and other
relevant information (the “suitability information”) at the beginning of our advisory relationship. We will use the
suitability information we gather from our initial meeting to develop a strategy that enables our firm to give you
continuous and focused investment advice and/or to make investments on your behalf. Once we construct an
investment portfolio for you, we will monitor your portfolio’s performance on an ongoing basis, and will
rebalance the portfolio as required by changes in market conditions and in your financial circumstances.
Generally, our clients grant us discretionary authority over the transactions in their accounts. Discretionary
authorization will allow our firm to determine the specific securities, and the amount of securities, to be
purchased or sold for your account without your approval prior to each transaction. Discretionary authority is
typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading
authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that
can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. If you
enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any
transactions on behalf of your account.
Our current fee for portfolio management services is based on a percentage of your assets we manage and is
set forth in the following fee schedule:
Annual Fee
Assets Under Management
$1 to $3,000,000
$3,000,001 to $5,000,000
$5,000,0001 to $8,000,000
$8,000,001 and above
1.00%
0.80%
0.60%
0.40%
Our annual portfolio management fee is billed and payable quarterly in advance based on the value of your
account on the last day of the previous quarter. If the portfolio management agreement is executed at any time
other than the first day of a calendar quarter, our fees will apply on a pro rata basis, which means that the
advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our
advisory fee is negotiable, depending on individual client circumstances.
At our discretion, we may combine the account values of family members living in the same household to
determine the applicable advisory fee. For example, we may combine account values for you and your minor
children, joint accounts with your spouse, and other types of related accounts. Combining account values may
increase the asset total, which may result in your paying a reduced advisory fee based on the available
breakpoints in our fee schedule stated above.
We will send you an invoice for the payment of our advisory fee, or we will deduct our fee directly from your
account through the qualified custodian holding your funds and securities. We will deduct our advisory fee only
when you have given our firm written authorization permitting the fees to be paid directly from your account.
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Further, the qualified custodian will deliver an account statement to you at least quarterly. These account
statements will show all disbursements from your account. You should review all statements for accuracy. We
will also receive a duplicate copy of your account statements.
We encourage you to reconcile our invoices with the statement(s) you receive from the qualified custodian. If
you find any inconsistent information between our invoice and the statement(s) you receive from the qualified
custodian, please call our main office number located on the cover page of this brochure.
You may terminate the portfolio management agreement upon 30 days’ written notice to our firm. You will incur
a pro rata charge for services rendered prior to the termination of the portfolio management agreement, which
means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a
client. If you have pre-paid advisory fees that we have not yet earned, you will receive a prorated refund of
those fees.
Types of Investments
We primarily offer advice on equity securities, warrants, corporate debt securities, certificates of deposit,
investment company securities, and US Government securities.
Additionally, we may advise you on other types of investments that we deem appropriate based on your stated
goals and objectives. We may also provide advice on other types of investments held in your portfolio at the
inception of our advisory relationship.
You may request that we refrain from investing in particular securities or certain types of securities. You must
provide these restrictions to our firm in writing.
Assets Under Management
As of December 31, 2025, we manage approximately $325,576,592.96 in client assets on a discretionary basis,
and $33,118,309.28 in client assets on a non-discretionary basis.
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Item 5: Fees and Compensation
Form ADV Part 2A, Item 5
Please refer to the “Advisory Business” section in this Brochure for information on our advisory fees, fee
deduction/paying arrangements, and refund policy.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in mutual
funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are
separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds
(described in each fund’s prospectus) to their shareholders. These fees will generally include a management
fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or
selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through
which your account transactions are executed. We do not share in any portion of the brokerage
fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will
incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For
information on our brokerage practices, please refer to the “Brokerage Practices” section of this Brochure.
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Item 6: Performance-Based Fees and Side-By-Side Management
Form ADV Part 2A, Item 6
We do not accept performance-based fees or participate in side-by-side management. Side-by-side
management refers to the practice of managing accounts that are charged performance-based fees while at the
same time managing accounts that are not charged performance-based fees. Performance-based fees are fees
that are based on a share of capital gains or capital appreciation of a client’s account. Our fees are calculated as
described in the Advisory Business section above and are not charged based on a share of capital gains upon,
or capital appreciation of, the funds in your advisory account.
Item 7: Types of Clients
Form ADV Part 2A, Item 7
We offer investment advisory services to individuals, pension and profit-sharing plans, trusts, estates,
charitable organizations, corporations, and other business entities.
In general, we require a minimum of $100,000 to open and maintain an advisory account. At our discretion, we
may waive this minimum account size. For example, we may waive the minimum if you appear to have
significant potential for increasing your assets under our management. We may also combine account values
for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet
the stated minimum.
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss
Form ADV Part 2A, Item 8
Our Methods of Analysis and Investment Strategies
We may use one or more of the following methods of analysis or investment strategies when providing
investment advice to you:
Fundamental Analysis – involves analyzing individual companies and their industry groups, such as a
company’s financial statements, details regarding the company’s product line, the experience and
expertise of the company’s management, and the outlook for the company’s industry. The resulting
data is used to measure the true value of the company’s stock compared to the current market value.
Technical Analysis – involves studying past price patterns and trends in the financial markets to predict
the direction of both the overall market and specific stocks.
Long Term Purchases – securities purchased with the expectation that the value of those securities will
grow over a relatively long period of time, generally greater than one year.
Short Term Purchases – securities purchased with the expectation that they will be sold within a
relatively short period of time, generally three to five years, to take advantage of the securities’ short
term price fluctuations.
Short Sales – a securities transaction in which an investor sells securities he or she borrowed in
anticipation of a price decline. The investor is then required to return an equal number of shares at
some point in the future. A short seller will profit if the stock goes down in price.
Our investment strategies and advice may vary depending upon each client’s specific financial situation. As
such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time
horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your
restrictions and guidelines may affect the composition of your portfolio.
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Our strategies and investments may have unique and significant tax implications. However, unless we
specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of
your assets. Regardless of your account size or any other factors, we strongly recommend that you
continuously consult with a tax professional prior to and throughout the investing of your assets.
More than a small portion of our clients’ assets are advised using short term and long term purchases. Short
term trading is not a fundamental part of our overall investment strategy, but we may use this strategy when we
determine that it is suitable given your stated investment objectives and tolerance for risk. Short term trading
generally involves a greater degree of risk than long term trading due to market volatility over a short period of
time; however, our short term purchases typically have a longer than average investment horizon to mitigate
risks associated with market volatility. Long term purchases may also be affected by unforeseen long term
changes in the company in which you are invested or in the overall market.
Risk of Loss
Investing in securities 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 will be met. Past performance is in no way an
indication of future performance.
Recommendation of Particular Types of Securities
As disclosed under the “Advisory Business” section in this Brochure, we primarily recommend the following
types of securities equity securities, warrants, corporate debt securities, certificates of deposit, investment
company securities, and U.S. Government securities. You should be advised that investing in securities of any
type involves a risk of loss. In an effort to limit your exposure to loss involving one particular security, we
diversify clients’ investments among various securities.
Item 9: Disciplinary Information
Form ADV Part 2A, Item 9
Item 10: Other Financial Industry Activities and Affiliations
Form ADV Part 2A, Item 10
We have not provided information on other financial industry activities and affiliations because we do not have
any relationship or arrangement that is material to our advisory business or to our clients with any of the types
of entities listed below.
1. broker-dealer, municipal securities dealer, or government securities dealer or broker
2.
investment company or other pooled investment vehicle (including a mutual fund, closed-end
investment company, unit investment trust, private investment company or “hedge fund,” and offshore
fund)
3. other investment adviser or financial planner
4.
futures commission merchant, commodity pool operator, or commodity trading advisor
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lawyer or law firm
insurance company or agency
5. banking or thrift institution
6. accountant or accounting firm
7.
8.
9. pension consultant
10. real estate broker or dealer
11. sponsor or syndicator of limited partnerships
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
Form ADV Part 2A, Item 11
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics
includes our guidelines for professional standards of conduct. Our goal is to protect your interests at all times
and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you.
Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or
dissemination of material, non-public information about you or your account holdings by our firm.
Our Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting
Shakeel Dewji at (617) 390-8001 or sdew@auroraim.com.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or
securities in which you are already invested. We may also buy or sell securities for you at the same time we
buy or sell such securities for our own account. A conflict of interest exists in such cases because we have the
ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this
conflict of interest, it is our policy that we will never have priority over your account in the purchase or sale of
securities.
We may also combine our orders to purchase securities with your orders to purchase securities (“block
trading”). Please refer to the “Brokerage Practices” section in this Brochure for information on our block trading
practices.
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Item 12: Brokerage Practices
Form ADV Part 2A, Item 12
We maintain relationships with several broker-dealers. While you are free to choose any broker-dealer or other
service provider, we recommend that you establish an account with a brokerage firm with which we have an
existing relationship. Such relationships may include benefits provided to our firm, including, but not limited to,
research, market information, and administrative services that help our firm manage your account(s). We
believe that recommended broker-dealers provide quality execution services for our clients at competitive
prices. Price is not the sole factor we consider in evaluating best execution. We also consider the quality of the
brokerage services provided by recommended broker-dealers, including the value of research provided, the
firm's reputation, execution capabilities, commission rates, and responsiveness to our clients and our firm. In
recognition of the value of research services and additional brokerage products and services recommended
broker-dealers provide, you may pay higher commissions and/or trading costs than those that may be available
elsewhere.
Brokerage for Client Referrals
We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as
brokerage services or research.
Directed Brokerage
Some clients may instruct our firm to use one or more particular brokers for the transactions in their accounts. If
you choose to direct our firm to use a particular broker, you should understand that this might prevent our firm
from aggregating trades with other client accounts or from effectively negotiating brokerage commissions on
your behalf. This practice may also prevent our firm from obtaining favorable net price and execution. Thus,
when directing brokerage business, you should consider whether the commission expenses, execution,
clearance, and settlement capabilities that you will obtain through your broker are adequately favorable in
comparison to those that we would otherwise obtain for you.
Block Trades
We combine multiple orders for shares of the same securities purchased for advisory accounts we manage
(this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to
participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically
proportionate to the size of the account, but it is not based on account performance or the amount or structure
of management fees. Subject to our discretion regarding factual and market conditions, when we combine
orders, each participating account pays an average price per share for all transactions and pays a
proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm
may participate in block trading with your accounts; however, they will not be given preferential treatment.
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Item 13: Review of Accounts
Form ADV Part 2A, Item 13
Shakeel Dewji, Managing Member/CCO of Aurora Investment Managers, LLC will monitor your accounts on an
ongoing basis and will conduct account reviews at least quarterly and upon your request to ensure that the
advisory services provided to you are consistent with your stated investment needs and objectives. Additional
reviews may be conducted based on various circumstances, including, but not limited to:
contributions and withdrawals;
year-end tax planning;
market moving events;
security specific events; and/or,
changes in your risk/return objectives.
You will receive trade confirmations and monthly or quarterly statements from your account custodian(s). We
will not provide you with additional or regular written reports in conjunction with account reviews.
Item 14: Client Referrals and Other Compensation
Form ADV Part 2A, Item 14
We do not receive any compensation from any third party in connection with providing investment advice to you
nor do we compensate any individual or firm for client referrals.
Item 15: Custody
Form ADV Part 2A, Item 15
We directly debit your account(s) for the payment of our advisory fees. This ability to deduct our advisory fees
from your accounts causes our firm to exercise limited custody over your funds or securities. We do not have
physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank,
broker-dealer, or other independent qualified custodian. 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.
You should compare our statements 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 Shakeel Dewji, Managing Member/CCO at (617)
390-8001 or sdew@auroraim.com.
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Item 16: Investment Discretion
Form ADV Part 2A, Item 16
Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement. By signing our discretionary management agreement, you are granting our firm the limited right to
make certain investment decisions on your behalf.
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.
Item 17: Voting Client Securities
Form ADV Part 2A, Item 17
We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice
regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or
mutual funds, you are responsible for exercising your right to vote as a shareholder.
In most cases, you will receive proxy materials directly from the account custodian. However, in the event we
were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless
you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic
solicitation to vote proxies.
Item 18: Financial Information
Form ADV Part 2A, Item 18
We are not required to provide financial information to our clients because we do not:
require the prepayment of more than $1,200 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.
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Additional Information
Your Privacy
We view protecting your private information as a top priority. Pursuant to applicable privacy requirements, we
have instituted policies and procedures to ensure that we keep your personal information private and secure.
We do not disclose any nonpublic personal information about you to any nonaffiliated third parties, except as
permitted by law. In the course of servicing your account, we may share some information with our service
providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys.
We restrict internal access to nonpublic personal information about you to employees who need that
information in order to provide products or services to you. We maintain physical and procedural safeguards
that comply with regulatory standards to guard your nonpublic personal information and to ensure our integrity
and confidentiality. We will never sell information about you or your accounts to anyone. We do not share your
information unless it is required to process a transaction, at your request, or required by law.
You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our
firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Please
contact Shakeel Dewji at (617) 390-8001 or sdew@auroraim.com if you have any questions regarding this
policy.
Trade Errors
In the event a trading error occurs in your account, our policy is to restore your account to the position it should
have been in had the trading error not occurred. Depending on the circumstances, corrective actions may
include canceling the trade, adjusting an allocation, and/or reimbursing the account. If a trade error results in a
profit, you will keep the profit.
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