AVAIL INVESTMENT PARTNERS, LLC

Item 1: Cover Sheet FORM ADV PART 2A INFORMATIONAL BROCHURE March 9, 2026 This brochure provides information about the qualifications and business practices of Avail Investment Partners, LLC. If you have any questions about the contents of this brochure, please contact us at 814-996-7206. 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. Our registration does not imply a certain level of skill or training. Additional information about Avail Investment Partners, LLC (CRD# 315678) is also available on the SEC’s website at www.adviserinfo.sec.gov. 801-1 Pike Street Lemont, PA 16851 814-996-7206 1  Item 2: Statement of Material Changes As of the date of this disclosure brochure, there are no material changes to disclose. Item 3: Table of Contents Item 1: Cover Sheet .................................................................................................................. 1 Item 2: Statement of Material Changes ..................................................................................... 2 Item 3: Table of Contents .......................................................................................................... 2 Item 4: Advisory Business ......................................................................................................... 3 Item 5: Fees and Compensation ............................................................................................... 4 Item 6: Performance-Based Fees .............................................................................................. 6 Item 7: Types of Clients ............................................................................................................ 6 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ....................................... 6 Item 9: Disciplinary Information ............................................................................................... 11 Item 10: Other Financial Industry Activities and Affiliations........................................................ 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading . 13 Item 12: Brokerage Practices .................................................................................................... 14 Item 13: Review of Accounts ..................................................................................................... 16 Item 14: Client Referrals and Other Compensation ................................................................... 16 Item 15: Custody ....................................................................................................................... 16 Item 16: Investment Discretion .................................................................................................. 16 Item 17: Voting Client Securities ............................................................................................... 17 Item 18: Financial Information ................................................................................................... 17 2  INFORMATIONAL BROCHURE Avail Investment Partners, LLC Item 4: Advisory Business Avail Investment Partners, LLC (“Avail”) is principally owned by Geoffrey Caber, Stuart Feinzig, Brett Greenfield, Derek Varner and Martin Wildy. Avail provides investment management services and financial planning to individuals, families, trusts, charitable organizations and foundations, businesses, and pension plans. Avail’s process starts with getting to know the client and what is most important to them, where the client is now financially and what they would like their money to accomplish for them. Avail uses the information for investment purposes where we will recommend strategies to help match the client’s goals. We like to work hand in hand with clients, helping them navigate any online tools and client technology so that the client can always have a clear picture of how their assets are working for them. When we perform asset management services, we will do so on a discretionary basis. This means that while we will continue an ongoing relationship with each client, being involved in various stages of their lives and decisions to be made, we will not seek specific approval of changes to client accounts. Because we take discretion when managing accounts, clients engaging us will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Advisory Agreement that outlines the responsibilities of both the client and Avail. Specific security changes will be implemented by Avail in keeping with client objectives but not necessarily with prior client authorization. In limited circumstances, we may provide asset management services on a non-discretionary basis, which means we will consult with the client prior to implementing any investment recommendation. Clients should be aware that some recommendations may be time- sensitive, in which case recommendations not implemented because we are unable to reach a non-discretionary client may not be made on a timely basis and therefore client’s account may not perform as well as it would have had Avail been able to reach the client for a consultation on the recommendation. Financial Planning Financial planning services may be provided as a part of the asset management process when requested. Avail’s planning process typically begins with a discovery meeting when time is taken to gather information, understand client expectations, and determine the right fit for pursuing a working relationship. For example, the discovery process may include the review of insurance currently in place (i.e., life, disability, and long-term care insurance), creating personal balance sheet and cash flow statements, and the review of estate planning documents in an effort to better understand the client’s holistic financial situation. Furthermore, the planning process may also include collaboratively developing a financial plan to assist the client in reaching his or her unique financial objectives. Assets Under Management As of December 31, 2025, Avail has $184,457,139 in assets under management in 427 accounts all managed on a discretionary basis. 3  Item 5: Fees and Compensation A. Fees Charged All investment management clients will be required to execute an Investment Management Agreement that will describe the type of management services to be provided and the fees, among other items. Clients are advised that they may pay fees that are higher or lower than fees they may pay another advisor for the same services and may in fact pay lower fees for comparable services from other sources. Clients are under no obligation at any time to engage or to continue to engage, Avail for investment services. Asset Management Avail asset management fees generally range from 0% to 1.35% per annum of the net market value of a client’s account managed by Avail. Clients may pay a different fee in each account dependent on the assets within that account. Fees are negotiable and may be higher or lower than this range, based on the nature of the account, and the origin of the client. Factors affecting fee percentages include the size of the account, complexity of asset structures, the non-management services provided to the client, and any other unique factors that may exist. All clients, but especially those with smaller accounts, should be advised they may receive similar services from other professionals for higher or lower overall costs. 529 Plans 529 plans managed by Avail are charged .25% per annum of the net market value of the 529 plan account. The fees are deducted directly from the 529 plan account by the custodian. Avail in its sole discretion may lower the fee charged on 529 plans. B. Fee Payment Financial Planning Financial planning services are charged as a flat fee to the client. Financial planning fees range from $2,500 to $15,000 depending on the scope of the planning and the complexity of the clients financial situation. Fees will be paid by the client either upon engagement of Avail or 50% of the fixed fee upon engagement of Avail and 50% upon the completion of services as described and mutually agreed upon in the financial planning agreement. Asset Management For clients whose assets are managed by the firm, investment advisory fees will be debited directly from each client’s account in accordance with the annual fee percentage indicated in the agreement entered into between Avail and the client. The advisory fee is paid quarterly in advance, and the value used for the fee calculation is the last business day of the prior quarter. The value of the client’s assets for the purpose of calculating advisory fees will include the most recently available value of any private investments in which the client is invested. The annual advisory fee percentage is broken down into a daily rate, and then Avail multiplies the daily percentage rate by the number of days in the upcoming quarter to calculate the quarterly rate. The quarterly rate is then applied to the value as of the last business day of the prior quarter to determine the quarterly fee to be charged. To the extent there is cash in your account, it will be included in the value for the purpose of calculating fees. Avail also tracks cash flows into and out of an account throughout the quarter. Avail will prorate the quarterly fee based on the days that the cash was active/inactive in the account for that prior quarter. This will be included as an additional “prior period” fee or rebate for the 4  prior quarter on the current cycle billing for the account, along with the full quarter of billing- Adjustments from the prior quarter would flow through the subsequent period. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by a qualified custodian chosen by the client. Avail is to invoice the qualified custodian for fees. Each quarter, the client will receive a statement from their account custodian showing all transactions in their account, including the fee. Avail encourages clients to carefully review the statements and confirmations sent to them by their custodian, and to compare the information on reports prepared by Avail against the information in the statements provided directly from the custodian. Please alert Avail of any discrepancies. Sub Advisory Fees ‐ ‐ As discussed in Item 4, Avail utilizes the services of sub advisers to manage client accounts. Fees for the sub-advisor services are included in the total fee charged to the client by Avail and are calculated as described above in accordance with the client advisory agreement. AssetMark deducts the stated client fee from the client account, retains their portion of the fee as per the contract with Avail, and then distributes the remaining revenue to Avail. C. Other Fees There are a number of other fees that can be associated with holding and investing in securities. Expenses of a mutual fund or ETF will not be included in management fees, as they are deducted from the value of the shares by the manager. When selecting mutual funds that have multiple share classes for recommendation to clients, Avail will take into account the internal fees and expenses associated with each share class, and it is Avail policy to choose the lowest-cost share class available, absent circumstances that dictate otherwise. For complete discussion of expenses related to each mutual fund or ETF, you should read a copy of the prospectus issued by that fund. Avail can provide or direct you to a copy of the prospectus for any fund that we recommend to you. Fees charged by independent third party managers are also separate and additional to any fees paid to Avail. Please make sure to read Item 12 of this informational brochure, where we discuss broker- dealer and custodial issues. D. Pro-rata Fees Pro-rated Fees If you become a client during a quarter, you will pay a management fee for the number of days left in that quarter. If you terminate our relationship during a quarter, you will be responsible for the payment of management fees for the portion of the quarter during which you were a client. Once your notice of termination is received, we will assess pro-rated fees for the number of days between the end of the prior billing period and the date of termination and issue any refund if necessary. Once the notice of termination is received, Avail will assess pro-rated fees to be paid in whatever way clients direct (check, wire). Avail will cease to perform services, including processing trades and distributions, upon termination. Assets not transferred from terminated accounts within 30 (thirty) days of termination may be “de- linked”, meaning they will no longer be visible to Avail and will become a retail account with the custodian. E. Compensation for the Sale of Securities. Avail does not accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. 5  Item 6: Performance-Based Fees Avail will not charge performance-based fees. Item 7: Types of Clients Clients advised may include individuals, families, trusts, charitable organizations and foundations, businesses, and pension plans. Avail does not impose a stated minimum fee or minimum portfolio value for starting or maintaining an investment advisory relationship. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss It is important for you to know and remember that all investments carry risks. Investing in securities involves risk of loss that clients should be prepared to bear. Strategies and Methods of Analysis Avail manages client assets using a predominantly top-down approach. We believe that in the current global economy, individual securities will tend to increase in value if the macroeconomic conditions are such that it can increase. The converse would also follow individual securities will go down if the macroeconomic factors are not favorable. In addition, some sectors or individual securities may perform better or worse depending on where they are in a cycle that may be determined by time or outside economic conditions. It is with these concepts in mind that Avail begins to construct client portfolios. There may be specific securities where this is limited or no research information available, and in those instances, Avail will not be able to assist clients with recommendations regarding those securities. Investment Allocations & Investment Programs Each client’s portfolio will be invested according to that client’s investment objectives, which are ascertained through the financial planning process or through a review of the existing plan. Once we ascertain your objectives for each account, using our evidence-based investment philosophy, we will develop a set of asset allocation guidelines that will aide in executing the proper allocation strategy. Using fundamental analysis, we base our conclusions on predominantly publicly available research, such as regulatory filings, press releases, competitor analyses, and in some cases research we receive from our custodian or other market analyses. The investment programs are not investment products. Clients may have different needs than others within the same investment program. Accordingly, not all clients in each investment program will have the exact same percentages of each underlying investment. The investment strategies that we recommend are based on the needs of the client as compared with the typical behavior of that security type or manager, current market conditions, the client’s current financial situation, financial goals, and the timeline to meet those goals, while emphasizing value and momentum within the market. Because we develop an investment strategy based on your personal situation and financial goals, your asset allocation guidelines may be similar to or different from another client. We may periodically recommend changes to the investment strategies and client portfolios to meet the guidelines of the asset allocation for the program or an individual client’s objectives. It is important to remember that because market conditions can vary greatly, your asset allocation guidelines are not necessarily strict rules. Rather, we review accounts 6  individually, and may deviate from the guidelines as we believe necessary. When Avail makes changes to an investment strategy, these changes may not be made simultaneously. Rather, some accounts may be modified before others. This may result in accounts being traded earlier inadvertently having an advantage over accounts traded later. Additionally, as assets are transitioned from a client’s prior advisors to Avail, clients may hold legacy securities and may place restrictions on individual security types. Legacy securities are those that a client owned prior to or separate from its Avail portfolio. If a client transitions mutual fund shares to Avail that are not the lowest-cost share class, and Avail is not recommending disposing of the security altogether, Avail will attempt to convert such mutual fund share classes into the lowest-cost share classes the client is eligible for, taking into account any adverse tax consequences associated with such conversion. Risk of Loss There are always risks to investing. Clients should be aware that all investments carry various types of risk including the potential loss of principal that clients should be prepared to bear. It is impossible to name all possible types of risks. Among the risks are the following: • Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world. • General Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations. • Currency Risk. When investing in another country using another currency, the changes in the value of the currency can change the value of your security value in your portfolio. • Regulatory Risk. Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments. • Tax Risks Related to Short Term Trading: Clients should note that Avail may engage in short-term trading transactions. These transactions may result in short term gains or losses for federal and state tax purposes, which may be taxed at a higher rate than long term strategies. Avail endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts. • Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply. • Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under business risk. Cyclical companies (like automobile companies) have more business risk because of the less steady income stream. On the other hand, fast food chains tend to have steadier income streams and therefore, less business risk. • Financial Risk. The amount of debt or leverage determines the financial risk of a company. • Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk. • Margin Risk. “Margin” is a tool used to maximize returns on a given investment by using securities in a client account as collateral for a loan from the custodian to the client. The proceeds of that loan are then used to buy more securities. Margin carries a higher degree 7  of risk than investing without margin. • Information Risk. All investment professionals rely on research in order to make conclusions about investment options. This research is always a mix of both internal (proprietary) and external (provided by third parties) data and analyses. Even an adviser who says they rely solely on proprietary research must still collect data from third parties. This data, or outside research is chosen for its perceived reliability, but there is no guarantee that the data or research will be completely accurate. Failure in data accuracy or research will translate to a compromised ability by the adviser to reach satisfactory investment conclusions. • Small Companies. Some investment opportunities in the marketplace involve smaller issuers. These companies may be starting up or are historically small. While these companies sometimes have potential for outsized returns, they also have the potential for losses because the reasons the company is small are also risks to the company’s future. For example, a company’s management may lack experience, or the company’s capital for growth may be restricted. These small companies also tend to trade less frequently that larger companies, which can add to the risks associated with their securities because the ability to sell them at an appropriate price may be limited compared to the markets as a whole. Not only do these companies have investment risk, if a client is invested in such small companies and requests immediate or short-term liquidity, these securities may require a significant discount to value in order to be sold in a shorter time frame. • Concentration Risk. While Avail selects individual securities, including mutual funds, for client portfolios based on an individualized assessment of each security, this evaluation comes without an overlay of general economic or sector specific issue analysis. This means that a client’s equity portfolio may be concentrated in a specific sector, geography, or sub- sector (among other types of potential concentrations), so that if an unexpected event occurs that affects that specific sector or geography, for example, the client’s equity portfolio may be affected negatively, including significant losses. • Transition risk. As assets are transitioned from a client’s prior advisers to Avail there may be securities and other investments that do not fit within the asset allocation strategy selected for the client. Accordingly, these investments will need to be sold in order to reposition the portfolio into the asset allocation strategy selected by Avail. However, this transition process may take some time to accomplish. Some investments may not be unwound for a lengthy period of time for a variety of reasons that may include unwarranted low share prices, restrictions on trading, contractual restrictions on liquidity, or market-related liquidity concerns. In some cases, there may be securities or investments that are never able to be sold. The inability to transition a client's holdings into recommendations of Avail may adversely affect the client's account values, as Avail’s recommendations may not be able to be fully implemented. • Restriction Risk. Clients may at all times place reasonable restrictions on the management of their accounts. However, placing these restrictions may make managing the accounts more difficult, thus lowering the potential for returns. • Risks Related to Investment Term & Liquidity. Securities do not follow a straight line up in value. All securities will have periods of time when the current price of the security is not an accurate measure of its value. If you require us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had the investment had the opportunity to regain its value. Further, some investments are made with the intention of the investment appreciating over an extended period of time. Liquidating these investments prior to their intended time horizon may result in losses. • REITs: Avail may recommend that portions of client portfolios be allocated to real estate investment trusts, otherwise known as “REITs”. A REIT is an entity, typically a trust or corporation that accepts investments from a number of investors, pools the money, and then uses that money to invest in real estate through either actual property purchases or mortgage loans. While there are some benefits to owning REITs, which include potential tax benefits, income and the relatively low barrier to invest in real estate as compared to directly investing in real estate, REITs also have some increased risks as compared to more traditional investments such as stocks, bonds, and mutual funds. First, real estate investing can be 8  highly volatile. Second, the specific REIT chosen may have a focus such as commercial real estate or real estate in a given location. Such investment focus can be beneficial if the properties are successful but lose significant principal if the properties are not successful. REITs may also employ significant leverage for the purpose of purchasing more investments with fewer investment dollars, which can enhance returns but also enhances the risk of loss. The success of a REIT is highly dependent upon the manager of the REIT. Clients should ensure they understand the role of the REIT in their portfolio. • MLPs: Avail may recommend that portions of client portfolios be allocated to master limited partnerships, otherwise known as “MLPs”. An MLP is a publicly traded entity that is designed to provide tax benefits for the investor. In order to preserve these benefits, the MLP must derive most, if not all, of its income from real estate, natural resources and commodities. While MLPs may add diversification and tax favored treatment to a client’s portfolio, they also carry significant risks beyond more traditional investments such as stocks, bonds and mutual funds. One such risk is management risk-the success of the MLP is dependent upon the manager’s experience and judgment in selecting investments for the MLP. Another risk is the governance structure, which means the rules under which the entity is run. The investors are the limited partners of the MLP, with an affiliate of the manager typically the general partner. This means the manager has all of the control in running the entity, as opposed to an equity investment where shareholders vote on such matters as board composition. There is also a significant amount of risk with the underlying real estate, resources or commodities investments. Clients should ask Avail any questions regarding the role of MLPs in their portfolio. • BDCs (Business Development Companies): Business Development Companies (BDCs) are a specific subset of investment companies that receive preferential tax treatment provided they meet certain investment restrictions and other regulatory requirements. Because BDCs are managed by third parties and are frequently chosen for the perceived strength of their managers, the investment thesis, and tax treatment, the risks associated with a BDC investment generally follow directly from the manager, in that the manager ultimately controls the investments, and can adversely impact the tax treatment of the vehicle. Additional risks exist and may be specific to the particular BDC. Accordingly, investors should carefully review the BDC’s prospectus and any addendums thereto. • Risks specific to sub-advisors, other managers and private placements: If Avail invests some of your assets with another advisor, including a private placement, there are additional risks. These include risks that the other manager is not as qualified as we believe them to be, that the investments they use are not as liquid as we would normally use in your portfolio, or their risk management guidelines are more liberal than we would normally employ. The third-party manager who has been successful in the past may not be able to replicate that success in the future. Private funds are pooled investment vehicles, and each pooled investment vehicle is managed according to the stated investment program in the respective private fund’s private placement memorandum. This means that individual investors in a fund will not receive individual asset management within the fund. In addition, as we do not control the underlying investments in a third-party manager’s portfolio (even if the portfolio is managed by an affiliate), there is also a risk that a manager may deviate from the stated investment mandate or strategy of the portfolio, making it a less suitable investment for a particular client. Moreover, when we do not control the manager’s daily business and compliance operations, it is possible for us to miss the absence of internal controls necessary to prevent business, regulatory or reputational deficiencies. Accordingly, clients investing in private funds should carefully read that fund’s private placement memorandum, and clients investing through a third-party manager should carefully read that manager’s Form ADV. • Use of Artificial Intelligence by Avail: Avail employs artificial intelligence using a number of platforms for the purpose of improving efficiency in firm operations. Specifically, Avail utilizes artificial intelligence to take notes during meetings and to gather data from our records for the purpose of reviewing that data as part of our decision making process. Avail has evaluated the security of these platforms, and does not use any platform that uses client information to train its models or that maintains sensitive client information in its records. The 9  platforms we use discard any audio from recordings used to create the note-taking. Further, human input is required by Avail policy to ensure notes from meetings are accurate, and any data aggregation or document summaries are accurate. The use of these platforms will be reviewed periodically to ensure confidentiality and accuracy as well as efficiency. • Artificial Intelligence and Impact on Businesses: Avail believes artificial intelligence is likely to be a significant part of the success or failure of any business in the years to come. Businesses that can efficiently utilize AI will, we believe, be at an advantage over those who do not. This does not just include businesses in which one may invest, such as publicly traded companies and the ETFs or mutual funds that purchase shares in those companies. It also includes the fund managers and other investment firms that manage those ETFs and mutual funds. Avail will have limited visibility, if any, to the true uses, programs and safeguards related to AI that any business outside of Avail has. Accordingly, we are unable to accurately measure or predict the risk AI might post to those businesses. Cryptocurrency Risk Disclosure Investing in crypto assets carries additional risks: • Volatility and Market Risk: Crypto assets are highly speculative and volatile. Prices can fluctuate dramatically and unpredictably, and there is a significant risk of losing all of your investment. They may experience sudden and drastic price swings, including significant declines in value. The value of cryptocurrency investments can be significantly impacted by a wide array of factors, including market sentiment, technological advancements, regulatory changes, and broader economic conditions. • Liquidity Risk: Some crypto assets may be illiquid, making it difficult to sell quickly at a reasonable price, particularly during periods of market stress. This illiquidity can exacerbate price fluctuations and make it challenging to exit positions quickly. • Regulatory Uncertainty: The regulatory landscape for crypto assets is still developing and is subject to change at both federal and state levels. Future regulatory actions could significantly impact the value and trading of crypto assets. • Custody and Security Risks: Storing and securing crypto assets presents unique challenges. Theft, hacking, and loss of private keys can lead to irreversible losses. While efforts are made to protect assets, some crypto asset service providers may be more vulnerable to cybersecurity risks and theft than others. • Fraud and Manipulation: The crypto asset market is susceptible to scams, fraud (including Ponzi and pyramid schemes), market manipulation, and other illicit activities. The pseudonymous nature of crypto assets can also make it difficult to recover lost or stolen funds. • Technological Risks: Crypto assets rely on complex and evolving technologies. Technical glitches, software bugs, and other technological issues could disrupt operations or negatively impact the value of crypto assets. Cryptocurrencies are vulnerable to various technological risks, including hacking, malware, and other cyberattacks that could lead to theft or loss of assets. The security of digital wallets, exchanges, and blockchain networks is crucial and requires robust security practices. • Operational Risks: The trading platforms, exchanges, and other third-party service providers involved in the crypto asset ecosystem may experience operational problems, security breaches, or even cease operations, potentially leading to losses. • Lack of SIPA Coverage: Crypto assets may not be covered by the Securities Investor Protection Act (SIPA), meaning that protections afforded to securities customers through SIPA might not apply, even if held by a broker-dealer that is a member of the Securities Investor Protection Corporation (SIPC). Additionally, risks specific to RIA Clients include but are not limited to the following: 10  • Suitability: Investing in crypto assets may not be suitable for all investors, especially those with limited experience, low-risk tolerance, or who are using funds drawn from retirement savings, emergency funds, or other critical sources. • Due Diligence: RIAs such as Radnor have a fiduciary duty to conduct thorough due diligence and ensure the appropriateness of crypto investments for clients, including assessing suitability, valuation methodologies, and custody controls. We confirm this has been conducted. • Valuation Challenges: The unique nature of crypto assets can make accurate and consistent valuation difficult. • Recordkeeping and Reporting: RIAs must maintain accurate records of client holdings and transactions, which can be challenging given the nature of crypto assets. We confirm we have recordkeeping capabilities. • Conflicts of Interest: RIAs must disclose any potential conflicts of interest related to crypto investments and ensure that their advice is solely in the client's best interest. We confirm that we have no conflicts of interest. Investment Research Partners Avail allocates assets predominantly to the strategies managed by its affiliate, Investment Research Partners, LLC. Investment Research Partners is owned by Geoffrey Caber, Brett Greenfield, Derek Varner and Martin Wildy who are also owners of Avail. Avail may also utilize the services of other managers when Avail deems appropriate for a client. Investment Research Partners, LLC, like other managers, is chosen based on investment performance, operations, and offerings to determine if the manager would be a fit for Avail clients. This process continues on an ongoing basis, throughout the time the client works with the third- party manager. It is important to note that these managers, including Investment Research Partners, LLC will charge a separate and additional fee, for their services. Avail will consider these fees in its decision to recommend the use of a third-party manager. The use of IRP as a sub advisor is a conflict of interest because Avail shares common control with IRP where the principal owners of Avail can financially benefit from the use of IRP as a sub advisor. Avail mitigates this conflict by disclosing it to the public and performing due diligence on the manager. The use of a third-party manager, including Investment Research Partners, LLC, does not change the relationship between Avail and the client, in that Avail will still manage the overall client portfolio, adding, subtracting and modifying the allocations to different strategies and managers. Item 9: Disciplinary Information In 2017, our Chief Compliance Officer, Ashleigh Swayze, signed a Consent Order with the Connecticut Department of Banking and Insurance. The underlying matter involved a client of Ms. Swayze’s that failed to register as an investment adviser representative in Connecticut. The state felt that Ms. Swayze’s firm should have followed this client’s activities and required her to register, despite not being engaged to do so. Item 10: Other Financial Industry Activities and Affiliations A. Broker-dealer The principals of Avail, nor any related persons are registered, or have an application pending to register, as a broker dealer or as an associated person of the foregoing entities. B. Futures Commission Merchant/Commodity Trading Advisor 11  Neither the principals of Avail, nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. C. Relationship with Related Persons Investment Research Partners, LLC Avail is a related entity to Investment Research Partners LLC (“IRP”) due to common control. Please see above in Item 8 in regard to IRP. Private Funds IRP is an owner in the Foundation Premium Income Fund GP, LLC which serves as the general partner to the Foundation Premium Income Fund, LP (“FPIF”). As the general partner, Foundation Premium Income Fund GP, LLC (the “General Partner”) directs the investments made on behalf of FPIF. As compensation for the investment management services provided to FPIF, the General Partner receives management fees paid by investors in FPIF. Accordingly, a conflict of interest exists where Avail recommends that clients invest in FPIF, because IRP, which shares common control with Avail, through its ownership of part of the General Partner, receives a portion of the management fee. An additional conflict of interest exists in the fact that management of FPIF’s investments and other affairs will require the attention of IRP’s principals, who may be less able to devote time to Avail. Avail attempts to mitigate this conflict by disclosing it to clients and requiring employees of Avail to acknowledge the firm’s Code of Ethics, their individual fiduciary duty to the clients of Avail, which requires that employees put the interests of clients ahead of their own. Further, no clients of Avail will invest in FPIF without receiving this conflict disclosure, and all clients who invest in FPIF will do so a non-discretionary basis. IRP is an owner in the Foundation Global Infrastructure Fund GP, LLC which serves as the general partner to the Foundation Global Infrastructure Fund, LP (“FGIF”). As the general partner, Foundation Global Infrastructure Fund GP, LLC (the “FGIF General Partner”) directs the investments made on behalf of FGIF. As compensation for the investment management services provided to FGIF, the FGIF General Partner receives management fees paid by investors in FGIF. Accordingly, a conflict of interest exists where Avail recommends that clients invest in FGIF, because IRP, through its ownership of part of the FGIF General Partner, receives a portion of the management fee, and IRP’s principals are also principals of Avail. An additional conflict of interest exists in the fact that management of the FGIF’s investments and other affairs will require the attention of IRP’s principals. Avail attempts to mitigate this conflict by disclosing it to clients and requiring employees of Avail to acknowledge the firm’s Code of Ethics, their individual fiduciary duty to the clients of Avail, which requires that employees put the interests of clients ahead of their own. Further, no clients of Avail will invest in the FGIF without receiving this conflict disclosure, and all clients who invest in the FGIF will do so a non- discretionary basis. IRP is the manager of New Lantern Hedged Equity Fund, LP (“New Lantern Fund”). As the investment manager, IRP directs the investments made on behalf of New Lantern Fund. As compensation for the investment management services provided to New Lantern Fund, IRP receives management fees paid by investors in New Lantern Fund that are in addition to and separate from the advisory fees paid to Avail. Accordingly, a conflict of interest exists where IRP recommends that clients invest in New Lantern Fund, because IRP, by being the manager of New Lantern Fund, receives a management fee. Assets invested in New Lantern Fund will be counted in assets under management for 12  the purpose of calculating management fees due to Avail. Further, New Lantern Fund’s general partner, New Lantern Capital, LLC is owned by Michael Allison, who is an investment adviser representative of IRP. Avail will consider the additional fees to New Lantern Fund as part of its diligence and evaluation process in determining whether to recommend that a client invest in New Lantern Fund. Because an affiliate (in this case, IRP) will receive indirect compensation because of investments in the Funds, Avail has a material conflict of interest when evaluating New Lantern Fund as a potential investment for a client. We attempt to mitigate this conflict by disclosing it to our clients both in this Form ADV and in a separate written disclosure to all investors that are clients of Avail. Further, all supervised persons of Avail are required to read and follow the firm’s Code of Ethics, which reminds our advisors of their fiduciary duty to place client interests ahead of their own. Further, no clients of IRP or Avail will invest in New Lantern Fund without receiving this conflict disclosure, and all clients who invest in New Lantern Fund will do so on a non-discretionary basis. IRP is an owner of the manager (the “Manager”) of OneAscent Capital Impact Fund, LP. (“OneAscent Capital”). As part of the investment manager, IRP is in part responsible for the oversight of the investment committee and the underlying portfolio assets. As compensation for the investment management services provided to OneAscent Capital, the Manager receives management fees paid by investors in OneAscent Capital. Accordingly, a conflict of interest exists where IRP recommends that clients invest in OneAscent Capital, because IRP, through its ownership of part of the Manager, receives a portion of the management fee. An additional conflict of interest exists in the fact that management of OneAscent Capital's investments and other affairs will require the attention of IRP’s principals, which means they may have less time to devote to Avail. Avail attempts to mitigate this conflict by disclosing it to clients and requiring employees of Avail to acknowledge the firm’s Code of Ethics, their individual fiduciary duty to the clients of Avail, which requires that employees put the interests of clients ahead of their own. Further, no clients of Avail will invest in OneAscent Capital without receiving this conflict disclosure, and all clients who invest in OneAscent Capital will do so a non- discretionary basis. D. Recommendations of Other Advisers As discussed in Item 8, Avail may recommend the use of one or more third party managers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A copy of our Code of Ethics is available upon request. Our Code of Ethics includes A. discussions of our fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines. IRP is an owner in the Foundation Premium Income Fund GP, LLC which serves as B. the general partner to the Foundation Premium Income Fund, LP (“FPIF”). As the general partner, Foundation Premium Income Fund GP, LLC (the “General Partner”) directs the investments made on behalf of FPIF. As compensation for the investment management services provided to FPIF, the General Partner receives management fees paid by investors in FPIF. Accordingly, a conflict of interest exists where Avail recommends that clients invest in FPIF, because IRP, which shares common control with Avail, through its ownership of part of the General Partner, receives a portion of the management fee. An additional conflict of interest exists in the fact that management of FPIF’s investments and other affairs will require the attention of IRP’s principals, who may be less able to devote time to Avail. Avail attempts 13  to mitigate this conflict by disclosing it to clients and requiring employees of Avail to acknowledge the firm’s Code of Ethics, their individual fiduciary duty to the clients of Avail, which requires that employees put the interests of clients ahead of their own. Further, no clients of Avail will invest in FPIF without receiving this conflict disclosure, and all clients who invest in FPIF will do so a non-discretionary basis. IRP is an owner in the Foundation Global Infrastructure Fund GP, LLC which serves as the general partner to the Foundation Global Infrastructure Fund, LP (“FGIF”). As the general partner, Foundation Global Infrastructure Fund GP, LLC (the “FGIF General Partner”) directs the investments made on behalf of FGIF. As compensation for the investment management services provided to FGIF, the FGIF General Partner receives management fees paid by investors in FGIF. Accordingly, a conflict of interest exists where Avail recommends that clients invest in FGIF, because IRP, through its ownership of part of the FGIF General Partner, receives a portion of the management fee, and IRP’s principals are also principals of Avail. An additional conflict of interest exists in the fact that management of the FGIF’s investments and other affairs will require the attention of IRP’s principals. Avail attempts to mitigate this conflict by disclosing it to clients and requiring employees of Avail to acknowledge the firm’s Code of Ethics, their individual fiduciary duty to the clients of Avail, which requires that employees put the interests of clients ahead of their own. Further, no clients of Avail will invest in the FGIF without receiving this conflict disclosure, and all clients who invest in the FGIF will do so a non-discretionary basis. C. On occasion, an employee of Avail may purchase for his or her own account securities which are also recommended for clients. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade, so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. On occasion, an employee of Avail may purchase for his or her own account securities D. which are also recommended for clients at the same time the clients purchase the securities. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades are reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade, so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. Item 12: Brokerage Practices A. Recommendation of Broker-Dealer Avail recommends that investment accounts be held in custody by qualified Custodian. Avail selects custodians based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Following are additional details regarding the brokerage practices of Avail: 1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an adviser enters into an agreement to place security trades with a broker- dealer/custodian in exchange for research and other services. Avail does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian. 14  2. Brokerage Referrals - Avail does not receive any compensation from any third party in connection with the recommendation for establishing an account. 3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, by Custodians unless otherwise suggested by the Client and approved by Avail. Further, all Client accounts are traded within their respective account[s]. Avail does not engage in any principal transactions (i.e., trade of any security from or to the Adviser’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]). Avail will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. We do not consider whether a Custodian refers clients to Avail as part of our evaluation of these broker-dealers. B. Aggregating Trades To the extent that Avail provides investment management services to its clients, the transactions for each client account generally will be effected independently, unless Avail decides to purchase or sell the same securities for several clients at approximately the same time. Avail may (but is not obligated to) combine or “bunch” such orders to obtain best execution, to negotiate more favorable commission rates or to allocate equitably among Avail’s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will be averaged as to price and will be allocated among clients in proportion to the purchase and sale orders placed for each client account on any given day. Avail shall not receive any additional compensation or remuneration as a result of such aggregation. Directed Brokerage Avail allows clients to direct brokerage. “Directing” brokerage means choosing to maintain all or some of their assets with a broker-dealer that is not recommended by Avail. Avail may be unable to achieve most favorable execution of client transactions if clients choose to direct brokerage. This may cost clients’ money because without the ability to direct brokerage Avail may not be able to aggregate orders to reduce transactions costs resulting in higher brokerage commissions and less favorable prices. Not all investment advisers allow their clients to direct brokerage. Right Capital Avail may provide its clients with access to an online platform hosted by Right Capital. The Right Capital platform allow clients to view their complete asset allocation, including those assets that Avail does not manage (the “Excluded Assets”). Avail does not provide investment management, monitoring, or implementation services for the Excluded Assets. Therefore, Avail shall not be responsible for the investment performance of the Excluded Assets. Rather, the client and/or their advisor(s) that maintain management authority for the Excluded Assets, and not Avail, shall be exclusively responsible for such investment performance. The client may choose to engage Avail to manage some or all of the Excluded Assets pursuant to the terms and conditions of an Investment Advisory Agreement between Avail and the client. The Right Capital platform also provides access to other types of information, including financial planning concepts, which should not, in any manner whatsoever, be construed as services, advice, or recommendations provided by Avail. Finally, Avail shall not be held responsible for any adverse results a client may experience if the client engages in financial planning or other functions. 15  Item 13: Review of Accounts All accounts will be reviewed by Avail when triggering events occur such as market conditions, changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts. Item 14: Client Referrals and Other Compensation A. Economic Benefit Provided by Third Parties for Advice Rendered to Client. Please refer to Item 12, where we discuss recommendation of Broker-Dealers. B. Compensation to Non-Advisory Personnel for Client Referrals. Avail does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody There are two avenues through which Avail has custody of client funds; by directly debiting its fees from client accounts pursuant to applicable agreements granting such right, and potentially by permitting clients to issue standing letters of authorization (“SLOAs”). SLOAs permit a client to issue one document that directs Avail to make distributions out of the client’s account(s). Clients will receive statements directly from the account custodian, and copies of all trade confirmations directly from the account custodian. Clients whose fees are directly debited will provide written authorization to debit advisory fees from their accounts held by the qualified custodian. Each month, the client will receive a statement from their account custodian showing all transactions in their account, including the fee. We encourage clients to carefully review the statements and confirmations sent to them by their custodian, and to compare the information on reports prepared by Avail against the information in the statements provided directly from the custodian. Please alert us of any discrepancies. In addition to the account custodian’s custody procedures, clients issuing SLOAs will be requested to confirm, in writing, that the accounts to which funds are distributed are parties unrelated to Avail or the account custodian. Item 16: Investment Discretion When Avail is engaged to provide asset management services on a discretionary basis, we will monitor your accounts to ensure that they are meeting your asset allocation requirements. If any changes are needed to your investments, we will make the changes. These changes may involve selling a security or group of investments and buying others or keeping the proceeds in cash. You may at any time place restrictions on the types of investments we may use on your behalf, or on the allocations to each security type. You may receive at your request written or electronic confirmations from your account custodian after any changes are made to your account. You will also receive statements at least quarterly from your account custodian. Clients engaging us on a discretionary basis will be asked to execute a Limited Power of Attorney (granting us the discretionary authority over the client accounts) as well as an Investment Advisory Agreement that outlines the responsibilities of both the client and Avail. 16  Item 17: Voting Client Securities Copies of our Proxy Voting Policies are available upon request. From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may be permitted to vote on various types of corporate actions. Examples of these actions include mergers, tender offers, or board elections. Clients are required to vote proxies related to their investments, or to choose not to vote their proxies. Avail will not accept authority to vote client securities. Clients will receive their proxies directly from the custodian for the client account. Avail will not give clients advice on how to vote proxies. Item 18: Financial Information Avail does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients. 17