Overview
- Headquarters
- San Rafael, CA
- Average Client Assets
- $4.2 million
- Minimum Account Size
- $250,000
- SEC CRD Number
- 118538
Fee Structure
Primary Fee Schedule (BROCHURE FOR ALL CLIENTS)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $250,000 | 1.50% |
| $250,001 | $1,500,000 | 1.00% |
| $1,500,001 | $3,000,000 | 0.75% |
| $3,000,001 | and above | 0.50% |
Minimum Annual Fee: $1,500
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $11,250 | 1.12% |
| $5 million | $37,500 | 0.75% |
| $10 million | $62,500 | 0.62% |
| $50 million | $262,500 | 0.52% |
| $100 million | $512,500 | 0.51% |
Clients
- HNW Share of Firm Assets
- 86.78%
- Total Client Accounts
- 172
- Discretionary Accounts
- 172
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Investment Advisor Selection
Regulatory Filings
Primary Brochure: BROCHURE FOR ALL CLIENTS (2026-03-19)
View Document Text
PART 2A
ITEM 1: COVER SHEET
AWR Investment Management, LLC
Office Address
883 Fourth Street
San Rafael, CA 94901
(415) 457-9415
Mailing Address
300 Laurel Avenue
San Anselmo, CA 94960
andy@awrinvestmentmanagement.com
www.awrinvestmentmanagement.com
February 9, 2026
This brochure provides information about the qualifications and business practices of AWR Investment
Management, LLC. If you have any questions about the contents of this brochure, please contact us at the
telephone number and/or e-mail address above. The information in this brochure has not been approved
or verified by the United States Securities and Exchange Commission or any state securities authority.
Our e-mail for regulatory compliance is awr@awrinvestmentmanagement.com.
AWR Investment Management, LLC is a registered investment advisor. Registration of an investment
advisor does not imply any level of skill or training. The verbal and written communications of an
investment adviser provide you with information you need to determine whether to hire or retain the
advisor.
Additional information about AWR Investment Management, LLC is also available on the SEC’s website
at www.adviserinfo.sec.gov. The Firm’s CRD number is 118538.
PART 2A
ITEM 2: MATERIAL CHANGES
AWR Investment Management, LLC
Our previous annual updating amendment was dated February 4, 2025. This item will be updated with
the next annual updating amendment to reflect material changes to the Part 2.
Item 4:
Investment Implementations: AWR uses primarily mutual funds, exchange traded funds, and separate
managed accounts for investment implementations.
Assets under management: As of December 31, 2025, we manage assets of $131.6 million on a
discretionary basis.
Please contact us at (415) 457-9415 or andy@awrinvestmentmanagement.com if you would like a copy
of our updated Part 2. Additional information about us is also available on the SEC’s website at
www.adviserinfo.sec.gov.
ITEM 3
TABLE OF CONTENTS
Item 1: Cover Sheet
Item 2: Material Changes
Item 3: Table of Contents
Item 4: Advisory Business ........................................................................................................................... 1
Who we are ............................................................................................................................................... 1
Services we offer....................................................................................................................................... 1
Assets under management......................................................................................................................... 3
Item 5: Fees and Compensation ................................................................................................................... 3
Item 6: Performance-Based Fees and Side-By-Side Management .............................................................. 4
Item 7: Types of Clients............................................................................................................................... 4
Item 8: Methods of Analysis, Investment Strategies and Risk of Loss........................................................ 5
Item 9: Disciplinary Information ................................................................................................................. 5
Item 10: Other Financial Industry Activities and Affiliations ..................................................................... 5
Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 6
Code of Ethics........................................................................................................................................... 6
Personal Trading for Associated Persons.................................................................................................. 6
Item 12: Brokerage Practices ....................................................................................................................... 7
The Custodian and Brokers We Use ......................................................................................................... 7
How We Select Brokers/Custodians ......................................................................................................... 7
Your Brokerage and Custody Costs.......................................................................................................... 8
Products and Services Available to Us From Schwab .............................................................................. 8
Our Interest in Schwab's Services............................................................................................................. 9
Aggregation of Orders .............................................................................................................................. 9
Directed Brokerage ................................................................................................................................. 10
Soft Dollars ............................................................................................................................................. 10
Item 13: Review of Accounts..................................................................................................................... 10
Item 14: Client Referrals and Other Compensation................................................................................... 10
Item 15: Custody........................................................................................................................................ 11
Item 16: Investment Discretion.................................................................................................................. 11
Item 17: Voting Client Securities............................................................................................................... 11
Item 18: Financial Information .................................................................................................................. 12
ITEM 4: ADVISORY BUSINESS
Who we are
AWR Investment Management, LLC (referred to as “we,” “our,” “us,” or “AWR”), has been registered as
an investment advisor since January 1999. Our principals are Andrew W. Ryan, Managing Member and
Chief Compliance Officer and Linda Ryan, Member. All investment advice is provided by Andrew Ryan.
Services we offer
We believe that a well-diversified strategically managed portfolio will perform better over the long-term,
with lower risk, than portfolios that are overly concentrated or market timing strategies. The following
components are key to our investment philosophy.
ASSET ALLOCATION - Our philosophy is based on Modern Portfolio Theory and asset allocation is the
largest component of a clients risk and return.
MANAGER SELECTION - We believe that our research and experience allows us to selectively direct
client's assets to managed portfolios or index strategies that give us the best opportunity to capture that
asset classes return while analyzing the risks involved.
CONTROLLING COST - We believe that cost to invest is critical in portfolio construction. Portfolios
are constructed to represent the asset classes and markets we target at the least expensive cost.
MANAGING RISK - We pay particular attention to managing risk in a portfolio. The three main areas
that we focus on are volatility, downside risk, and broad exposure. We measure these on a macro level
and on each investment selected.
IMPACT OF TAXES - We construct portfolios to minimize the impact of taxes. We consider the
allocation of investments across taxable and tax deferred accounts as well as trade activity and year-end
tax gain/loss harvesting options.
INDIVIDUALLY DESIGNED PORTFOLIOS - We construct a portfolio unique to your individual
needs. We will work around client's existing positions and outside investments like self-directed 401k
holdings. You may impose restrictions on the investments.
Client Meeting
AWR will meet with all clients to develop a personalized investment plan. The investment plan will
outline the client’s current investment holdings, long- and short-term investment objectives and risk
tolerances. AWR will discuss target asset allocation models and tactical allocation factors. Target asset
allocation models will further refine each client’s risk/reward tolerances and underlying investment
selection criteria.
Asset Allocation
AWR believes that a well-diversified strategically managed portfolio will perform better over the long-
term, with lower risk, than portfolios that are more concentrated or market timing strategies.
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Portfolio allocations are monitored and reported to clients on a quarterly basis. Portfolios are periodically
rebalanced to client specific asset allocation targets.
Investment Implementations
AWR uses primarily mutual funds, exchange traded funds, and separate managed accounts for investment
implementations. Separate managed accounts are portions of your portfolio that are managed by
unaffiliated investment managers, in a similar way as a mutual fund, but with much more transparency to-
and control by-AWR. These investments allow AWR to diversify across asset classes, market capital
weightings, and industry sectors, while selecting the best managers in each class. AWR will attempt to
purchase mutual fund shares at the lowest price available, using no-load or load-waived funds, and
institutionally priced shares offered to investment advisors. AWR does not, in the ordinary course of
business, implement investment strategies that use leverage, inversed investments, options, futures, or
margin. In addition, AWR does not, in the ordinary course of business, recommend investments or
unaffiliated investment managers that utilize these instruments. The investment management agreement
you enter into with us allows us to invest in a wide range of investments that may use leverage, inversed
investments, options, futures, or margin. These investments will only be utilized when a situation arises
that calls for them, and only after discussing the matter with you. When we find that we use any of the
aforementioned investments on a more regular basis, the disclosure in this brochure will be updated.
For large portfolios, AWR may, in addition to mutual funds and separate managed accounts, periodically
invest in individual equity securities and individual bond holdings. Bond portfolios are managed using a
“laddered” maturity of holdings. AWR does not exclude any type of security from consideration for its
clients’ investments.
Separate managed accounts are often used for larger accounts. Client’s assets are allocated across several
accounts with minimum account sizes ranging from $100,000 to $500,000 per account.
Tax consequences, for security positions initially transferred to a AWR account, are reviewed with clients
before selling and re-assigning proceeds to other investments.
Investment Manager Selection and Monitoring
AWR selects mutual funds and separate managed accounts advisors based on management discussions
and analysis, manager tenure, underlying expenses, past performance and most importantly, manager
sector expertise. Managers are expected to outperform their respective performance benchmarks for the
long term. AWR monitors all investments on an at least quarterly basis.
Continuous Portfolio Management
Individual attention and client support is paramount to asset management. As AWR learns and
understands more about each client and their goals and risk tolerances, investment holdings will be
adjusted to meet their long-term investment targets.
We do not provide portfolio management services to a wrap fee program.
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Financial Planning
AWR will periodically work with clients to build a financial plan outlining investments, assets, liabilities,
savings, expenses, estimated returns, inflation, taxes, and projected sources and uses of funds. This
review usually happens when the client is approaching retirement or has concerns about funding long-
term financial goals. The outcome of the plan is a long-term discounted cash flow analysis that gives the
client an understanding of realistic withdrawal rates and probability of success based on changes in key
underlying estimates and factors used to build the plan.
Assets under management
As of December 31, 2025, we manage assets of $131.6 million on a discretionary basis. We do not
manage any assets on a non-discretionary basis.
ITEM 5: FEES AND COMPENSATION
Advisory Fees & Billing Practices
Fees for investment management services are calculated as a percentage of assets under management.
These fees are billed quarterly in arrears, based on the assets under management as of the last day of the
calendar quarter. Our standard fee schedule is:
Assets under Management
Annual Fee
On the first $250,000
On amounts from $250,001 to $1,500,000
On amounts from $1,500,001 to $3,000,000
On amounts over $3,000,000
1.50%
1.00%
0.75%
0.50%
Minimum quarterly fee: $375
We may negotiate a discounted fee for clients based on total assets under management, relationship with
principals of AWR, and if they were directed or referred to us from CPA firms or other professionals.
Financial planning services are included in the above fees.
You may provide authorization for us to deduct our fees directly from your investment account.
Important information about the deduction of management fees:
You must provide authorization for us to pull fees by initialing the appropriate section of our
contract.
You will receive a statement from your custodian which shows your holdings.
You are responsible for reviewing the accuracy of the fees being billed, as the custodian will not
do so.
You may elect to pay by check rather than having payment deducted directly from your account.
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If you would like to end our advisory relationship, you may do so by providing 30 days’ written notice.
We will prorate the advisory fees earned through the termination date and send you an invoice for the
advisory fees due. In addition, you may terminate our relationship within 5 days after signing your
agreement, without penalty, if you did not receive this Form ADV Part 2 at least 48 hours before signing.
You will, however, be responsible for any cost associated with implementing the investment strategy, and
losses, if any, that occurred in your account, during the time we managed your assets.
Other Costs Involved
In order to use separate managed accounts, you are required to enroll in Schwab’s Managed Account
Select and/or Access programs. These programs incur fees that are disclosed when you sign up. These
fees are in addition to the fees charged by AWR. The regular tiered fees for these services are based on
the amount of assets invested in each selected strategy and start at 1% for equity and balanced strategies,
0.75% for ETF-based strategies, 0.65% for fixed income and index-based equity strategies, and 0.35% for
fixed income strategies. The percentages are lowered as the amount of the investment in a strategy
exceeds certain thresholds. As part of the enrollment process, you are required to grant AWR the
authority to hire and fire separate managed account managers, and the authority to commit you to pay the
fees charged by these separate managed account managers. AWR will not engage in a strategy that
charges more than 1% in additional management fees.
In addition to our advisory fee and costs shown above, you are responsible for paying fees associated with
investing for your account. These fees include:
management fees for ETFs and mutual funds. These are fees charged by the managers of the ETF
or mutual fund and are a portion of the expenses of the ETF or mutual fund.
brokerage costs and transaction fees for any securities or fixed income trades. These are
generally charged by your custodian and/or executing broker. These may include brokerage
costs and transaction fees incurred in the Schwab’s Managed Account Select and/or Access
programs.
Additional information about brokerage costs and services is provided in “Item 12: Brokerage Practices.”
We believe the fees mentioned above are competitive; you may, however, be able to obtain similar
services from other sources at a lower price.
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
We do not receive performance fees for managing accounts.
ITEM 7: TYPES OF CLIENTS
Our clients are generally individuals or families with assets in excess of $250k. Also, non-profit or
corporate investment pools that have a unified investment policy.
We generally require that you maintain $250,000 under management with us. However, we may waive
that minimum at our sole discretion.
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ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
AWR selects managed asset or index investments based on management discussions and analysis,
manager tenure, underlying fund expenses, past performance and manager sector expertise. Managers are
expected to outperform their respective performance benchmarks for the long term.
Past performance may not be indicative of future results. Asset class or sectors can realize performance
and volatility outside their average or normal historic risk and return percentage. Asset class correlations
can significantly fall outside their average at time of market stress.
AWR does not, in the ordinary course of business, implement investment strategies that use leverage,
inversed investments, options, futures, or margins. In addition, AWR does not, in the ordinary course of
business, recommend investments or unaffiliated investment managers that utilize these instruments.
However, under certain circumstances, we may add margin to accounts to facilitate a client’s cash flow
needs, in lieu of selling securities to create cash.
All investments involve different degrees of risk. You should be aware of your risk tolerance level and
financial situations at all times. We cannot guarantee the successful performance of an investment and
we are expressly prohibited from guaranteeing accounts against losses arising from market conditions.
ITEM 9: DISCIPLINARY INFORMATION
Registered investment advisors are required to disclose any material facts regarding any legal or
disciplinary actions that would be material to your evaluation of the investment advisor and each
investment advisor representative providing investment advice to you. We have no information of this
type to report.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS
Mr. Ryan is an Investment Advisory Representative with Heffernan Financial Services, a registered
investment advisory firm. Mr. Ryan expects to spend approximately 20% of his time in that capacity.
We feel that the time commitment for Mr. Ryan is the only significant conflict between the two entities.
AWR clients also receive benefits from the relationship, such as the additional ideas Mr. Ryan receives
from other investment professionals and improved access to investment options due to the fact of being
affiliated with a larger group or firm.
AWR will, at no time, receive compensation for recommending or implementing investment strategies
from the providers of the instruments that are used, other than the products and services described in
Items 12 and 14 of this Brochure. AWR will not utilize third party asset managers or subadvisors outside
of Schwab’s platform.
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ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING
Code of Ethics
We have adopted a set of enforceable guidelines (Code of Ethics), which describes unacceptable conduct by
AWR and our associated persons. Summarized, this Code of Ethics prohibits us from:
placing our interests before yours,
using non-public information gathered when providing services to you for our own gains, or
engaging in any act, practice or course of business that is, or might be considered, fraudulent,
deceptive, manipulative, or in violation of any applicable law, rule or regulation of a
governmental agency.
Please contact us if you would like to receive a full copy of this Code of Ethics.
We have also adopted a privacy policy that requires us and our affiliated persons to not disclose client
information to third parties for any purpose, other than required by law, or necessary to service your
account(s). This mean that your information will be disclosed if it is needed or required for account
maintenance, responding to state or federal requests, court ordered subpoenas, etc. Please refer to our
complete privacy policy statement that will be provided at contract signing and at least annually
thereafter.
Personal Trading for Associated Persons
We may buy or sell some of the same securities for you that we already hold in our personal account. We
may also buy for our personal account some of the same securities that you already hold in your account.
It is our policy not to permit our associated persons (or their immediate relatives) to trade in a way that
takes advantage of price movements caused by your transactions.
We may restrict trading for a particular security for our accounts or those of our associated person if there
is a pending trade in that security in a client account. Trades for our accounts (and those of our associated
persons) will be placed as part of a block trade with client trades, or individually after client trades have
been completed. Additional information about block trades is provided in the Aggregation of Orders
section of “Item 12: Brokerage Practices.” When our trades are placed after our client trades, we may
receive a better or worse price than that received by the client.
AWR and its associated persons may purchase or sell specific securities for their own account based on
personal investment considerations without regard to whether the purchase or sale of such security is
appropriate for clients.
All persons associated with us are required to report all personal securities transactions to us quarterly.
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ITEM 12: BROKERAGE PRACTICES
The Custodian and Brokers We Use
We do not maintain custody of your assets that we manage, although we may be deemed to have custody
of your assets if you give us authority to withdraw assets from your account (see “Item 15: Custody”).
Your assets must be maintained in an account at a “qualified custodian,” generally a broker/dealer or
bank. We recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-
dealer, member SIPC as the qualified custodian.
We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your
assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend
that you use Schwab as custodian/broker, you will decide whether to do so and will open your account
with Schwab by entering into an account agreement directly with them. Conflicts of interest associated
with this arrangement are described below as well as in "Item 14: Client Referrals and Other
Compensation". You should consider these conflicts of interest when selecting your custodian.
We do not open the account for you, although we may assist you in doing so. Even though your account
is maintained at Schwab, and we anticipate that most trades will be executed through Schwab, we can still
use other brokers to execute trades for your account, as described below (see "Your Brokerage and
Custody Costs").
How We Select Brokers/Custodians
We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms
that are, overall, most advantageous when compared to other available providers and their services. We
consider a wide range of factors, including, among others:
Combination of transaction execution services and asset custody services (generally without a
separate fee for custody)
Capability to execute, clear, and settle trades (buy and sell securities for your account)
Capability to facilitate transfers and payments to and from accounts (wire transfers, check
requests, bill payment, etc.)
Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds
(ETFs), etc.)
Availability of investment research and tools that assist us in making investment decisions
Quality of services
Competitiveness of the price of those services (commission rates, margin interest rates, other fees,
etc.) and willingness to negotiate the prices
Reputation, financial strength, and stability
Prior service to us and our other clients
Availability of other products and services that benefit us, as discussed below (see “Products and
Services Available to Us From Schwab”)
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Your Brokerage and Custody Costs
For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for
custody services but is compensated by charging you commissions or other fees on trades that it executes
or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may
not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on
the uninvested cash in your account in Schwab’s Cash Features Program. In addition to commissions,
Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we
have executed by a different broker-dealer but where the securities bought or the funds from the securities
sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or
other compensation you pay the executing broker-dealer. Because of this, in order to minimize your
trading costs, we have Schwab execute most trades for your account.
We are not required to select the broker or dealer that charges the lowest transaction cost, even if that
broker provides execution quality comparable to other brokers or dealers. Although we are not required
to execute all trades through Schwab, we have determined that having Schwab execute most trades is
consistent with our duty to seek "best execution" of your trades. Best execution means the most favorable
terms for a transaction based on all relevant factors, including those listed above (see "How we Select
Brokers/Custodians"). By using another broker or dealer you may pay lower transaction costs.
Products and Services Available to Us From Schwab
Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us.
They provide us and our clients with access to their institutional brokerage services (trading, custody,
reporting, and related services), many of which are not typically available to Schwab retail customers.
However, certain retail investors may be able to get institutional brokerage services from Schwab without
going through us. Schwab also makes available various support services. Some of those services help us
manage or administer our clients’ accounts, while others help us manage and grow our business.
Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them)
and at no charge to us. Following is a more detailed description of Schwab’s support services:
Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of client assets. The investment
products available through Schwab include some to which we might not otherwise have access or that
would require a significantly higher minimum initial investment by our clients. Schwab’s services
described in this paragraph generally benefit you and your account.
Services that do not directly benefit you. Schwab also makes available to us other products and services
that benefit us but do not directly benefit you or your account. These products and services assist us in
managing and administering our clients’ accounts and operating our firm. They include investment
research, both Schwab’s own and that of third parties. We may use this research to service all or a
substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to
investment research, Schwab also makes available software and other technology that:
Provide access to client account data (such as duplicate trade confirmations and account
statements)
Facilitate trade execution and allocate aggregated trade orders for multiple client accounts
Provide pricing and other market data
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Facilitate payment of our fees from our clients’ accounts
Assist with back-office functions, recordkeeping, and client reporting
Services that generally benefit only us. Schwab also offers other services intended to help us manage and
further develop our business enterprise. These services include:
Educational conferences and events
Consulting on technology and business needs
Consulting on legal and related compliance needs
Publications and conferences on practice management and business succession
Access to employee benefits providers, human capital consultants, and insurance providers
Marketing consulting and support
Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to
provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all
or a part of the third party's fees. Schwab also provides us with other benefits, such as occasional
business entertainment of our personnel. If you did not maintain your account with Schwab we would be
required to pay for these services from our own resources.
Our Interest in Schwab's Services
The availability of these services from Schwab benefits us because we do not have to produce or purchase
them. We don’t have to pay for Schwab’s services. These services are not contingent upon us
committing any specific amount of business to Schwab in trading commissions or assets in custody. The
fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab
rather than making such a decision based exclusively on your interest in receiving the best value in
custody services and the most favorable execution of your transactions. This is a conflict of interest. We
believe, however, that taken in the aggregate, our [selection/recommendation] of Schwab as custodian and
broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality,
and price of Schwab’s services (see “How We Select Brokers/Custodians”) and not Schwab’s services
that benefit only us.
Aggregation of Orders
There are occasions on which portfolio transactions will be executed as part of concurrent authorizations
to purchase or sell the same security for another client or one or more of our associated persons.
We may choose to block (aggregate) trades for your account with those of other client accounts and
personal accounts of persons associated with AWR. When we place a block trade, all participants
included in the block receive the same price per share on the trade. The price is calculated by averaging
the price of all of the shares traded. Due to the averaging of price over all of the participating accounts,
aggregated trades could be either advantageous or disadvantageous. Commission costs are not averaged.
You will pay the same commission whether your trade is placed as part of a block or on an individual
basis. The objective of the aggregated orders will be to allocate the executions in a manner that is deemed
equitable to the accounts involved.
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We may aggregate purchases or sales depending on the need to use outside trading desks to work the
order and if multiple clients are involved. We normally use mutual funds or managed accounts where
aggregation at our level does not matter.
Directed Brokerage
You may instruct us to execute any or all securities transactions for your account with or through one or
more broker/dealers designated by you. In these cases, you are responsible for negotiating the terms and
conditions (including, but not limited to, commission rates) relating to all services to be provided by the
broker/dealers and you are satisfied with the terms and conditions. We have no responsibility for
obtaining the best prices or any particular commission rates for transactions with or through the
broker/dealer in these situations. You recognize that you may not obtain rates as low as you might
otherwise obtain if we had discretion to select broker/dealers other than those chosen by you. If you
would like us to cease executing transactions with or through the designated broker/dealer you must
notify us in writing.
Soft Dollars
The receipt of goods and/or services from the required custodian in connection with providing advice to
clients is seen by the regulators as “soft dollars.” The additional services we receive from Schwab, as
disclosed in the section entitled “Products and Services Available to Us From Schwab” above, would fall
under this description of soft dollars.
ITEM 13: REVIEW OF ACCOUNTS
A full review of each client account is done on a quarterly basis by Andrew W. Ryan, Managing Member.
During this process he reviews asset allocation, performance and holdings. He also performs interim
reviews on accounts depending on cash flow, maturity, or change in managers or asset allocation.
We send out quarterly reports with market commentary, asset allocation, portfolio and benchmark
performance, holdings and a fee statement.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
We receive an economic benefit from Schwab in the form of the support products and services it makes
available to us and other independent investment advisors whose clients maintain their accounts at
Schwab. You do not pay more for assets maintained at Schwab as a result of these arrangements.
However, we benefit from the referral arrangement because the cost of these services would otherwise be
borne directly by us. You should consider these conflicts of interest when selecting a custodian. These
products and services, how they benefit us, and the related conflicts of interest are described above (see
Item 12: Brokerage Practices”).
We do not receive compensation from third parties for recommending or implementing investment
strategies. This includes referral fees from third party advisors (“TPA”) for placing your assets under
management with them. When we consider to receive referral fees, we’ll enter into an agreement with the
TPA, provide you with written disclosure about the nature of the relationship between the AWR and the
TPA, including any affiliations, the compensation or fees paid to the TPA, and how the compensation or
fees will be shared between the parties, and update this disclosure. We strive to have all referral
payments, agreements, other practices, and disclosures comply with all applicable state and federal rules
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and regulations. We will confirm initially, and from time to time thereafter, that TPAs that we
recommend are legally eligible to manage your assets.
We do not directly or indirectly compensate anyone for client referrals.
ITEM 15: CUSTODY
If you give us authority to deduct our fees directly from your separately managed account, we have
custody of those assets. In order to avoid additional regulatory requirements in these cases, we follow the
procedures outlined in “Item 5: Fees and Compensation.” For accounts where the client has a standing
letter of authorization that allows us to transfer money to third party accounts specified by the client, we
are also deemed to have custody. We follow the guidance outlined in the Investment Adviser Association
no-action letter dated February 21, 2017, for these accounts. A copy of this letter is available upon
request. At no time do we accept physical custody of client assets.
You will receive quarterly statements directly from custodian of the account that details all transactions in
the account. They will be sent to the email or postal mailing address you provided to the custodian. You
should carefully review those statements promptly when you receive them. We also urge you to compare
Schwab’s account statements to the periodic portfolio reports you will receive from us.
ITEM 16: INVESTMENT DISCRETION
As one of the conditions of managing your account, you are required to provide discretionary authority
for us to manage your assets. Discretionary authority means that you are giving us a limited power of
attorney to place trades on your behalf. This limited power of attorney does not allow us to withdraw
money from your account, other than advisory fees if you agree to give us that authority.
You grant us discretionary authority by completing the following items:
Sign a contract with us that provides a limited power of attorney for us to place trades on your
behalf. Any limitations to the trading authorization will be added to this agreement.
Provide us with discretionary authority on the new account forms that are submitted to the
broker/dealer acting as custodian for your account(s).
We do not allow for limitations on the discretionary authority provided by the client.
ITEM 17: VOTING CLIENT SECURITIES
As a matter of policy and as a fiduciary to our clients, we have responsibility for voting proxies for your
portfolio securities consistent with your best economic interests. We maintain written policies and
procedures as to the handling, research, voting and reporting of proxy voting and make appropriate
disclosures about our proxy policies and practices. Our policy and practice include the responsibility to
monitor corporate actions, receive and vote client proxies and disclose any potential conflicts of interest
as well as making information available to clients about the voting of proxies for their portfolio securities
and maintaining relevant and required records. You may provide direction regarding any particular proxy
solicitation.
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You may elect to retain the authority to vote the proxies yourself. In this case, we would provide
guidance on voting a particular proxy solicitation only upon request.
You may request a copy of our Proxy Policies and Procedures and/or information about how a proxy was
voted at any time.
ITEM 18: FINANCIAL INFORMATION
We do not charge or solicit pre-payment of more than $1,200 in fees per client six months or more in
advance. We have never filed for bankruptcy and are not aware of any financial conditions that are
reasonably likely to impair our ability to meet our contractual obligations to clients.
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BROCHURE SUPPLEMENT
ITEM 1: COVER SHEET
Andrew W. Ryan
AWR Investment Management, LLC
300 Laurel Avenue
San Anselmo, CA 94960
(415) 457-9415
February 9, 2026
This Brochure Supplement provides information about Andrew W. Ryan that supplements the AWR
Investment Management, LLC Brochure. You should have received a copy of that Brochure. Please
contact Andrew W. Ryan, Managing Member at (415) 457-9415 or
andy@awrinvestmentmanagement.com if you did not receive AWR Investment Management, LLC’s
Brochure or if you have any questions about the content of this supplement.
Additional information about Andrew W. Ryan is available on the SEC’s website at
www.adviserinfo.sec.gov. Mr. Ryan’s CRD number is 1765898.
ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE
Andrew W. Ryan was born in 1960. He received a BA in Business Administration from University of
Wisconsin/Eau Claire in 1984 and a MBA in Finance from University of San Francisco in 1987.
Employment Background
Employment Dates:
Firm Name:
Type of Business:
Job Title & Duties:
11/1998 - Present
AWR Investment Management, LLC
Investment Advisor
Managing Member, Chief Investment Officer/CCO
Employment Dates:
Firm Name:
Type of Business:
Job Title & Duties:
8/2016 - Present
Global Retirement Partners LLC dba
Heffernan Financial Services
Investment Advisor
Investment Advisory Representative
AWR Investment Management, LLC
Brochure Supplement
Andrew W. Ryan
Employment Background (continued)
Employment Dates:
Firm Name:
Type of Business:
Job Title & Duties:
5/2000 – 1/2017
Heffernan Investment Advisors, Inc.
Investment Advisor
Chief Investment Officer
ITEM 3: DISCIPLINARY INFORMATION
Registered investment advisors are required to disclose any material facts regarding any legal or
disciplinary actions that would be material to your evaluation of each investment advisor representative
providing investment advice to you. There is no information of this type to report.
ITEM 4: OTHER BUSINESS ACTIVITIES
Mr. Ryan is also an Investment Advisor Representative with Heffernan Financial Services, a registered
investment advisory firm. Mr. Ryan expects to spend approximately 20% of his time in that capacity.
ITEM 5: ADDITIONAL COMPENSATION
Mr. Ryan does not receive any economic benefit from any non-client for providing advisory services.
ITEM 6: SUPERVISION
Mr. Ryan, Managing Member, is the owner and sole person providing investment advice on our behalf.
His telephone number is (415) 457-9415.
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