Overview

Assets Under Management: $138 million
Headquarters: CHARLOTTESVILLE, VA
High-Net-Worth Clients: 47
Average Client Assets: $3 million

Services Offered

Services: Portfolio Management for Individuals, Portfolio Management for Institutional Clients

Fee Structure

Primary Fee Schedule (SEC ADV PART 2A & 2B)

MinMaxMarginal Fee Rate
$0 and above 1.25%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $12,500 1.25%
$5 million $62,500 1.25%
$10 million $125,000 1.25%
$50 million $625,000 1.25%
$100 million $1,250,000 1.25%

Clients

Number of High-Net-Worth Clients: 47
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 93.71
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 74
Discretionary Accounts: 74

Regulatory Filings

CRD Number: 298041
Last Filing Date: 2025-01-14 00:00:00
Website: https://clioam.com

Form ADV Documents

Primary Brochure: SEC ADV PART 2A & 2B (2025-09-08)

View Document Text
FORM ADV PART 2A DISCLOSURE BROCHURE Clio Asset Management LLC 1 Boars Head Place, Ste 220 Charlottesville, VA 22903 Tel: 434-329-7463 James@ClioAM.com www.ClioAM.com September 8, 2025 This brochure provides information about the qualifications and business practices of Clio Asset Management LLC. Being registered as a registered investment adviser does not imply a certain level of skill or training. If you have any questions about the contents of this brochure, please contact us at 434-329-7463. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. ADDITIONAL INFORMATION ABOUT CLIO ASSET MANAGEMENT LLC (CRD #298041) IS AVAILABLE ON THE SEC’S WEBSITE AT WWW.ADVISERINFO.SEC.GOV i Item 2: Material Changes The Material Changes section of this brochure will be updated annually or when material changes occur since the previous release of the Firm Brochure. • Since the last update on January 14, 2025 the following has been updated: Item 4 has been updated with the firm’s most recent assets under management Full Brochure Available calculation. This Firm Brochure being delivered is the complete brochure for the Firm. ii Item 3: Table of Contents Form ADV – Part 2A – Firm Brochure Item 1: Cover Page Item 2: Material Changes .................................................................................................................... ii Item 3: Table of Contents ................................................................................................................... iii Item 4: Advisory Business .................................................................................................................. 1 Item 5: Fees and Compensation ....................................................................................................... 1 Item 6: Performance-Based Fees and Side-by-Side Management ........................................ 4 Item 7: Types of Clients ....................................................................................................................... 5 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ................................ 5 Item 9: Disciplinary Information ..................................................................................................... 8 Item 10: Other Financial Industry Activities and Affiliations ............................................... 8 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................................................................................................................................... 8 Item 12: Brokerage Practices ......................................................................................................... 10 Item 13: Review of Accounts ........................................................................................................... 11 Item 14: Client Referrals and Other Compensation ................................................................ 11 Item 15: Custody .................................................................................................................................. 11 Item 16: Investment Discretion ..................................................................................................... 12 Item 17: Voting Client Securities ................................................................................................... 12 Item 18: Financial Information ...................................................................................................... 12 iii Item 4: Advisory Business Firm Description Clio Asset Management LLC (“Clio” or the “Firm”) is organized as a Virginia limited liability company. The Firm was organized in May of 2018, and began offering advisory services in August Types of Advisory Services of 2018. James G. Aldigé IV is 100% owner of Clio. ASSET MANAGEMENT Clio offers discretionary asset management services to advisory Clients. Clio will offer Clients ongoing asset management services through determining individual investment goals, time horizons, objectives, and risk tolerance. Investment strategies, investment selection, asset allocation, portfolio monitoring and the overall investment program will be based on the above factors. The Client will authorize Clio discretionary authority to execute selected investment Client Tailored Services and Client Imposed Restrictions program transactions as stated within the Investment Advisory Agreement. The goals and objectives for each Client are documented in our Client files. Investment strategies are created that reflect the stated goals and objectives. Clients may impose restrictions on investing in certain securities or types of securities. The Clio Core Portfolio strategy: Agreements may not be assigned without written Client consent. We generally offer one model portfolio strategy, the Clio Core Portfolio strategy, whose objective is to compound capital through the long-term ownership of roughly 8-12 exceptional businesses. These businesses tend to exhibit high or improving returns on invested capital, leading competitive positions, strong corporate cultures, exceptional management teams, best-in-class Wrap Fee Programs products or services, strong balance sheets, and secular growth tailwinds. Client Assets under Management Clio does not sponsor any wrap fee programs. Clio has the following Client assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $142,188,956 $0 September 4, 2025 Item 5: Fees and Compensation Method of Compensation and Fee Schedule ASSET MANAGEMENT Clio offers discretionary asset management services to advisory Clients. Clio charges an annual investment advisory fee based on the total assets under management, as described in each Client’s Investment Advisory Agreement. Annual fees typically are no more than 1.25% of total assets under management and, starting in the fourth year, will be reduced by 0.05% each year Client has assets with Clio for a maximum discount of 0.25% from year 8 and beyond. 1 For example: Year of Client Relationship Years 0-3 Year 4 Year 5 Year 6 Year 7 Year 8 and beyond Annual Advisory Fee 1.25% 1.20% 1.15% 1.10% 1.05% 1.00% For example, a Client with $1,000,000 under management and a 1.25% annual investment advisory fee would pay $12,500 on an annual basis. Starting in year 4 the fee will go down .05% each year until year 8. By year 8 the annual fee will be $10,000 ($1,000,000 x 1.00%) The annual fee may be negotiable based upon certain criteria (e.g., historical relationship, type of assets, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, Client tenure (i.e. length of the Client relationship), other negotiations with Clients, etc.). Fees are billed quarterly in arrears based on the amount of the client’s assets as of the close of business on the last business day of the previous quarter. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. Clients may terminate advisory services with ten (10) days written notice. For accounts opened or closed mid-billing period, any unpaid earned fees will be due to Clio based on the number of days the account was managed in the final quarter. If cash and/or securities are deposited into or withdrawn from an existing account mid billing period a prorated fee will be charged for that portion. Client shall be given thirty (30) days prior written notice of any increase in fees. Any increase in fees will be acknowledged in writing by both parties before any increase in said fees occurs. PERFORMANCE BASED FEES For Clients who choose to participate in performance-based fees they will be 20% of any increase from the previous quarter (“high water mark”) and charged quarterly in arrears. The performance fee will be a calculated by a Gross Asset Value of the account on a start date and be benchmarked to the Net Asset Value of the stated account net of quarterly performance fees. The account would have to achieve the high watermark valued at the end of each quarter in order for the performance fee to trigger (or be applicable). A snapshot of the value of the account will be taken on the start and end of each quarter and compared to the high-water mark. All fees will be deducted from the account via the custodial providers or billed directly to the Client. For accounts closed mid-billing period, any unpaid earned performance fees will be due to Clio based on the value of the account at the date of liquidation or account closure relative to the prior quarter-end. Performance Fee disclaimer: All performance fees are based on a new high-water mark for any quarter that is charged. HIGH WATER MARK CALCULATIONS: • • • • Initial deposit $1,000,000 Performance fee is set at 20% of the gain. End of first quarter balance is $1,075,000. First quarter performance fee for us is $15,000 2 • Calculation: $75,000 x 20% = $15,000. New high-water mark is $1,060,000 ($1,075,000 - $15,000) • • • • End of second quarter balance is $1,050,000 No performance fee paid High water mark remains $1,060,000 Fees will not be charged until the account value goes above the high-water mark of $1,060,000 This example assumes that there were no new deposits or new withdrawals, which can affect the high-water mark. Hypothetical Deposit - If a new deposit is made into the account the high-water mark will be calculated based on the dollar amount. Using the above scenario as an example: • • • • • • Deposit $50,000 to account with $1,050,000 New account balance will be $1,100,000 Adjusted high water mark is now $1,110,000 ($1,060,000 + $50,000) Still below the new high-water mark of $1,110,000 No performance fee paid The account will only be charged a performance fee once the account has made over $10,000 ($1,110,000-$1,100,000=$10,000), after accounting for all other relevant fees Hypothetical withdrawal - If new withdrawals are made in the account the high-water mark will be calculated based on the dollar amount. Using the above scenario as an example: • • • • • • Withdraw $50,000 from account with $1,050,000 New account balance will be $1,000,000 Adjusted high water mark is now $1,010,000 ($1,060,000 - $50,000) Still below the new high-water mark of $1,010,000 No performance fee paid The account will only be charged a performance fee once it has gained more than $10,000 ($1,010,000 - $1,000,000), after accounting for all other relevant fees. The Client will be billed for the performance-based Fees through a direct invoice or deducted from the Client account. Lower fees for comparable services may be available from other sources. Clients may terminate their account within five (5) business days of signing the Investment Advisory Agreement with no obligation and without penalty. Clients may terminate advisory services with thirty (30) days written notice. For accounts closed mid-billing period, if account is above the high-water mark, Client will be billed 20% of the increase of the high-water mark. Client shall be given thirty (30) days prior written notice of any increase in fees, and Client will acknowledge, in writing, any agreement of increase in said fees. Transaction fees still apply to the Client Payment of Fees performance-based account. Investment management and performance fees are billed quarterly in arrears. Fees are usually deducted from a designated Client account to facilitate billing. The Client must consent in advance to direct debiting of their investment account. Clio, in its sole discretion, may charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future 3 additional assets, dollar amounts of assets to be managed, related accounts, account composition, Additional Client Fees Charged negotiations with Clients, etc.). In addition to the fees charged by Clio, custodians may charge transaction fees on purchases or sales of certain mutual funds, equities, and exchange-traded funds. These charges may include mutual fund transaction fees, postage and handling and miscellaneous fees. Prepayment of Client Fees For more details on the brokerage practices, see Item 12 of this brochure. Clio does not require or accept any prepayment of fees. Clio has no formal refund policy because External Compensation for the Sale of Securities to Clients advisory fees payable are assessed in arrears. Clio does not receive any external compensation for the sale of securities to Clients, nor do any of the investment advisor representatives of Clio. Item 6: Performance-Based Fees and Side-by-Side Management Sharing of Capital Gains Clio offers a program in which we share in the capital gains or capital appreciation of managed securities. This program is offered only to Clients that must meet certain requirements to be able to participate in being charged performance based fees which include: i. has at least $1.1 million in assets under management with the investment adviser immediately after entering into the advisory contract; or ii. has a net worth (together, in the case of a client that is a natural person, with assets held jointly with a spouse) that the investment adviser reasonably believes to be in excess of $2.2 million immediately prior to entering into the advisory contract (“net worth test”). The Client does not pay an annual advisory fee based on the assets under management. The only fee charged is a percentage of the quarterly portfolio performance. To the extent that we charge a performance–based fee, the performance-based fee will comply with the requirements of Section 205 and Rule 205-3 under the Investment Advisers Act of 1940. The simultaneous management of these different types of Client accounts, with different fee structures, creates certain conflicts of interest, as the fees for the management of some Client types are higher than for others. Nevertheless, when managing the assets of these accounts, we have a duty to treat all accounts fairly and equitably over time. Additionally, since performance-based fees reward us for strong performance in accounts which are subject to such fees, we may have an incentive to favor these accounts over those that have only asset-based fees (i.e., fees based simply on the amount of assets under management in an account) with respect to areas such as trading opportunities, trade allocation, and allocation of new investment opportunities. To mitigate the conflict, we represents that it is not our intent to trade a Client’s account in an irresponsible, unethical or baseless manner, or to assume unnecessary risk given potential perceived reward. We will never knowingly or intentionally breach the fiduciary duty we owe to a Client, and we believe the incentive or performance fee portion of its compensation aligns, rather than divides, the interests of Clients and us in addition, the Client may choose to place their account in the advisory fee only program. 4 Item 7: Types of Clients Description institutional Clio generally provides investment advice to individuals, high net worth individuals, family offices, investors. endowments, foundations, LLCs, Trusts, Corporations, and other Additionally, Clio provides investment advice to limited partnerships which themselves might operate as pooled investment vehicles on behalf of their Limited Partners. In all such cases, neither Clio nor James Aldigé has any affiliation or involvement in such pooled investment vehicles beyond the normal investment advisory services described in Clio’s standard investment advisory agreement. No clients of Clio are solicited or referred to such pooled investment vehicles. Clio does not advise any pooled investment vehicle as a portfolio manager of that vehicle. Account Minimums Client relationships vary in scope and length of service. Clio generally requires minimum of $1,000,000 to open an account. Clio may, in its sole discretion, lower or waive the minimum requirement. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis Security analysis methods may include fundamental analysis. Investing in securities involves risk of loss that Clients should be prepared to bear. Past performance is not a guarantee of future returns. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. The main sources of information include financial newspapers and magazines, annual reports, Investment Strategy prospectuses, and filings with the Securities and Exchange Commission. The investment strategy for a specific Client is based upon the objectives stated by the Client during consultations. The Client may change these objectives at any time by providing written notice to Clio. Each Client executes a Client profile form or similar form that documents their objectives and their desired investment strategy. Security Specific Material Risks Other strategies may include long-term purchases, short-term purchases and trading. • Market Risk All investment programs have certain risks that are borne by the investor. Our investment approach constantly keeps the risk of loss in mind. Investors face the following investment risks and should discuss these risks with Clio: : The prices of securities held by mutual funds in which Clients invest or securities directly held by the Client may decline in response to certain events taking place around the world, including those directly involving the companies whose securities are owned by a fund; conditions affecting the general economy; overall market changes; local, regional or global political, social or economic instability; and currency, interest rate and commodity price fluctuations. Investors should have a long-term perspective and be able to tolerate potentially sharp declines in market value. 5 Interest-rate Risk • • : Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, Inflation Risk causing their market values to decline. : When any type of inflation is present, a dollar today will buy more than a • Currency Risk dollar next year, because purchasing power is eroding at the rate of inflation. : Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as • Reinvestment Risk exchange rate risk. • Liquidity Risk : This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Management Risk: : Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Equity Risk: The advisor’s investment approach may fail to produce the intended results. If the advisor’s assumptions regarding the performance of a specific asset class or fund are not realized in the expected time frame, the overall performance of the Client’s portfolio may suffer. • Fixed Income Risk: Equity securities tend to be more volatile than other investment choices. The value of an individual stock, mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the Client’s overall portfolio. Small and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies. • The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by a fund is likely to decrease. A nominal interest rate is the sum of a real Investment Companies Risk: interest rate and an expected inflation rate. When a Client invests in open end mutual funds or ETFs, the Client indirectly bears their proportionate share of any fees and expenses payable directly by those funds. Therefore, the Client will incur higher expenses, which may be duplicative. In addition, the Client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value or (ii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. Clio has no control over the risks taken by the underlying funds in which a Client invests. 6 • Long-term purchases • Short-term purchases : Long-term investments are those vehicles purchased with the intension of being held for more than one year. Typically the expectation of the investment is to increase in value so that it can eventually be sold for a profit. In addition, there may be an expectation for the investment to provide income. One of the biggest risks associated with long-term investments is volatility, the fluctuations in the financial markets that can cause investments to lose value. : Short-term investments are typically held for one year or less. Generally, there is not a high expectation for a return or an increase in value. Typically, short-term investments are purchased for the relatively greater degree of principal protection they are designed to provide. Short-term investment vehicles may be subject to purchasing power risk — the risk that your investment’s return will not keep up with • Trading risk inflation. : Investing involves risk, including possible loss of principal. There is no • Foreign Securities Risk: assurance that the investment objective of any fund or investment will be achieved. The advisor may invest in the securities of foreign issuers. These o Exchange rate risk securities may entail special risks, including: —the risk that the currency in the issuing company’s country will o Political risk drop relative to the US dollar —the risk that politics or regime changes in the issuing company’s country o Inflation risk will undermine exchange rates or destabilize the company and its earnings —the risk that inflation in the issuing company’s country will erode the • ADR Risk: value of that currency • OTC Risk: The advisor may invest in American Depository Receipts (“ADRs”), which are a form of equity security that was created to simplify foreign investing for American investors. ADRs may be listed on a major exchange such as the New York Stock Exchange or may be traded over the counter (OTC). ADRs can be issued as unsponsored without any involvement or approval by the foreign company or they can be issued as sponsored, where the underlying foreign company participates in the issuance of the ADR and also retains a controlling relationship. Only sponsored ADRs may be listed on a national exchange and they must meet certain qualifications, otherwise they trade in the U.S. OTC market. Unsponsored ADRs only trade in the U.S. OTC market. An ADR is issued by an American bank or broker. It represents one or more shares of foreign-company stock held by that bank in the home stock market of the foreign company. Those that are listed can be traded, settled, and held as if they were ordinary shares of US-based companies. Because ADRs are issued by non-US companies, they entail special risks inherent to all foreign securities. Depending on the level of the ADR program, investors also may not have access to the amount of information available on domestic companies. ADRs may not be as liquid as the ordinary shares of the foreign issuer on a foreign exchange, which can lead to greater share price volatility and wider bid-ask spreads. The advisor may invest in Over-the-Counter (“OTC”) securities, which are securities that are not listed on a major exchange in the United States and are instead traded via a broker-dealer network, usually because many are smaller companies and do not meet the requirements to be listed on a formal exchange. Foreign company shares may also trade Over-the-Counter in the United States, which are known as “foreign ordinaries”. OTC securities present a number of additional risks, compared to securities that trade on a 7 national exchange. The biggest difference between an OTC stock and a listed stock is the amount of publicly available information about the company. Information about OTC companies can be difficult to find, making them more vulnerable to investment fraud schemes and making it less likely that quoted prices in the market will be based on full and complete information about the company. Companies quoted on OTC Markets generally do not have to meet any minimum standards, as typically required by the large exchanges, such as the New York Stock Exchange. OTC securities may not be as liquid as securities traded on a national exchange, which can lead to greater share price volatility and wider bid-ask spreads. Item 9: Disciplinary Information Criminal or Civil Actions Administrative Enforcement Proceedings Clio and its management have not been involved in any criminal or civil action. Self- Regulatory Organization Enforcement Proceedings Clio and its management have not been involved in administrative enforcement proceedings. Clio and its management have not been involved in legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of Clio or the integrity of its management. Item 10: Other Financial Industry Activities and Affiliations Broker-Dealer or Representative Registration Clio is not registered as a broker-dealer and no affiliated representatives of Clio are registered Futures or Commodity Registration representatives of a broker-dealer. Neither Clio nor its affiliated representatives are registered or have an application pending to register as a futures commission merchant, commodity pool operator, or a commodity trading Material Relationships Maintained by this Advisory Business and Conflicts of Interest advisor. Managing Member James G. Aldigé IV does not have any business activities that represent a conflict of interest. Managing Member James G. Aldigé IV has an investment holding company for his personal assets, Turl Street Ventures LLC. There is no conflict of interest as advisory clients of Clio are not solicited services for Turl Street Ventures LLC. Furthermore, the assets held within Turl Street Venture LLC are not publicly traded securities. As such, these assets are not traded or transacted contrary to any advice given to clients of Clio. James Aldigé devotes less than ½ hour per month to Turl Street Recommendations or Selections of Other Investment Advisors and Conflicts of Interest Ventures. Clio does not select or recommend other investment advisors or any pooled investment vehicles. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics Description The affiliated persons (affiliated persons include employees and/or independent contractors) of Clio have committed to a Code of Ethics (“Code”). The purpose of our Code is to set forth standards of conduct expected of Clio affiliated persons and addresses conflicts that may arise. The Code 8 defines acceptable behavior for affiliated persons of Clio. The Code reflects Clio and its supervised persons’ responsibility to act in the best interest of their Client. One area which the Code addresses is when affiliated persons buy or sell securities for their personal accounts and how to mitigate any conflict of interest with our Clients. We do not allow any affiliated persons to use non-public material information for their personal profit or to use internal research for their personal benefit in conflict with the benefit to our Clients. Clio’s policy prohibits any person from acting upon or otherwise misusing non-public or inside information. No advisory representative or other employee, officer or director of Clio may recommend any transaction in a security or its derivative to advisory Clients or engage in personal securities transactions for a security or its derivatives if the advisory representative possesses material, non-public information regarding the security. Clio’s Code is based on the guiding principle that the interests of the Client are our top priority. Clio’s officers, directors, advisors, and other affiliated persons have a fiduciary duty to our Clients and must diligently perform that duty to maintain the complete trust and confidence of our Clients. When a conflict arises, it is our obligation to put the Client’s interests over the interests of either affiliated persons or the company. The Code applies to “access” persons. “Access” persons are affiliated persons who have access to non-public information regarding any Clients' purchase or sale of securities, or non-public information regarding the portfolio holdings of any reportable fund, who are involved in making securities recommendations to Clients, or who have access to such recommendations that are non- public. Investment Recommendations Involving a Material Financial Interest and Conflict of Clio will provide a copy of the Code of Ethics to any Client or prospective Client upon request. Interest Clio and its affiliated persons do not recommend to Clients securities in which we have a material Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of financial interest. Interest Clio and its affiliated persons may buy or sell securities that are also held by Clients. In order to mitigate conflicts of interest such as trading ahead of Client transactions, affiliated persons are required to disclose all reportable securities transactions as well as provide Clio with copies of their brokerage statements. The Chief Compliance Officer of Clio is James G. Aldigé IV. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities over associated persons’ transactions. Transactions and Conflicts of Interest Clio does not maintain a firm proprietary trading account and does not have a material financial interest in any securities being recommended and therefore no conflicts of interest exist. However, affiliated persons may buy or sell securities at the same time they buy or sell securities for Clients. In order to mitigate conflicts of interest such as front running, affiliated persons are required to disclose all reportable securities transactions as well as provide Clio with copies of their brokerage statements. 9 The Chief Compliance Officer of Clio is James G. Aldigé IV. He reviews all trades of the affiliated persons each quarter. The personal trading reviews ensure that the personal trading of affiliated persons does not affect the markets and that Clients of the firm receive preferential treatment over associated persons’ transactions. Item 12: Brokerage Practices Factors Used to Select Broker-Dealers for Client Transactions Clio may recommend the use of a particular broker-dealer or may utilize a broker-dealer of the Client's choosing. Clio will select appropriate brokers based on a number of factors including but not limited to their relatively low transaction fees and reporting ability. Clio relies on its broker to provide its execution services at the best prices available. Lower fees for comparable services may be available from other sources. Clients pay for any and all custodial fees in addition to the • Directed Brokerage advisory fee charged by Clio. In circumstances where a Client directs Clio to use a certain broker-dealer, Clio still has a fiduciary duty to its Clients. The following may apply with Directed Brokerage: Clio's inability to negotiate commissions, to obtain volume discounts, there may be a disparity in commission charges among Clients and conflicts of interest arising from brokerage firm • Best Execution referrals. • Soft Dollar Arrangements Investment advisors who manage or supervise Client portfolios have a fiduciary obligation of best execution. The determination of what may constitute best execution and price in the execution of a securities transaction by a broker involves a number of considerations and is subjective. Factors affecting brokerage selection include the overall direct net economic result to the portfolios, the efficiency with which the transaction is affected, the ability to effect the transaction where a large block is involved, the operational facilities of the broker-dealer, the value of an ongoing relationship with such broker and the financial strength and stability of the broker. The firm does not receive any portion of the trading fees. The Securities and Exchange Commission defines soft dollar practices as arrangement under which products or services other than execution services are obtained by Clio from or through a broker-dealer in exchange for directing Client transactions to the broker- dealer. As permitted by Section 28(e) of the Securities Exchange Act of 1934, Clio receives economic benefits as a result of commissions generated from securities transactions by the broker-dealer from the accounts of Clio. These benefits include both proprietary research from the broker and other research written by third parties. A conflict of interest exists when Clio receives soft dollars. This conflict is mitigated by the fact that Clio has a fiduciary responsibility to act in the best interest of its Clients and the services received are beneficial to all Clients. Clio utilizes the services of custodial broker dealers. Economic benefits are received by Clio which would not be received if Clio did not give investment advice to Clients. These benefits include: A dedicated trading desk, a dedicated service group and an account services manager dedicated to Clio's accounts, ability to conduct "block" Client trades, electronic download of trades, balances and positions, duplicate and batched Client statements, and the ability to have advisory fees directly deducted from Client accounts. 10 Aggregating Securities Transactions for Client Accounts When purchasing or selling the same security for multiple client portfolios in a single trading day, Clio will generally seek to aggregate all client orders into a single "block trade." Block trades are used to ensure that all clients receive the same execution price for the trade. If a block transaction is not possible and purchases or sales have to be executed gradually over more than one day and on an account-by-account basis, then Clio will typically prorate or randomly allocate the purchases or sales across the accounts. Item 13: Review of Accounts Schedule for Periodic Review of Client Accounts or Financial Plans and Advisory Persons Involved Clio reviews its client’s account activity at least quarterly. The reviews are conducted by James Aldigé, Managing Member and Chief Compliance Officer of Clio. Reviews consist of determining whether a client’s investment goals and objectives are aligned with Clio’s investment strategy. Review of Client Accounts on Non-Periodic Basis More frequent reviews are performed when market conditions dictate. Other conditions that may trigger a review of Clients’ accounts are changes in the tax laws, new Content of Client Provided Reports and Frequency investment information, and changes in a Client's own situation. Clients receive written account statements no less than monthly for managed accounts. Clients can also elect to receive electronic monthly statements and can access their account online at any time in between reporting periods. Account statements are issued by Clio’s Custodian. Performance reports will be provided by Clio. at least quarterly to Clients with assets under management. Client receives confirmations of each transaction in an account from the Custodian and an additional statement during any month in which a transaction occurs. Item 14: Client Referrals and Other Compensation Economic Benefits Provided to the Advisory Firm from External Sources and Conflicts of Interest Advisory Firm Payments for Client Referrals Clio does not receive any economic benefits from external sources. Clio does not compensate for Client referrals. Item 15: Custody Account Statements All assets are held at qualified custodians, which means the custodians provide account statements directly to Clients at their address of record at least quarterly. Clients are urged to compare the account statements received directly from their custodians to any documentation or reports prepared by Clio. Clio is deemed to have constructive custody solely because advisory fees are directly deducted from Client’s accounts by the custodian on behalf of Clio. 11 Item 16: Investment Discretion Discretionary Authority for Trading Clio requires discretionary authority to manage securities accounts on behalf of Clients. Clio has the authority to determine, without obtaining specific Client consent, the securities to be bought or sold, and the amount of the securities to be bought or sold. The client will authorize Clio discretionary authority to execute selected investment program transactions as stated within the Investment Advisory Agreement. The Client approves the custodian to be used and the commission rates paid to the custodian. Clio does not receive any portion of the transaction fees or commissions paid by the Client to the custodian. Item 17: Voting Client Securities Proxy Votes Clio does not vote proxies on securities. Clients are expected to vote their own proxies. The Client will receive their proxies directly from the custodian of their account or from a transfer agent. Clio does not render advice to clients with respect to voting. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information Balance Sheet A balance sheet is not required to be provided because Clio does not serve as a custodian for Client funds or securities and Clio does not require prepayment of fees of more than $1,200 per Client Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet and six months or more in advance. Commitments to Clients Clio has no condition that is reasonably likely to impair our ability to meet contractual Bankruptcy Petitions during the Past Ten Years commitments to our Clients. Clio has not had any bankruptcy petitions in the last ten years. 12 Item 1 Cover Page S U P E R V I S E D P E R S O N B R O C H U R E F O R M A D V P A R T 2 B James G. Aldigé IV Clio Asset Management LLC 1 Boars Head Place, Ste 220 Charlottesville, VA 22903 Tel: 434-329-7463 James@ClioAM.com www.ClioAM.com September 8, 2025 This brochure supplement provides information about James G. Aldigé IV and supplements the Clio Asset Management LLC brochure. You should have received a copy of that brochure. Please contact James G. Aldigé IV if you did not receive the brochure or if you have any questions about A D D I T I O N A L I N F O R M A T I O N A B O U T J A M E S G . A L D I G É I V the contents of this supplement. ( C R D # 6 9 8 6 5 7 3 ) I S A V A I L A B L E O N T H E S E C ’ S W E B S I T E A T W W W . A D V I S E R I N F O . S E C . G O V . 13 Brochure Supplement (Part 2B of Form ADV) Supervised Person Brochure Principal Executive Officer – James G. Aldigé IV • Item 2 - Educational Background and Business Experience Year of birth: 1981 Educational Background: • • • Harvard Business School; Master of Business Administration; 2010 University of Oxford (UK); Master of Philosophy (M.Phil.) in Economic History; 2005 University of Virginia; Bachelor of Arts in Economics; 2003 Business Experience: • • • • • • Clio Asset Management LLC; Investment Advisor Representative; 08/2018 – Present Clio Asset Management LLC; Managing Member; 05/2018 – Present Turl Street Ventures LLC; Managing Member; 01/2018 - Present Ivy Road Partners LLC; Managing Partner; 06/2016 – 02/2018 Unemployed; 02/2016 – 06/2016 Tiger Eye Capital LLC; Partner and Managing Director; 06/2010 – 02/2016 None to report. Item 3 - Disciplinary Information Criminal or Civil Action: Administrative Proceeding: Self-Regulatory Proceeding: Item 4 - Other Business Activities Engaged In None to report. None to report. Managing Member James G. Aldigé IV does not have any business activities that represent a conflict of interest. Managing Member James G. Aldigé IV has an investment holding company for his personal assets, Turl Street Ventures LLC. There is no conflict of interest as advisory clients of Clio are not solicited services for Turl Street Ventures LLC. Furthermore, the assets held within Turl Street Venture LLC are not publicly traded securities. As such, these assets are not traded or transacted contrary to any advice given to clients of Clio. James Aldigé devotes less than ½ hour per month to Turl Street Item 5 - Additional Compensation Ventures. Item 6 - Supervision James G. Aldigé IV may receive performance-based fees. Since James G. Aldigé IV is the sole owner and investment adviser representative of Clio he is solely responsible for all supervision and formulation and monitoring of investment advice offered to Clients. He will adhere to the policies and procedures as described in the firm’s Compliance Manual. He can be reached at James@ClioAM.com or 434-329-7463. 14