Overview

Assets Under Management: $1.4 billion
Headquarters: ROCKY MOUNT, NC
High-Net-Worth Clients: 26
Average Client Assets: $53.2 million

Frequently Asked Questions

IRONSIDES ASSET ADVISORS, LLC charges 0.85% on the first $10 million, 0.70% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #161683), IRONSIDES ASSET ADVISORS, LLC is subject to fiduciary duty under federal law.

IRONSIDES ASSET ADVISORS, LLC is headquartered in ROCKY MOUNT, NC.

IRONSIDES ASSET ADVISORS, LLC serves 26 high-net-worth clients according to their SEC filing dated February 12, 2026. View client details ↓

According to their SEC Form ADV, IRONSIDES ASSET ADVISORS, LLC offers financial planning, portfolio management for individuals, portfolio management for institutional clients, and selection of other advisors. View all service details ↓

IRONSIDES ASSET ADVISORS, LLC manages $1.4 billion in client assets according to their SEC filing dated February 12, 2026.

According to their SEC Form ADV, IRONSIDES ASSET ADVISORS, LLC serves high-net-worth individuals and institutional clients. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Investment Advisor Selection

Fee Structure

Primary Fee Schedule (IRONSIDES ASSET ADVISORS, LLC)

MinMaxMarginal Fee Rate
$0 $10,000,000 0.85%
$10,000,001 and above 0.70%

Minimum Annual Fee: $42,500

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million Below minimum client size
$5 million $42,500 0.85%
$10 million $85,000 0.85%
$50 million $365,000 0.73%
$100 million $715,000 0.72%

Clients

Number of High-Net-Worth Clients: 26
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 97.17%
Average Client Assets: $53.2 million
Total Client Accounts: 872
Discretionary Accounts: 237
Non-Discretionary Accounts: 635
Minimum Account Size: $5,000,000
Note on Minimum Client Size: $5,000,000

Regulatory Filings

CRD Number: 161683
Filing ID: 2051791
Last Filing Date: 2026-02-12 19:12:17

Form ADV Documents

Primary Brochure: IRONSIDES ASSET ADVISORS, LLC (2026-02-12)

View Document Text
Brochure Form ADV Part 2A Item 1 - Cover Page Ironsides Asset Advisors, LLC CRD# 161683 511 Tarrytown Center Rocky Mount, North Carolina 27804 (252) 443-7041 February 12, 2026 This Brochure provides information about the qualifications and business practices of Ironsides Asset Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us at (252) 443-7041 or WGibson@IronsidesAA.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state authority. www.AdviserInfo.sec.gov Ironsides Asset Advisors, LLC is an investment advisory firm registered with the appropriate regulatory authority. Registration does not imply a certain level of skill or training. Additional information about Ironsides also is available on the SEC’s website at . Item 2 - Material Changes This Brochure is prepared in the revised format required beginning in 2011. Registered Investment Advisers are required to use this format to inform clients of the nature of advisory services provided, types of clients served, fees charged, potential conflicts of interest and other information. The Brochure requirements include providing a Summary of Material Changes (the “Summary”) reflecting any material changes to our policies, practices, or conflicts of interest made since our last required “annual update” filing. In the event of any material changes such Summary is provided to all clients within 120 days of our fiscal year-end. Our last annual update was filed on February 19, 2025. Of course, the complete Brochure is available to you at any time upon request. Item 3 - Table of Contents Page Item 1 - Cover Page ............................................................................................................................................................ 1 Item 2 - Material Changes................................................................................................................................................ 1 Item 3 - Table of Contents ............................................................................................................................................... 2 Item 5 - Fees and Compensation .................................................................................................................................. 5 Item 6 - Performance-Based Fees and Side-By-Side Management ................................................................ 6 Item 7 - Types of Clients .................................................................................................................................................. 6 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 7 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 .. 11 Item 12 - Brokerage Practices ..................................................................................................................................... 12 Item 13 - Review of Accounts ...................................................................................................................................... 14 Item 14 - Client Referrals and Other Compensation .......................................................................................... 14 Item 15 - Custody .............................................................................................................................................................. 15 Item 16 - Investment Discretion ................................................................................................................................. 15 Item 17 - Voting Client Securities .............................................................................................................................. 15 Item 18 - Financial Information .................................................................................................................................. 16 Brochure Supplements………….…………..………………………...……………………………………………… Exhibit A Page 2 Item 4 - Advisory Business Exhibit A General Information Ironsides Asset Advisors, LLC (“Ironsides”), formed in 2009, provides financial planning, portfolio management and general consulting services to our clients. Brochure Supplements E. Wayne Gibson and Mark E. Roberts are the principal owners of Ironsides. Please see , for more information on Mr. Gibson and Mr. Roberts. As of December 31, 2025, Ironsides managed $578,066,923 on a discretionary basis and $845,809,529 on a non-discretionary basis. SERVICES PROVIDED At the outset of each client relationship, we spend time with you, asking questions, discussing your investment experience and financial circumstances, and broadly identifying your major goals. Some clients may elect to retain us to prepare a full financial plan, while most want us to prepare an asset allocation plan. At least one of these written reports is presented to you for consideration. In most cases, a client will retain us to manage the investment portfolio on an ongoing basis. For those financial planning clients making this election, and for other clients who do not need financial planning but retain us for portfolio management services, based on all the information initially gathered, we generally develop: • • a financial outline for you based on your financial circumstances and goals, and your risk tolerance level (the “Financial Profile” or “Profile”); and your investment objectives and guidelines (the “Investment Policy Statement”). The Financial Profile is a reflection of your current financial picture and a look to your future goals. The Investment Policy Statement outlines the types of investments we plan to make on your behalf to meet those goals. The Financial Profile and the Investment Policy Statement are discussed regularly with you, are not necessarily written documents and are subject to modification as circumstances change. Where we provide general consulting services, we will work with you to prepare an appropriate summary of the specific project(s) to the extent necessary or advisable under the circumstances. Financial Planning One of the services we offer is Financial Planning, described below. This service may be provided as a stand-alone service or may be coupled with ongoing portfolio management. Financial Planning may include advice that addresses one or more areas of your financial situation, such as estate planning, risk management, budgeting and cash flow controls, retirement planning, education funding, and investment portfolio design and ongoing management. Depending on your particular situation, financial planning may include some or all of the following: • • • Gathering factual information concerning your personal and financial situation; Assisting you in establishing financial goals and objectives; Analyzing your present situation and anticipated future activities in light of your financial goals and objectives; Page 3 • • • • • • Identifying problems foreseen in the accomplishment of these financial goals and objectives and offering alternative solutions to the problems; Making recommendations to help achieve retirement plan goals and objectives; Designing an investment portfolio to help meet your goals and objectives; Providing input regarding estate planning strategies; Assessing risk and reviewing basic health, life and disability insurance needs; or Reviewing goals and objectives and measuring progress toward these goals. Once Financial Planning advice is given, you may choose to have us implement your financial plan and manage your investment portfolio on an ongoing basis. However, you are under no obligation to act upon any of the recommendations made by us under a Financial Planning engagement and/or engage the services of any recommended professional. Portfolio Management As described above, at the beginning of a client relationship, we meet with you, gather information, and perform research and analysis as necessary to develop your Investment Policy Statement. The Investment Policy Statement will be updated from time to time when requested by you, or when determined to be necessary or advisable by us based on updates to your financial or other circumstances. To implement your Investment Plan, we will manage your investment portfolio on a discretionary basis. As a discretionary investment adviser, we will have the authority to supervise and direct your portfolio without prior consultation with you. Notwithstanding the foregoing, you may impose certain written restrictions on us in the management of your investment portfolio, such as prohibiting the inclusion of certain types of investments in an investment portfolio or prohibiting the sale of certain investments held in the account at the commencement of the relationship. You should note, however, that restrictions imposed by you may adversely affect the composition and performance of your investment portfolio. You should also note that your investment portfolio is treated individually by giving consideration to each purchase or sale for your account. For these and other reasons, performance of your investment portfolio within the same investment objectives, goals and/or risk tolerance may differ and you should not expect that the composition or performance of your investment portfolio would necessarily be consistent with similar clients of ours. in recommending/selecting Managers generally include your stated Separate Account Managers When appropriate and in accordance with the Investment Policy Statement for you, we may recommend the use of one or more Separate Account Managers (each a “Manager”). Having access to various Managers offers a wide variety of manager styles, and offers clients the opportunity to utilize more than one Manager if necessary to meet their needs and investment objectives. We will usually select or recommend the Manager(s) we deem most appropriate for you. Factors that we investment consider objective(s), management style, performance, risk level, reputation, financial strength (to the extent available), reporting, pricing, and research. The Manager(s) will generally be granted discretionary trading authority to provide investment supervisory services for your portfolio. Under certain circumstances, we may retain the authority to terminate the Manager’s relationship or to add new Managers without your specific consent. In other situations, you may ultimately be asked to select one or more Managers recommended by us. Fees paid to such Manager(s) are separate from and in addition to the fee assessed by Ironsides. Page 4 In any case, with respect to assets managed by a Manager, our role will be to monitor your overall financial situation, to monitor the investment approach and performance of the Manager(s), and to assist you in understanding the investments of your portfolio. Third Party Wrap Programs From time to time and in accordance with the Investment Policy Statement for you, we may utilize one or more Managers in a Third-Party Wrap Program. Wrap Programs generally offer a wide variety of manager styles and offer clients the opportunity to utilize more than one Manager if necessary to meet their needs and investment objectives. A Wrap Program is one that charges one fee (the “wrap fee”) for both the Manager’s fee and the transaction expenses incurred by the account. Our fee is charged separately from, and in addition to, the wrap fee. Individual Retirement Advice When we are making investment recommendations to you regarding your retirement plan account or individual retirement account, we are acting as fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money or otherwise are compensated creates some conflicts with your financial interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must:       Meet a professional standard of care when making investment recommendations (give prudent advice) to you; Never put our financial interests ahead of yours when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; Charge no more than what is reasonable for our services; and Give you basic information about our conflicts of interest. General Consulting In addition to the foregoing services, we may provide general consulting services to clients. These services are generally provided on a project basis, and may include, without limitation, minimal cash flow planning for certain events such as education expenses or retirement, estate planning analysis, and review of a client’s insurance portfolio, as well as other matters specific to the client as and when requested by the client and agreed to by Ironsides. The scope and fees for consulting Item 5 - Fees and Compensation services will be negotiated with each client at the time of engagement for the applicable project. Item 12 - Brokerage Practices Please see General Fee Information Fees paid to us are exclusive of all custodial and transaction costs paid to your custodian, brokers or other third-party consultants. for additional information. Fees paid to us are also separate and distinct from the fees and expenses charged by mutual funds, ETFs (exchange traded funds) or other investment pools to their shareholders (generally including a management fee and fund expenses, as described in each fund’s prospectus or offering materials). You should review all fees charged by funds, brokers, Ironsides and others to fully understand the total amount of fees paid by you for investment and financial-related services. Page 5 Financial Planning Fees When we provide stand-alone financial planning services to clients, these fees are negotiated at the time of the engagement for such services and are normally based on a fixed fee. Portfolio Management Fees The annual fee schedule, based on a percentage of assets under management, is as follows: Portfolio Value Annual Fee Up to $10,000,000 Account over $10,000,000 0.85% flat fee 0.70% flat fee The minimum portfolio value is generally set at $5,000,000. The minimum annual fee for any account is $42,500. We may, at our discretion, make exceptions to the foregoing or negotiate special fee arrangements where we deem appropriate under the circumstances. Portfolio management fees are generally payable quarterly, in arrears. Because some fees are based on average daily portfolio values, these fees are, in essence, prorated for assets added to or distributed from a portfolio during a quarter. If management begins or ends after the start of a calendar quarter, we will prorate fees accordingly. With your authorization and unless other arrangements are made, fees are normally debited directly from your account(s). Either you or Ironsides may terminate your Investment Management Agreement at any time, subject to any written notice requirements in the agreement. In the event of termination, any fees due to us from you will be invoiced or deducted from your account prior to termination, at our discretion. Separate Account Manager Fees When a Manager(s) is/are utilized, the Managers’ fees will be separate from, and in addition to, our fee. Wrap Programs Fees Ironsides’ fees are charged separately from, and in addition to, Wrap Program fees. General Consulting Fees When we provide general consulting services to clients, these services are generally separate from our financial planning and portfolio management services. Fees for general consulting are negotiated at the time of the engagement for such services and are normally based on an hourly or Item 6 - Performance-Based Fees and Side-By-Side Management fixed fee basis. We do not have any performance-based fee arrangements. “Side-by-Side Management” refers to a situation in which the same firm manages accounts that are billed based on a percentage of assets under management and at the same time manages other accounts for which fees are assessed on a performance fee basis. Because we have no performance-based fee accounts, we have no side-by- side management. Item 7 - Types of Clients We serve individuals, corporations, trusts, estates, pension plans, and foundations, endowments and other charitable organizations. With some exceptions, the minimum portfolio value eligible for Page 6 conventional investment advisory services is $5,000,000, and the annual minimum fee charged is $42,500. Under certain circumstances and in our sole discretion, we may negotiate such Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss minimums. Methods of Analysis To develop your Investment Policy Statement, we begin with Asset Allocation planning and the particular risk and objectives of your portfolio. Once we have developed your Investment Policy Statement to attempt to meet these objectives, we will invest the portfolio in numerous investments including, but not limited to, common stocks, ETFs, individual bonds, with third party managers (primarily private fund Managers), and in mutual funds. In making selections of individual stocks for client portfolios, we may use any of the following types of analysis: Fundamental Analysis – involves review of the business and financial information about an issuer. Without limitation, the following factors generally will be considered: o o o o Financial strength ratios; Price-to-earnings ratios; Dividend yields; and Ratio of Price-to-earnings to growth rate Technical Analysis – involves studying past price patterns and trends in the financial markets to predict the direction of both the overall market and specific stocks. Cyclical Analysis – involves evaluating recurring price patterns and trends in a type of technical analysis. We generally evaluate and select mutual funds and ETFs based on a variety of factors, including, as applicable and without limitation, past performance, fee structure, portfolio manager, fund sponsor, overall ratings for safety and returns, and other factors. When we select Hedge Fund and Active Equity/Credit Managers, we utilize multiple evaluation methods. Quantitatively, we dissect each Manager’s return history by looking at a combination of annualized returns over various periods, an evaluation of rolling correlations, and volatility measures. To evaluate downside risk, we consider rolling Sortino ratios and semi-variance characteristics, as well as the Manager’s return skew. Qualitatively, we will interview each management team, seeking to understand organizational dynamics, determine who the key decision makers are, evaluate firm compensation and, most importantly, determine if their team has developed a replicable process. We believe that process and discipline lead toward more reliable investment results. We source Managers via a variety of access points including database searches, manager references, industry research, and our contact group. Although we do not accept compensation from Managers, there is sometimes no way to determine definitively if fees charged by any Manager are impacted by the cumulative amount of investments from our different clients and, if so, whether the benefit accrues to any specific client(s) of ours. Our goal is for any benefit to accrue to all of our clients invested in that Manager. Page 7 When we select illiquid Private Equity/Credit and Private Asset managers, we utilize multiple evaluation methods. We evaluate the manager’s performance relative to the vintage invested and the specified market segment, and by seeking to evaluate the specific internal team tied to portfolio transactions. These will often include the evaluation of purchase multiples, process improvements at the particular portfolio companies and the exit process utilized by the private manager. We look at the alignment of interests by evaluating the terms and structure of the fund. Evaluations are tailored by manager type and segment. We source Private Asset Managers via a variety of access points including database searches, manager references, industry research, and our contact group. We sometimes use fixed income investments as a strategic investment, as an instrument to fulfill liquidity or income needs in a portfolio, or to add a component of capital preservation. We will generally evaluate and select individual bonds or bond funds based on a number of factors including, without limitation, rating, yield and duration. Investment Strategies Our strategic approach is to invest your portfolio in accordance with the Investment Policy Statement that has been developed specifically for you. We use common stocks extensively, while we utilize ETFs to invest passively in segments of the market to meet portfolio or asset allocation weights. On a targeted basis, we will utilize ETFs to hedge the portfolio. As mentioned above, we may use individual bonds as strategic investments to fulfill specific liquidity needs in a portfolio. We will use other types of instruments as appropriate. Selectively (<10%) we will occasionally enter into arbitrage trades where we purchase acquisition companies and attempt to earn an accreted purchase target. We primarily do this for cash acquisitions, but intermittently based on our risk/reward evaluation, we may enter a long (the target) and short (the acquirer) position in a stock-for-stock acquisition. We may use the following specific strategies in varying combinations over time for a given client, depending upon the client’s individual circumstances: Long Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Short Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short term price fluctuations. Short Sales – a securities transaction in which an investor sells securities he or she borrowed in anticipation of a price decline. The investor is then required to return an equal number of shares at some point in the future. A short seller will profit if the stock goes down in price. Margin Transactions – a securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. While we typically do not engage in this, certain transactions, such as short sales and writing of options, by their nature are margin transactions. Trading – generally considered holding a security for less than thirty (30) days. Page 8 Options Trading/Writing – a securities transaction that involves buying or selling (writing) an option. If you write an option, and the buyer exercises the option, you are obligated to purchase or deliver a specified number of shares at a specified price at the exercise of the option regardless of the market value of the security at expiration of the option. Buying an option gives you the right to purchase or sell a specified number of shares at a specified price until the date of expiration of the option regardless of the market value of the security at expiration of the option. Hedging – We will evaluate and implement strategies that hedge, overlay or alter the core portfolio. These strategies will typically be utilized to mitigate risk, enhance yield or change the overall characteristics of the underlying portfolio. Risk of Loss While we seek to diversify your investment portfolio across various asset classes consistent with your Investment Policy Statement in an effort to reduce risk of loss, all investment portfolios are subject to risks. Accordingly, there can be no assurance that your investment portfolio will be able to fully meet your investment objectives and goals, or that investments will not lose money. Below is a description of several of the principal risks that your investment portfolio faces. Management Risks. While we manage your investment portfolio based on our experience, research and proprietary methods, the value of your investment portfolio will change daily based on the performance of the underlying securities in which it is invested. Accordingly, your investment portfolio is subject to the risk that we allocate your assets to individual securities and/or asset classes that are adversely affected by unanticipated market movements or by unanticipated economic factors, and the risk that our specific investment choices could underperform their relevant indexes. Risks of Investments in Mutual Funds, ETFs and Other Investment Pools. As described above, we may invest your portfolios in mutual funds, ETFs and other investment pools (“pooled investment funds”). Investments in pooled investment funds are generally less risky than investing in individual securities because of their diversified portfolios; however, these investments are still subject to risks associated with the markets in which they invest. In addition, pooled investment funds’ success will be related to the skills of their particular managers and their performance in managing their funds. Pooled investment funds are also subject to risks due to regulatory restrictions applicable to registered investment companies under the Investment Company Act of 1940. Risks Related to Alternative Investment Vehicles (“Private Funds”) . From time to time and as appropriate, we may recommend that a client invest a portion of his or her portfolio in Private Funds, whether Hedge Funds, Private Equity/Credit Funds, or Direct Private Investments. The value of client portfolios will be based in part on the value of Private Funds in which they are invested, the success of each of which will depend heavily upon the efforts of their respective Managers. When the investment objectives and strategies of a Manager are out of favor in the market or a Manager makes unsuccessful investment decisions, the Private Fund may lose money. A client account may lose a substantial percentage of its value if the investment objectives and strategies of many or most of the Private Funds in which it is invested are out of favor at the same time, or many or most of the Managers make unsuccessful investment decisions at the same time. Hedge Funds are generally subject to various risk factors and liquidity constraints, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to clients Page 9 for review and consideration prior to investing. Investing in Hedge Funds is intended only for experienced and sophisticated investors who are willing to bear the high economic risks of the investment. Clients should carefully review and consider potential risks before investing in Hedge Funds. Certain of these risks may include: loss of all or a substantial portion of the investment due to leveraging, short-selling, or other speculative practices; lack of liquidity because of redemption terms and conditions and the fact that there generally will not be a secondary market for the Hedge Fund; volatility of returns; restrictions on transferring interests in the fund; a potential lack of diversification; higher fees than mutual funds, and limited transparency regarding valuations. Private Equity/Credit Funds and Direct Private Investments are generally subject to various risk factors and liquidity constraints, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to clients for review and consideration prior to investing. Investing in Private Equity/Credit Funds and Direct Private Investments is intended only for experienced and sophisticated investors who are willing to bear the high economic risks of the investment. Clients should carefully review and consider potential risks before investing in Private Equity/Credit Funds or Direct Private Investments. Certain of these risks may include: loss of all or a substantial portion of the investment due to leveraging or other speculative practices; lack of liquidity because there generally will not be a secondary market for the Private Equity/Credit Fund or Direct Private Investment; volatility of returns; restrictions on the transfer of interests in the fund or direct investment; lack of diversification; higher fees than mutual funds, and limited transparency regarding valuations. Equity Market Risks. We will generally invest portions of your assets directly into equity investments, either stocks or pooled investment funds that invest in the stock market. As noted above, while pooled investments have diversified portfolios that may make them less risky than investments in individual securities, funds that invest in stocks and other equity securities are nevertheless subject to the risks of the stock market. These risks include, without limitation, the risks that stock values will decline due to daily fluctuations in the markets, that stock values will decline over longer periods (e.g., bear markets) due to general market declines in the stock prices for all companies, regardless of any individual security’s prospects, and that the manager of the pooled investment fund may not properly analyze a company’s prospects and select the wrong companies in which to invest. Fixed Income Risks. We may invest portions of your assets directly into fixed income instruments, such as bonds and notes, or may invest in pooled investment funds that invest in bonds and notes. While investing in fixed income instruments, either directly or through pooled investment funds, is generally less volatile than investing in stock (equity) markets, fixed income investments nevertheless are subject to risks. These risks include, without limitation, interest rate risks (risks that changes in interest rates will devalue the investments), credit risks (risks of default by borrowers), or maturity risk (risks that bonds or notes will change value from the time of issuance to maturity). Foreign Securities Risks. We may invest portions of your assets into pooled investment funds that invest internationally. While foreign investments are sometimes important to the diversification of your investment portfolio, they carry risks that may be different from U.S. investments. For example, foreign investments may not be subject to uniform audit, financial reporting or disclosure standards, practices or requirements comparable to those found in the U.S. Foreign investments are also subject to foreign withholding taxes and the risk of adverse changes in investment or exchange control regulations. Finally, foreign investments may involve currency risk, which is the risk that the value of the foreign security will decrease due to changes in the relative value of the U.S. dollar and the security’s underlying foreign currency. Page 10 Item 9 - Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of Ironsides or the integrity of our management. We have no disciplinary events. Item 10 - Other Financial Industry Activities and Affiliations Neither Ironsides nor our Management Persons have any other financial industry activities or Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading affiliations to report. Code of Ethics and Personal Trading We have adopted a Code of Ethics (“the Code”), the full text of which is available to you upon request. Our Code has several goals. First, the Code is designed to assist us in complying with applicable laws and regulations governing our investment advisory business. Under the Investment Advisers Act of 1940, we owe fiduciary duties to our clients. Pursuant to these fiduciary duties, our Code requires persons associated with us (managers, officers and employees) to act with honesty, good faith and fair dealing in working with clients. In addition, the Code prohibits such associated persons from trading or otherwise acting on insider information. Next, the Code sets forth guidelines for professional standards for our associated persons. Under the Code’s Professional Standards, we expect our associated persons to put the interests of our clients first, ahead of personal interests. In this regard, our associated persons are not to take inappropriate advantage of their positions in relation to our clients. Third, the Code sets forth policies and procedures to monitor and review the personal trading activities of associated persons. Often our associated persons will invest in the same securities recommended to clients. Under our Code, Ironsides has adopted procedures designed to reduce or eliminate conflicts of interest that this could potentially cause. The Code’s personal trading policies include procedures for limitations on personal securities transactions of associated persons, reporting and review of such trading and pre-clearance of certain types of personal trading activities. These policies are designed to discourage and prohibit personal trading that would disadvantage clients. The Code also provides for disciplinary action as appropriate for violations. In addition to the above, by virtue of being a CFA, Mark Roberts is obligated to follow the guidelines established by the CFA Institute. Participation or Interest in Client Transactions As outlined above, we have adopted procedures to protect client interests when our associated persons invest in the same securities as those selected for or recommended to clients. In the event of any identified potential trading conflicts of interest, our goal is to place client interests first. Consistent with the foregoing, we maintain policies regarding participation in initial public offerings (“IPOs”) and private placements to comply with applicable laws and avoid conflicts with client transactions. If our associated person wishes to participate in an IPO or invest in a private placement, he or she must submit a pre-clearance request and obtain the approval of the Chief Compliance Officer. Page 11 Item 12 - Brokerage Practices Best Execution and Benefits of Brokerage Selection When given discretion to select the brokerage firm that will execute orders in your account, we seek “best execution” for your trades, which is a combination of a number of factors, including, without limitation, quality of execution, services provided and commission rates. Therefore, we may use or recommend the use of brokers who do not charge the lowest available commission in the recognition of research and securities transaction services, or quality of execution. Research services received with transactions may include proprietary or third-party research (or any combination), and may be used in servicing any or all of our clients. Therefore, research services received may not be used for the account for which the particular transaction was effected. We generally recommend that you establish a brokerage account with Charles Schwab & Co., Inc. (“Schwab”), a FINRA registered broker-dealer, member SIPC, as the qualified custodian to maintain custody of your assets. Ironsides may also place trades for client accounts at Schwab, or may in some instances, consistent with our duty of best execution and specific agreement with each client, elect to execute trades elsewhere. Although we may recommend that you establish an account or accounts at Schwab, it is ultimately your decision whether to custody assets with Schwab or with another broker/dealer. We are independently owned and operated and are not affiliated with Schwab. Schwab Advisor Services provides us with access to its institutional trading, custody, reporting and related services, which are typically not available to Schwab retail investors. 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. These services generally are available to independent investment advisors on an unsolicited basis, at no charge to them. These services are not soft dollar arrangements but are part of the institutional platform offered by Schwab. Schwab’s brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account. Schwab Advisor Services also makes available to us other products and services that benefit us but may not directly benefit our clients’ accounts. Many of these products and services may be used to service all or a substantial number of our accounts, including accounts not maintained at Schwab. Schwab’s products and services that assist us in managing and administering clients’ accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide, pricing and other market data; (iv) facilitate payment of Ironsides’ fees from its clients’ accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Schwab Advisor Services also offers other services intended to help us manage and further develop our business enterprise. These services may include: (i) technology, compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. Page 12 Schwab may make available, arrange and/or pay third-party vendors for the types of services rendered to us. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to Ironsides. Schwab Advisor Services may also provide other benefits such as educational events or occasional business entertainment of our personnel. In evaluating whether to recommend that clients custody their assets at Schwab, we may take into account the availability of some of the foregoing products and services and other arrangements as part of the total mix of factors we consider and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab, which may create a potential conflict of interest. Directed Brokerage You may direct us to use a particular broker for custodial or transaction services on behalf of your portfolio. In directed brokerage arrangements, you are responsible for negotiating the commission rates and other fees to be paid to the broker. Accordingly, if you choose to direct brokerage you should consider whether such designation may result in certain costs or disadvantages to you, either because you may pay higher commissions or obtain less favorable execution, or the designation limits the investment options available to you. The arrangement that we have with Schwab is designed to maximize efficiency and to be cost effective. By directing brokerage arrangements, you acknowledge that these economies of scale and levels of efficiency are generally compromised when alternative brokers are used. While every effort is made to treat clients fairly over time, the fact that a client chooses to use the brokerage and/or custodial services of these alternative service providers can in fact result in a certain degree of delay in executing trades for their account(s) and otherwise adversely affect management of their account(s). By directing us to use a specific broker or dealer, clients who are subject to ERISA confirm and agree with us that they have the authority to make the direction, that there are no provisions in any client or plan document which are inconsistent with the direction, that the brokerage and other goods and services provided by the broker or dealer through the brokerage transactions are provided solely to and for the benefit of the client’s plan, plan participants and their beneficiaries, that the amount paid for the brokerage and other services have been determined by the client and the plan to be reasonable, that any expenses paid by the broker on behalf of the plan are expenses that the plan would otherwise be obligated to pay, and that the specific broker or dealer is not a party in interest of the client or the plan as defined under applicable ERISA regulations. Aggregated Trade Policy We enter trades as a block where possible and when advantageous to clients whose accounts have a need to buy or sell shares of the same security. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts. Block trading allows us to execute equity trades in a timelier, equitable manner, and may reduce overall costs to clients. We will only aggregate transactions when we believe that aggregation is consistent with our duty to seek best execution (which includes the duty to seek best price) for our clients, and is consistent with the terms of our Investment Advisory Agreement with each client for which trades are being aggregated. No advisory client will be favored over any other client; each client that participates in an aggregated order will participate at the average share price for all Ironsides’ transactions in a given security for that order, with transaction costs generally being set on a per account basis. On occasion, owing to the size of a particular account’s pro rata share of an order or other factors, the commission or transaction fee charged could be above or below a breakpoint in a pre-determined Page 13 commission or fee schedule set by the executing broker, and therefore transaction charges may vary slightly among accounts. Accounts may be excluded from a block due to tax considerations, client direction, allocation issues or other factors making the account’s participation ineligible, impractical or inappropriate. Also, we may include an allocation in the block for accounts of our principals on the same basis as it does for our clients. We will prepare, before entering an aggregated order, a written statement (“Allocation Statement”) specifying the participating client accounts and how we intend to allocate the order among those clients. If the aggregated order is filled in its entirety, it will be allocated among clients in accordance with the Allocation Statement. If the order is partially filled, it will generally be allocated pro-rata, based on the Allocation Statement, or randomly in certain circumstances. Notwithstanding the foregoing, the order may be allocated on a basis different from that specified in the Allocation Statement if all client accounts receive fair and equitable treatment, and the reason for different allocation is explained in writing and is approved by an appropriate individual/officer of Ironsides. Our books and records will separately reflect, for each client account included in a block trade, the securities held by and bought and sold for that account. Funds and securities of clients whose orders are aggregated will be deposited with one or more banks or broker-dealers, and neither the clients’ cash nor their securities will be held collectively any longer than is necessary to settle the transaction on a delivery versus payment basis; cash or securities held collectively for clients will be delivered out to the custodian bank or broker-dealer as soon as practicable following the settlement, and we will receive no additional compensation or Item 13 - Review of Accounts remuneration of any kind as a result of the proposed aggregation. Managed portfolios are reviewed at least quarterly but may be reviewed more often if requested by you, upon receipt of information material to the management of your portfolio, or at any time such a review is deemed necessary or advisable by us. These factors generally include but are not limited to, the following: change in your general circumstances (marriage, divorce, retirement); or economic, political or market conditions. Wayne Gibson and Mark Roberts, Ironsides’ Members, review all accounts. For those clients to whom we provide separate financial planning and/or consulting services, reviews are conducted on an as-needed or agreed-upon basis. Such reviews are conducted by one of our investment adviser representatives or principals. Account custodians are responsible for providing monthly or quarterly account statements which reflect the positions (and current pricing) in each account as well as transactions in each account, including fees paid from an account. Account custodians also provide prompt confirmation of all trading activity and year-end tax statements, such as 1099 forms. In addition, on at least an annual basis we provide you with a written statement of holdings and returns for your managed portfolio. Item 14 - Client Referrals and Other Compensation As noted in Item 12 above, we receive certain “economic” benefits from Schwab in the form of support products and services it makes available to us and other independent investment advisors Item 12 - Brokerage Practices. whose clients maintain accounts at Schwab. These products and services, how they benefit our firm, and the related conflicts of interest are described in detail in The availability of Schwab’s products and services to us is based solely on our participation in the programs and not on the provision of any particular investment advice. Neither Schwab nor any other party is paid to refer clients to Ironsides. Page 14 Item 15 - Custody Schwab is the custodian of nearly all client accounts at Ironsides. From time to time, however, you may select an alternate broker to hold accounts in custody. In any case, it is the custodian’s responsibility to provide you with confirmations of trading activity, tax forms and statements no less often than quarterly. You are advised to review this information carefully, and to notify us of any questions or concerns. You are also asked to notify us promptly if the custodian fails to provide statements on each account held. From time to time and in accordance with our agreement with you, we will provide additional reports. The account balances reflected on these reports should be compared to the balances shown on the brokerage statements to ensure accuracy. At times there may be small differences due to the timing of dividend reporting, pending trades, differences in pricing or other similar issues. Item 16 - Investment Discretion Item 4 - Advisory Business discretionary accounts , we will accept clients on either a discretionary or non- As described in discretionary basis. For , a Limited Power of Attorney (“LPOA”) is executed by you, giving us the authority to carry out various activities in your account, generally including the following: trade execution; the ability to request checks on your behalf; and, the withdrawal of advisory fees directly from your account. We then direct investment of your portfolio using our discretionary authority. You may limit the terms of the LPOA to the extent consistent with your investment advisory agreement with us and the requirements of your custodian. non-discretionary For accounts, you also generally execute an LPOA, which allows us to carry out trade recommendations and approved actions in the portfolio. However, in accordance with the investment advisory agreement between you and Ironsides, we do not implement trading recommendations or other actions in the account unless and until you have approved the recommendation or action. As with discretionary accounts, you may limit the terms of the LPOA, Item 17 - Voting Client Securities subject to our agreement with you and the requirements of your custodian. Where we have the authority to vote proxies, we will seek to vote proxies in the best interest of the client(s) holding the applicable securities. In voting proxies, we consider factors that we believe relate to the client’s investment(s) and factors, if any, that are set forth in written instructions from the client. for In general, we believe that voting proxies in accordance with the following guidelines, with respect to such routine items, is in the best interests of our clients. Accordingly, we generally vote : • • • • • • The election of directors (where no corporate governance issues are implicated); Proposals that strengthen the shared interests of shareholders and management; The selection of independent auditors based on management or director recommendation, unless a conflict of interest is perceived; Proposals that we believe may lead to an increase in shareholder value; Management recommendations adding or amending indemnification provisions in charter or by-laws; and Proposals that maintain or increase the rights of shareholders. Page 15 against We will generally vote any proposals that we believe will have a negative impact on shareholder value or rights. If we perceive a conflict of interest, our policy is to notify affected clients so that they may choose the course of action they deem most appropriate. A copy of our complete policy and records of proxies voted are available to you upon request. As required under the Advisers Act, such records are maintained for a period of five (5) years. Item 18 - Financial Information We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore have no disclosure required for this item. Page 16 Exhibit A Brochure Supplement Form ADV Part 2B Item 1 - Cover Page E. Wayne Gibson CRD# 6029583 of Ironsides Asset Advisors, LLC 511 Tarrytown Center Rocky Mount, North Carolina 27804 (252) 443-7041 February 12, 2026 This Brochure Supplement provides information about Wayne Gibson, and supplements the Ironsides Asset Advisors, LLC (“Ironsides”) Brochure. You should have received a copy of that Brochure. Please contact us at (252) 443-7041 if you did not receive our Brochure, or if you have any questions about the contents of this Supplement. www.AdviserInfo.sec.gov. Additional information about Wayne is available on the SEC’s website at Item 2 - Educational Background and Business Experience E. Wayne Gibson (year of birth 1952) is the Manager and a Member of Ironsides. As an entrepreneur, Wayne is an officer, director, and/or owner of numerous businesses, as well as being involved in several foundations. In particular, he has served as President and a director of Tuscarora Company, LLC (and predecessors) since 1982 and was a director and served as Chairman of the Executive Committee of Ellett Brothers, Inc. during its eight years as a public company. Wayne has extensive experience in commercial real estate and in business mergers and acquisitions, as well as in investments in public equities. He has been instrumental in the analysis and negotiations for the acquisition and divestiture of more than 30 private and public companies. Wayne received both his Master of Business Administration degree and his Bachelor of Arts degree from the University of North Carolina at Chapel Hill. Item 3 - Disciplinary Information Advisers are required to disclose any material facts regarding certain legal or disciplinary events that would be material to your evaluation of an adviser; however, Wayne has no such disciplinary information to report. Exhibit A-1 Item 4 - Other Business Activities Wayne is the owner and President of Tuscarora Company, LLC. Tuscarora has an office building it rents to outside tenants; additionally, it is in the private investment business and provides administrative services to Ironsides. Furthermore, Wayne is Trustee of the Robert D. Gorham, Jr. Master Foundation Trust. Mr. Gorham was the founder of Tuscarora’s predecessor company, and Wayne is responsible for managing Mr. Gorham’s investments through the trust. Wayne spends approximately 50% of his time on other business and charitable matters. Other than being involved in the private investment business and charitable organizations, Wayne is not engaged in any other investment-related business or occupation, and does not earn Item 5 - Additional Compensation compensation for the sale of any other products or services. As stated above, Wayne has no other income or compensation to disclose. Item 6 - Supervision As the principal owner and Chief Compliance Officer of Ironsides, Wayne supervises all duties and activities of the firm, and is responsible for all advice provided to clients. He can be reached at (252) 443-7041. Exhibit A-2 Brochure Supplement Form ADV Part 2B Item 1 - Cover Page Mark E. Roberts, CFA CRD# 2229420 of Ironsides Asset Advisors, LLC 511 Tarrytown Center Rocky Mount, North Carolina 27804 (252) 443-7041 February 12, 2026 This Brochure Supplement provides information about Mark Roberts, and supplements the Ironsides Asset Advisors, LLC (“Ironsides”) Brochure. You should have received a copy of that Brochure. Please contact us at (252) 443-7041 if you did not receive our Brochure, or if you have any questions about the contents of this Supplement. www.AdviserInfo.sec.gov. Additional information about Mark is available on the SEC’s website at Item 2 - Educational Background and Business Experience Mark E. Roberts (year of birth 1962) is a Member and the Chief Investment Officer of Ironsides. He also serves as Senior Vice President for Tuscarora Company, LLC. Prior to joining Tuscarora in late 2009, Mark was the Director of Global Equities and Hedged Strategies for the North Carolina Retirement Systems, where he and his team were responsible for the $33 billion Global Equity and Hedge Fund portfolios. Additionally, Mark has served as Chief Investment Officer for families and provided consulting services for the North Carolina State University endowment. From 2001 to 2009, he was the Director of Investments for Murphy Family Ventures. ® Mark received his Master of Science degree in Finance from Virginia Commonwealth University and a Bachelor of Science degree from the Calloway School of Business at Wake Forest University. He designation. Mark is a board member on the NC State holds the Chartered Financial Analyst Investment Fund and is a member of the North Carolina Society of Financial Analysts. ® ® (“CFA The Chartered Financial Analyst ”) designation is a professional designation given by the CFA Institute that measures the competence and integrity of financial analysts. The CFA Program is a graduate-level self-study program that combines a broad-based curriculum of investment principles with professional conduct requirements. Candidates are required to pass three levels of Exhibit A-3 examinations covering areas such as accounting, economics, ethics, money management and security analysis. Before a candidate is eligible to become a CFA charterholder, he must meet minimum experience requirements in the area of investment/financial practice. To enroll in the program, a candidate must hold a bachelor’s degree. Item 3 - Disciplinary Information Advisers are required to disclose any material facts regarding certain legal or disciplinary events that would be material to your evaluation of an adviser; however, Mark has no such disciplinary Item 4 - Other Business Activities information to report. Mark serves as Senior Vice President of Tuscarora Company, LLC. Tuscarora has an office building it rents to outside tenants; additionally, it is in the private investment business and provides administrative services to Ironsides. Other than being involved in the private investment business, Mark is not engaged in any other investment-related business or occupation, and does not earn compensation for the sale of any Item 5 - Additional Compensation other products or services. Item 6 - Supervision As stated above, Mark has no other income or compensation to disclose. Wayne Gibson, principal owner and Chief Compliance Officer of Ironsides, is responsible for supervising Mark and for reviewing accounts. Wayne can be reached at (252) 443-7041. Exhibit A-4