LIBERTY ASSET MANAGEMENT, LLC

Part 2A of Form ADV: Firm Brochure Liberty Asset Management, LLC 3570 Hamilton Blvd. Suite 301 Allentown, PA 18103 Telephone: 610 398-7333 Email: Tyopconka@lwmgmt.com Web Address: www.lwmgmt.com Registration does not imply a certain level of skill or training. 08/15/2025 Registration does not imply a certain level of skill or training. This brochure provides information about the qualifications and business practices of Liberty Asset Management, LLC. If you have any questions about the contents of this brochure, please contact us at 610 398-7333 or tyopconka@lwmgmt.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Liberty Asset Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 142094. 1  Item 2 Material Changes This Item is used to provide our clients with a summary of new and/or updated information. We will inform you of the revision(s) based on the nature of the updated information. Specifically, we will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary. The material changes in this brochure from the last annual updating amendment of Liberty Asset Management, LLC on February 18, 2025 are described below. Material changes relate to Firm name policies, practices or conflicts of interests only. • Liberty Asset Management, LLC has transitioned to registration with the United States Securities and Exchange Commission from its prior registration at the state level. 2  Item 3 Table of Contents Page Table of Contents Item 2 Material Changes ..............................................................................................2 Item 3 Table of Contents Page ...................................................................................3 Item 4 Advisory Business ............................................................................................4 Item 6 Performance-Based Fees and Side-By-Side Management .....................10 Item 7 Types of Clients ..............................................................................................10 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................10 Item 9 Disciplinary Information .................................................................................12 Item 10 Other Financial Industry Activities and Affiliations ..................................12 Item 11 Code of Ethics, Participation or Interest in Client Transactions and ...13 Personal Trading .........................................................................................................13 Item 12 Brokerage Practices .....................................................................................14 Item 13 Review of Accounts ......................................................................................16 Item 14 Client Referrals and Other Compensation ...............................................17 Item 15 Custody ..........................................................................................................17 Item 16 Investment Discretion ..................................................................................17 Item 17 Voting Client Securities ...............................................................................17 Item 18 Financial Information ....................................................................................18 3  Item 4 Advisory Business Liberty Asset Management, LLC is a Pennsylvania state registered investment adviser with its principal place of business located in Pennsylvania. Liberty Asset Management, LLC began conducting business in 2011. Listed below are the firm's principal shareholders (i.e., those individuals and/or entities controlling 25% or more of this company). Richard E. Frable Liberty Asset Management, LLC offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations The Asset Allocation Program utilizes the concept of Modern Portfolio Theory as the means of making investment decisions. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. After which, we will make a recommendation as to how the account will be allocated based on our asset allocation methodology. The client will make an investment with a mutual fund family, variable annuity, or brokerage account. We will determine the appropriate mix of investment asset classes and specific mutual funds that we believe will meet the investment objectives of the client. In some cases, the client may have certain investments that he or she does not wish to sell and, in such cases, we will incorporate those investments into the client's portfolio. The investments we select will be reviewed on a regular periodic basis. We may also, from time to time, re-balance the client's portfolio. The minimum account size for this service is $50,000. We may, at our discretion, waive the minimum requirement in some situations. 4  MANAGER SELECTION PROGRAMS We also offer advisory management services to our clients through the Manager Selection Programs (hereinafter, "Programs"). Our firm provides the client with an asset allocation strategy developed through personal discussions in which goals and objectives based on the client's particular circumstances are established. This asset allocation strategy is drafted into the client's Personal Investment Policy Statement ("PIPS"). Based on the client's individual circumstances and needs (as exhibited in the client's PIPS) we will then perform management searches of various unaffiliated registered investment advisers to identify which registered investment adviser's portfolio management style is appropriate for that client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the selected registered investment adviser. Clients should refer to the selected registered investment adviser's Firm Brochure or other disclosure document for a full description of the services offered. We are available to meet with clients on a regular basis, or as determined by the client, to review the account. Once we determine the most suitable investment adviser(s) for the client, we provide the selected adviser(s) with the client's PIPS. The adviser(s) then creates and manages the client's portfolio based on the client's individual needs as exhibited in the PIPS. We monitor the performance of the selected registered investment adviser(s). If we determine that a particular selected registered investment adviser(s) is not providing sufficient management services to the client, or is not managing the client's portfolio in a manner consistent with the client's PIPS, we may suggest that the client contract with a different registered investment adviser and/or program sponsor. Under this scenario, our firm assists the client in selecting a new registered investment adviser and/or program. However, any move to a new registered investment adviser and/or program is solely at the discretion of the client. FINANCIAL PLANNING We provide financial planning services. Financial planning is a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. Clients purchasing this service receive a written report which provides the client with a detailed financial plan designed to assist the client achieve his or her financial goals and objectives. In general, the financial plan can address any or all of the following areas: PERSONAL: We review family records, budgeting, personal liability, estate information and financial goals. TAX & CASH FLOW: We analyze the client’s income tax and spending and planning for past, current and future years; then illustrate the impact of various investments on the client's current income tax and future tax liability. 5  INVESTMENTS: We analyze investment alternatives and their effect on the client's portfolio. INSURANCE: We review existing policies to ensure proper coverage for life, health, disability, long-term care, liability, home and automobile. RETIREMENT: We analyze current strategies and investment plans to help the client achieve his or her retirement goals. DEATH & DISABILITY: We review the client’s cash needs at death, income needs of surviving dependents, estate planning and disability income. ESTATE: We assist the client in assessing and developing long-term strategies, including as appropriate, living trusts, wills, review estate tax, powers of attorney, asset protection plans, nursing homes, Medicaid and elder law. We gather required information through in-depth personal interviews. Information gathered includes the client's current financial status, tax status, future goals, returns objectives and attitudes towards risk. We carefully review documents supplied by the client, including a questionnaire completed by the client, and prepare a written report. Should the client choose to implement the recommendations contained in the plan, we suggest the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. We also provide advice regarding various types of investments which may include: Exchange-listed securities Securities traded over-the-counter Foreign issuers Warrants Corporate debt securities (other than commercial paper) Commercial paper Certificates of deposit Municipal securities Variable life insurance Variable annuities Mutual fund shares United States governmental securities Options contracts on securities Interests in partnerships investing in real estate Interests in partnerships investing in oil and gas interests Interests in partnerships investing in equipment leasing, fast food franchising, and technology, among others. Any other investments we deem appropriate based on the client's stated goals and Objectives In addition, we also provide general non-securities advice on topics that may include tax and budgetary planning, estate planning and business planning. Typically, the financial plan is presented to the client within six months of the contract date, provided that all information needed to prepare the financial plan has been promptly provided. 6  Financial Planning recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company. AMOUNT OF MANAGED ASSETS As of December 2024, LAM’s assets under management are $ 106,177,228 .00 all on a discretionary basis. Item 5 Fees and Compensation INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT FEES The annualized fee for Investment Supervisory Services are charged as a percentage of assets under management, according to the following schedule: Asset Allocation Program Assets up to $1,000,000 1.50% Assets over $1,000,000 1.00% Fees are charged in advance on a calendar quarter basis. They are calculated by taking the account value on the last day of the calendar quarter and multiplying by one-quarter of the annual fee. The initial fee will be prorated when the account is established during the quarter. When a copy of the Brochure Document(s) is not provided to the client at least 48 hours prior to signing the contract(s), client has five business days in which to cancel the contract, without penalty. If the investment advisory agreement is cancelled during a quarter the unused portion of the feel will be refunded on a prorated basis. Because client fees will be withdrawn directly from client accounts, LAM will: (A) Possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian. (B) Send the qualified custodian written notice of the amount of the fee to be deducted from the client’s account and verify that the qualified custodian sends invoices to the client. (C) Send the client a written invoice itemizing the fee upon or prior to fee deduction, including the formula used to calculate the fee, the time period covered by the fee and the amount of assets under management on which the fee was based. Limited Negotiability of Advisory Fees: Although Liberty Asset Management, LLC has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, assets 7  to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule is identified in the contract between the adviser and each client. We may group certain related client accounts for the purposes of achieving the minimum account size requirements and determining the annualized fee. Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons of our firm. FINANCIAL PLANNING FEES Liberty Asset Management, LLC's Financial Planning fee is determined based on the nature of the services being provided and the complexity of each client’s circumstances. All fees are agreed upon prior to entering into a contract with any client. Our Financial Planning fees are calculated and charged on a fixed fee basis, typically ranging from $300 to $3,000, depending on the specific arrangement reached with the client. We may also charge hourly fees for Financial Planning related services. Our hourly rate ranges between $150 and $300. We may request a retainer upon completion of our initial fact-finding session with the client; however, advance payment will never exceed $500 for work that will not be completed within six months. The balance is due upon completion of the plan. Financial Planning Fee Offset: Liberty Asset Management, LLC reserves the discretion to reduce or waive the hourly fee and/or the minimum fixed fee if a financial planning client chooses to engage us for our Portfolio Management Services. GENERAL INFORMATION Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason upon receipt of written notice. Once having received notice, the agreement shall be deemed canceled at the close of the second business day after receipt of notice. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In the case of a client terminating the agreement within five business days from the date of inception, all fees that have been paid will be refunded. Mutual Fund Fees: All fees paid to Liberty Asset Management, LLC for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should 8  review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Wrap Fee Programs and Separately Managed Account Fees: Clients participating in separately managed account programs may be charged various program fees in addition to the advisory fee charged by our firm. Details about the program and related fees are disclosed once the advisor and client have decided on a program. Such fees may include the investment advisory fees of the independent advisers, which may be charged as part of a wrap fee arrangement. In a wrap fee arrangement, clients pay a single fee for advisory, brokerage and custodial services. Client’s portfolio transactions may be executed without commission charge in a wrap fee arrangement. In evaluating such an arrangement, the client should also consider that, depending upon the level of the wrap fee charged by the broker-dealer, the amount of portfolio activity in the client’s account, and other factors, the wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately. We will review with clients any separate program fees that may be charged to clients. Other Revenue: Management personnel and other related persons of our firm are licensed as registered representatives of a broker-dealer and/or licensed as insurance agents or brokers. In these separate capacity(ies), these individuals are able to implement investment recommendations for advisory clients for separate and typical compensation, such as commissions, 12b-1 fees (trail fees earned from the sale of mutual funds and/or ETFs) or other sales-related forms of compensation. This presents a conflict of interest to the extent that these individuals recommend that a client invest in a security which results in a commission being paid to the individuals. Clients are not under any obligation to engage these individuals when considering implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. Liberty Asset Management, LLC's representatives will at all times to put the interest of the clients first as part of Liberty Asset Management, LLC's fiduciary duty. In some instances, depending on the size of the transaction, advisory fees will be discounted, at our discretion, for commissions earned. Commissions will not be credited towards future advisory fees. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to Liberty Asset Management, LLC's minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our firm's minimum account requirements will differ among clients. ERISA Accounts: Liberty Asset Management, LLC is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), respectively. . As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, Liberty Asset Management, LLC may only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our firm and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset Liberty Asset Management, LLC's advisory fees. 9  Advisory Fees in General: Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $500 more than six months in advance of services rendered. Item 6 Performance-Based Fees and Side-By-Side Management PERFORMANCE-BASED FEES Liberty Asset Management, LLC does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7 Types of Clients Liberty Asset Management, LLC provides advisory services to the following types of clients: Individuals (other than high net worth individuals) High net worth individuals Pension and profit sharing plans(other than plan participants) Charitable organizations Corporations or other businesses not listed above Item 8 Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS We use the following methods of analysis in formulating our investment advice and/or managing client assets: Charting. In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict how long the trend may last and when that trend might reverse. Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement. Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client’s investment goals and risk tolerance. 10  A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client’s goals. Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client’s portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client’s portfolio. Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. INVESTMENT STRATEGIES We use the following strategy(ies) in managing client accounts, provided that such strategy(ies) are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. We purchase securities with the idea of holding them in the client's account for a year or longer. Typically, we employ this strategy when: we believe the securities to be currently undervalued, and/or we want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Risk of Loss. Securities investments are not guaranteed, and you may lose money on your investments. We ask that you work with us to help us understand your tolerance for risk. 11  Item 9 Disciplinary Information We are required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose. Item 10 Other Financial Industry Activities and Affiliations Management personnel and other related persons of our firm are licensed as registered representatives of a broker-dealer and/or licensed as insurance agents or brokers. In these separate capacity(ies), these individuals are able to implement investment recommendations for advisory clients for separate compensation. This presents a conflict of interest to the extent that these individuals recommend that a client invest in a security which results in a commission being paid to the individuals. However, clients are not under any obligation to engage these individuals when considering implementation of advisory recommendations. The implementation of any or all recommendations is solely at the discretion of the client. Liberty Asset Management, LLC endeavors at all times to put the interest of its clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps to address this conflict: we disclose to clients the existence of all material conflicts of interest, including the potential for our firm and our employees to earn compensation from advisory clients in addition to our firm's advisory fees; we disclose to clients that they are not obligated to purchase recommended investment products from our employees or affiliated companies; we collect, maintain and document accurate, complete and relevant client background information, including the client’s financial goals, objectives and risk tolerance; our firm's management conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances; we conduct initial and periodic due diligence on the selected investment advisers to establish that the advisers are suitable to recommend to our clients; and we educate our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. Liberty Asset Management, LLC directs clients to third-party investment advisers and will be compensated via a fee share from the advisers to which it directs those clients. The fees shared will not exceed any limit imposed by any regulatory agency. The portion of the advisory fee paid to us does not increase the total advisory fee paid to the selected investment adviser by the client. This practice creates a conflict of interest in that Liberty Asset Management, LLC has an incentive to direct clients to the third-party investment advisers that provide Liberty Asset Management, LLC with a larger fee split. Liberty Asset Management, LLC will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. Liberty Asset Management, LLC will ensure that all recommended advisers are licensed or notice filed in the states in which Liberty Asset Management, LLC is recommending them to clients. 12  Charles J. Noti is an accountant. From time to time, he may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. Liberty Asset Management, LLC always acts in the best interest of the client and clients always have the right to decide whether or not to utilize the services of any representative of Liberty Asset Management, LLC in such individual’s outside capacities. A. Non Investment-Related Activities Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Liberty Asset Management, LLC and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement and recordkeeping provisions. Liberty Asset Management, LLC's Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to tyopconka@lwmgmt.com, or by calling us at 610 398- 7333. Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell for their personal accounts securities identical to or different from those recommended to our clients. In addition, any related person(s) may have an interest or position in a certain security(ies). However, our firm does not recommended these securities to a clients. We may aggregate our employee trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. In the instances where there is a partial fill of a particular batched order, 13  we will allocate all purchases pro-rata, with each account paying the average price. Our employee accounts will be included in the pro-rata allocation. As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of our firm may put his or her own interest above the interest of an advisory client. 2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless the information is also available to the investing public. 3. Our firm requires prior approval for any IPO or private placement investments by related persons of the firm. 4. We have established procedures for the maintenance of all required books and records. 5. Clients can decline to implement any advice rendered, except in situations where our firm is granted discretionary authority. 6. All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 7. We have established policies requiring the reporting of Code of Ethics violations to our senior management. 8. Any individual who violates any of the above restrictions may be subject to termination. Item 12 Brokerage Practices Custodians/broker-dealers will be recommended based on Liberty Asset Management, LLC’s duty to seek “best execution,” which is the obligation to seek to execute securities transactions for a Client on terms that are the most favorable to the Client under the circumstances. The client will not necessarily pay the lowest commission or commission equivalent, and Liberty Asset Management, LLC may also consider the market expertise and research access provided by the payment of commissions, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers to aid in the research efforts of Liberty Asset Management, LLC. Liberty Asset Management, LLC will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. Liberty Asset Management, LLC uses Fidelity. Liberty Asset Management, LLC does not have any soft-dollar arrangements and does not receive any soft-dollar benefits. Liberty Asset Management, LLC will block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. 14  Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an average share price. Liberty Asset Management, LLC will typically aggregate trades among clients whose accounts can be traded at a given broker. Liberty Asset Management, LLC's block trading policy and procedures are as follows: 1) Transactions for any client account may not be aggregated for execution if the practice is prohibited by or inconsistent with the client's advisory agreement with Liberty Asset Management, LLC, or our firm's order allocation policy. 2) The portfolio manager must reasonably believe that the order aggregation will benefit, and will enable Liberty Asset Management, LLC to seek best execution for each client participating in the aggregated order. This requires a good faith judgment at the time the order is placed for the execution. It does not mean that the determination made in advance of the transaction must always prove to have been correct in the light of a "20-20 hindsight" perspective. Best execution includes the duty to seek the best quality of execution, as well as the best net price. 3) If the order cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated pro rata among the participating client accounts in accordance with the initial order ticket or other written statement of allocation. However, adjustments to this pro rata allocation may be made to participating client accounts in accordance with the initial order ticket or other written statement of allocation. Furthermore, adjustments to this pro rata allocation may be made to avoid having odd amounts of shares held in any client account, or to avoid excessive ticket charges in smaller accounts. 4) Generally, each client that participates in the aggregated order must do so at the average price for all separate transactions made to fill the order, and must share in the commissions on a pro rata basis in proportion to the client's participation. Under the client’s agreement with the custodian/broker, transaction costs may be based on the number of shares traded for each client. 5) If the order will be allocated in a manner other than that stated in the initial statement of allocation, a written explanation of the change must be provided to and approved by the Chief Compliance Officer no later than the morning following the execution of the aggregate trade. 6) Liberty Asset Management, LLC's client account records separately reflect, for each account in which the aggregated transaction occurred, the securities which are held by, and bought and sold for, that account. 7) Funds and securities for aggregated orders are clearly identified on Liberty Asset Management, LLC's records and to the broker-dealers or other intermediaries handling the transactions, by the appropriate account numbers for each participating client. 8) No client or account will be favored over another. Liberty Asset Management, LLC participates in the customer program offered by Fidelity. Fidelity is a registered trademark of FMR LLC an unaffiliated SEC-registered brokerdealer and FINRA member. Fidelity Investments is among the most diversified financial services companies in the world, offering a full range of product solutions for individual investors, 15  employers, institutions and intermediaries. Fidelity’s fundamental mission is to help customers and clients achieve their financial objectives. Fidelity offers retirement planning, portfolio guidance, brokerage services and many other financial products and services. Fidelity is one of the largest staffs of portfolio managers, analysts and traders in the industry, and manage hundreds of mutual funds and institutional strategies, encompassing virtually every investment class and category. Fidelity is a leading provider of clearing, custody, brokerage, and investment service to independent advisors, broker- dealers, family offices, and institutions. Some of the products and services made available by Fidelity through the program may benefit Liberty Asset Management, LLC but may not benefit our client accounts. These products or services may assist us in managing and administering client accounts, including accounts not maintained at Fidelity. Other services made available by Fidelity are intended to help us manage and further develop our business enterprise. The benefits received by Liberty Asset Management, LLC, or our personnel through participation in the program do not depend on the amount of brokerage transactions directed to Fidelity. Clients should be aware, however, that the receipt of economic benefits by Liberty Asset Management, LLC or our related persons in and of itself creates a potential conflict of interest and may indirectly influence our choice of Fidelity for custody and brokerage services. Clients invested in wrap fee programs have directed brokerage to their wrap sponsor- broker. Clients should be aware that important disclosures regarding trading and brokerage practices are contained in the brochure of the wrap manager and wrap program sponsors. Item 13 Review of Accounts INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed at least quarterly. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. Liberty Asset Management, LLC has adopted a detailed process for maintaining record of analysis of our investment management process. These accounts are reviewed by: Asset Allocation: Rick Frable FINANCIAL PLANNING SERVICES REVIEWS: While reviews may occur at different stages depending on the nature and terms of the specific engagement, typically no formal reviews will be conducted for Financial Planning clients unless otherwise contracted for. Financial Planning clients will receive a completed financial plan. 16  Item 14 Client Referrals and Other Compensation LAM does not receive any economic benefit, directly or indirectly from any third party for advice rendered to LAM clients. LAM does not compensate non-advisory personnel (solicitors) for client referrals. Item 15 Custody We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. As part of this billing process Liberty Asset Management uses Albridge, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. Our firm does not have actual custody of client accounts. Item 16 Investment Discretion Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: determine the security to buy or sell; and/or determine the amount of the security to buy or sell Clients give us discretionary authority when they sign a discretionary agreement with our firm, and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. Item 17 Voting Client Securities As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm may provide investment advisory services relative to client investment assets, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets, to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. 17  We do not offer any consulting assistance regarding proxy issues to clients. However, Liberty Asset Management, LLC may, only at the client’s request, offer clients advice regarding the exercise of proxy voting rights. Item 18 Financial Information Under no circumstances do we require or solicit payment of fees in excess of $1,200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. Liberty Asset Management, LLC has not been the subject of a bankruptcy petition at any time during the past ten years. 18