Overview

Assets Under Management: $1.1 billion
Headquarters: PALM BEACH GARDENS, FL
High-Net-Worth Clients: 165
Average Client Assets: $6 million

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Pension Consulting

Fee Structure

Primary Fee Schedule (LRI INVESTMENTS, LLC DISCLOSURE BROCHURE)

MinMaxMarginal Fee Rate
$0 and above 2.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $20,000 2.00%
$5 million $100,000 2.00%
$10 million $200,000 2.00%
$50 million $1,000,000 2.00%
$100 million $2,000,000 2.00%

Clients

Number of High-Net-Worth Clients: 165
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 76.38
Average High-Net-Worth Client Assets: $6 million
Total Client Accounts: 1,250
Discretionary Accounts: 1,250

Regulatory Filings

CRD Number: 323556
Last Filing Date: 2025-02-13 00:00:00
Website: https://linrip.com

Form ADV Documents

Additional Brochure: LRI INVESTMENTS, LLC DISCLOSURE BROCHURE (2025-08-15)

View Document Text
Form ADV Part 2A - FIRM Disclosure Brochure ADV2A_LRI (08/13/2025) Item 1 – Cover Page Registered As: LRI Investments, LLC | CRD No. 323556 3825 PGA Blvd., Suite 303 Palm Beach Gardens, FL 33410 Phone: (561) 323-2265 Fax: (860) 761-9791 www.linrip.com August 13, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of LRI Investments, LLC (“the firm”). If you have any questions about the contents of this Disclosure Brochure, please contact us at (860) 257-5791 or by email at info@linrip.com. The information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission (“SEC”) or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about the firm to assist you in determining whether to retain the firm. Additional information about LRI Investments, LLC is available on the SEC’s website at www.adviserinfo.sec.gov by searching our CRD number 323556. Page 1 of 29 ADV2A_LRI (08/13/2025) Item 2 – Material Changes Annually, a complete Disclosure Brochure will be offered to Clients along with a summary of material changes, if any, within 120 days from the firm’s fiscal year-end. At any time, the current Disclosure Brochure is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching the firm name or CRD number 311892. A copy of this Disclosure Brochure may be requested at any time, by contacting (561) 323-2265 or by email at info@linrip.com. Material Changes: As of January 1st, 2025 the ownership structure of LRI Investments, LLC has changed. 70% is owned by SP Investments Squared, LLC and 30% is owned by JKJ LRII Equity Partners, LLC. Please refer to Item 4 – Advisory Business for additional details. - Remainder of page intentionally left blank - Page 2 of 29 ADV2A_LRI (08/13/2025) Item 3 – Table of Contents Item 1 – Cover Page ............................................................................................................................................................................................. 1 Item 2 – Material Changes…………………………………………………………………………………………………………………………………………………………2 Item 3 – Table of Contents ............................................................................................................................................................................. 3 Item 4 – Advisory Business ......................................................................................................................................................................... 4 Item 5 – Fees and Compensation ........................................................................................................................................................... 12 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................................... 13 Item 7 – Types of Clients ............................................................................................................................................................................... 13 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................... 14 Item 9 – Disciplinary Information............................................................................................................................................................ 18 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................................... 18 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................. 18 Item 12 – Brokerage Practices ................................................................................................................................................................... 19 Item 13 – Review of Accounts ................................................................................................................................................................... 20 Item 14 – Client Referrals and Other Compensation ................................................................................................................. 20 Item 15 – Custody ............................................................................................................................................................................................... 21 Item 16 – Investment Discretion .............................................................................................................................................................. 21 Item 17 – Voting Client Securities............................................................................................................................................................ 21 Item 18 – Financial Information ................................................................................................................................................................ 21 Appendix 1 - Wrap Fee Program Brochure...……………………………………..………………………………………………..…………………………..22 Privacy Policy………………………………………………………………………………………………………………………………...…………………………………………….27 Page 3 of 29 ADV2A_LRI (08/13/2025) Item 4 – Advisory Business Firm Information The firm was organized as a Florida member managed LLC in 2022 and subsequently registered as an investment advisor with the SEC. Principal Owners SP Investments Squared, LLC (70% Owner) Indirect Owners in Control Position Anthony T. Pace, CFP®, CLU, ChFC – Managing Member (31.5% Owner) Mr. Pace serves as a managing member with over 30 years of industry experience. He also runs the company’s Investment Management division. Anthony has authored articles for the Boston Business Journal and Providence Business Journal on various investment topics, hosted WPRO Money PRO talk show in Providence, RI, and was named one of the Hartford Business Journal’s “40 under Forty.” He is on the Board of Directors for The Entrepreneurs Organization of South Florida, the Program Committee Chair of the Palm Beach Estate Planning Council and a member of the Palm Beach Tax Institute. He is past president of both the Financial Planning Association of Connecticut Valley, and Hartford Association of Insurance and Financial Advisors. Anthony has served on the WSAC and its predecessor, the M Holdings Securities Advisory Committee. Carl J. Peterson – Managing Member (31.5% Owner) Mr. Peterson serves as a managing member of the RIA with over 30 years of industry experience. He started in the life insurance business after graduation from University of New Hampshire with a BA in Economics. He also serves on the Board of Directors for M Financial Securities, Inc, M Life Insurance Company and the Association for Advanced Life Underwriting (AALU). Nancy L. Shepard, CFP® – Managing Member & Chief Operating Officer (31.5% Owner) Ms. Shepard manages the day to day operations of the firm. She graduated from Marist College and has almost 30 year of industry experience Hayley A. Snell – Chief Compliance Officer (5.5% Owner) Ms. Snell serves as the Chief Compliance Officer and is a graduate of the University of Connecticut. JKJ LRII Equity Partners, LLC (30% Owner) Page 4 of 29 ADV2A_LRI (08/13/2025) Advisory Services Offered LRI Investments, LLC provides financial planning and fee-based investment advisory services primarily to individual Clients and high-net worth individuals. Services are also available to businesses and financial institutions. Accounts are managed based on the individual goals, objectives, time horizon, and risk tolerance of each Client. Advisory services include, but are not limited to, the following: Financial Planning Investment Management Insurance • Retirement • College • Estate • Cash Flow & Budgeting • • Diversified Portfolio • Retirement Accounts • Automatic Rebalancing • Stock Option Planning • Tax Planning • Pension Analysis Investment Advisor Representatives are restricted to providing services and charging fees based in accordance with the descriptions detailed in this document and the account agreement. However, the exact service and fees charged to a particular Client are dependent upon the Investment Advisor Representatives that are working with the Client. Investment Advisor Representatives will consider the individual needs of each Client when providing investment advice. Investment strategies and recommendations are tailored to the individual needs of each Client but generally consist of an asset allocation consistent with: 1. Income with Capital Preservation. Designed as a longer-term accumulation account, this investment objective is considered generally the most conservative. Emphasis is placed on generation of current income with minimal risk of capital loss. Lowering the risk generally means lowering the potential income and overall return. 2. Income with Moderate Growth. This investment objective emphasizes generation of current income with a secondary focus on moderate capital growth. 3. Growth with Income. This investment objective emphasizes modest capital growth with some focus on generation of current income. 4. Growth. This investment objective emphasizes achieving high long-term growth and capital appreciation. There is little focus on generation of current income. 5. Aggressive Growth. This investment objective emphasizes aggressive growth and maximum capital appreciation, with no focus on generation of current income. This objective has a very high level of risk and is for investors with a longer timer horizon. At no time will LRI Investments, LLC accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated brokerage account or pension account, pursuant to the Client investment advisory agreement on a discretionary or non-discretionary basis. Investment advice is not limited to certain investment types. • • A minimum total investment amount of $250,000 is generally required but, a lesser amount will be considered. Page 5 of 29 ADV2A_LRI (08/13/2025) • Advisory services are tailored to the individual need of each Client. • Clients may place reasonable restrictions on investing in certain types of securities. Asset Management Services LRI Investments, LLC provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. Our Investment Management Services encompasses asset management as well as providing financial planning and financial consulting to Clients. It is designed to assist Clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone conference) with Clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the Client. We generally propose an investment portfolio, that consists primarily of exchange traded equity securities, exchange traded funds, mutual funds (Please see Item 8 for a more comprehensive list of available investment types). Upon the Client’s agreement to the proposed investment plan, we work with the Client to establish or transfer investment accounts so that we can manage the Client’s investment portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust Client accounts under our management. If the Client experiences any significant changes to his/her financial or personal circumstances, the Client must notify us so that we can consider such information in managing the Client’s investments. Investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. LRI Investments, LLC will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. LRI Investments, LLC may recommend, on occasion, redistributing investment allocations to diversify the portfolio. LRI Investments, LLC may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. LRI Investments, LLC may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will LRI Investments, LLC accept or maintain custody of a Client’s funds or securities, except for authorized deduction of the Advisor’s fees. All Client assets will be managed within their designated account[s] at the Custodian, pursuant to the Client investment advisory agreement. Financial Planning Services We provide a variety of financial planning and consulting services to individuals, families and other Clients regarding the management of their financial resources based upon an analysis of the Client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for Clients based on the Client’s Page 6 of 29 ADV2A_LRI (08/13/2025) financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning • • Corporate Structure • Retirement Planning • Real Estate Analysis • Estate Planning • Mortgage/Debt Analysis • Charitable Planning Insurance Analysis • • Education Planning • Lines of Credit Evaluation • Corporate and Personal Tax Planning • Divorce Planning • Cost Segregation Study • Business and Personal Financial Planning • Stock Options Analysis Our financial plans usually include general recommendations for a course of action or specific actions to be taken by the Client. For example, recommendations can be made that the Clients begin or revise investment programs, create or revise wills or trusts, obtain or revise insurance coverage, commence or alter retirement savings, or establish education or charitable giving programs. For written financial planning engagements, we provide our Clients with a written summary of their financial situation, observations, and recommendations. For financial consulting engagements, we usually do not provide our Clients with a written summary of our observations and recommendations as the process is less formal than our planning service. • For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Implementation of the recommendations will be at the discretion of the Client. • LRI Investments, LLC may also refer Clients to an accountant, attorney or another specialists, as appropriate for their unique situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. Financial planning and consulting recommendations may pose a conflict between the interests of the Advisor and the interests of the Client. For example, a recommendation to engage the Advisor for investment management services or to increase the level of investment assets with the Advisor would pose a conflict, as it would increase the advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to execute the transaction through the Advisor. Retirement Plan Consulting Services Investment Advisor Representatives assist Clients that are trustees or other fiduciaries to retirement plans (“Plans”) by providing fee-based consulting and/or non-discretionary advisory services. Investment Advisor Representatives perform one or more of the following services, as selected by the Client in the Client agreement: Page 7 of 29 ADV2A_LRI (08/13/2025) • Acting as a liaison between the Plan and service providers, product sponsors or vendors. • Ongoing monitoring of investment manager(s) or investments in relation to written guidelines provided by the Client to the Investment Advisor Representative. • Preparation of reports describing the performance of Plan investment manager(s) or investments, as well as comparing the performance to benchmarks. • Ongoing recommendations for consideration and selection by Client about specific investments to be held by the Plan or, in the case of a participant-directed defined contribution plan, to be made available as investment options under the Plan. • Training for the members of the Plan Committee with regard to their service on the Committee, including education and consulting with respect to fiduciary responsibilities. • Assistance in enrolling Plan participants in the Plan, including conducting an agreed upon number of enrollment meetings. As part of such meetings, Representatives may provide participants with information about the Plan, which includes information on the benefits of Plan participation, the benefits of increasing Plan contributions, the impact of pre-retirement withdrawals on retirement income, the terms of the Plan and the operation of the Plan. • Assistance with investment education seminars and meetings for Plan participants. Such meetings may be on a group or individual basis, and includes information about the investment options under the Plan (e.g., investment objectives, risk/return characteristics, and historical performance), investment concepts (e.g., diversification, asset classes, and risk and return), and how to determine investment time horizons and assess risk tolerance. Such meetings can include specific investment advice about investment options under the Plan as being appropriate for a particular participant. • Assistance at Client’s direction in making changes to investment options under the Plan. • Assistance with the preparation, distribution and evaluation of Request for Proposals, finalist interviews, and conversion support in connection with vendor analysis and service provider support. • Preparation of comparisons of Plan data (e.g., regarding fees and services and participant enrollment and contributions) to data from the Plan’s prior years and/or a benchmark group of similar plans. • Assistance in identifying the fees and other costs borne by the Plan for, as specified by Client, investment management, record keeping, participant education, participant communication and/or other services provided with respect to the Plan. Page 8 of 29 ADV2A_LRI (08/13/2025) If the Plan makes available publicly traded employer stock (“company stock”) as an investment option under the Plan, Investment Advisor Representatives do not provide investment advice regarding company stock and are not responsible for the decision to offer company stock as an investment option. In addition, if participants in the Plan invest the assets in their accounts through individual brokerage accounts, a mutual fund window, or other similar arrangement, or obtain participant loans, Investment Advisor Representatives do not provide any individualized advice or recommendations to the participants regarding these decisions. If a Client elects to engage the firm and our Investment Advisor Representatives to perform ongoing investment monitoring and ongoing investment recommendation services in the Client agreement, such services will constitute “investment advice” under Section 3(21)(A)(ii) of ERISA. Therefore, the firm and our Investment Advisor Representative will be deemed a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of ERISA in connection with those services. ERISA Fiduciary Services provided by an Investment Advisor Representative may be subject to the Investment Advisers Act of 1940 (“Advisers Act”), and the advisor is a fiduciary under the Advisers Act with respect to such services. If a Client elects to engage an Investment Advisor Representative to perform ongoing investment monitoring and ongoing investment recommendation services to a Plan subject to ERISA in the Client agreement, such services will constitute “investment advice” under Section 3(21)(A)(ii) of ERISA. Therefore, the Investment Advisor Representatives will be deemed a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of ERISA in connection with those services. Clients should understand that to the extent the Investment Advisor Representative is engaged to perform services other than ongoing investment monitoring and recommendations, those services are not “investment advice” under ERISA and therefore, the Investment Advisor Representative will not be a “fiduciary” under ERISA with respect to those other services. From time to time the Investment Advisor Representative may make the Plan or Plan participants aware of other services available that are separate and apart from the services provided under Retirement Plan Consulting. Such other services may be services to the Plan, to a Client with respect to Client's responsibilities to the Plan and/or to one or more Plan participants. In offering any such services, the Investment Advisor Representative is not acting as a fiduciary under ERISA with respect to such offering of services. If any such separate services are offered to a Client, the Client will make an independent assessment of such services without reliance on the advice or judgment of the Investment Advisor Representative. Retirement Plan Rollovers An employee generally has four (4) options for their retirement plan when they leave an employer: 1. Leave the money in his/her former employer’s plan, if permitted 2. Rollover the assets to his/her new employer’s plan if one is available and permitted 3. Rollover to an Individual Retirement Account (IRA), or 4. Cash out the account value, which has significant tax considerations Each of these options has advantages and disadvantages and before making a change we encourage you to speak with your CPA and/or tax attorney. If you are considering rolling over your retirement funds to an IRA for us to manage here are a few points to consider before you do so: • Determine whether the investment options in your employer's retirement plan address your needs or whether you might want to consider other types of investments. Page 9 of 29 ADV2A_LRI (08/13/2025) • Employer retirement plans generally have a more limited investment menu than IRAs. • Employer retirement plans may have unique investment options not available to the public such as employer securities, or previously closed funds. • Your current plan may have lower fees than our fees. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset- based fee as set forth in the agreement you executed with our firm. This practice presents a conflict of interest because Investment Advisor Representatives have an incentive to recommend a rollover to you for the purpose of generating fee-based compensation rather than solely based on your needs. You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of each. An employee will typically be investing only in mutual funds, you should understand the cost structure of the share classes, available in your employer's retirement plan and how the costs of those share classes compare with those available in an IRA. Clients should understand the various products and services they might take advantage of at an IRA provider and the potential costs of those products and services. • Our strategy may have higher risk than the option(s) provided to you in your plan. • Your current plan may also offer financial advice. • If you keep your assets titled in a 401k or retirement account, participants could potentially delay their required minimum distribution beyond age 70½. • A 401(k) may offer more liability protection than a rollover IRA; each state may vary. • Participants may be able to take out a loan on your 401k, but not from an IRA. • IRA assets can be accessed any time; however, distributions are subject to ordinary income tax and may also be subject to a 10% early distribution penalty unless they qualify for an exception such as disability, higher education expenses or the purchase of a home. • If company stock is owned in a plan, participants may be able to liquidate those shares at a lower capital gains tax rate. • Plans may allow Advisor to be hired as the manager and keep the assets titled in the plan name. Generally, federal law protects assets in qualified plans from creditors. Since 2005, IRA assets have been generally protected from creditors in bankruptcies. However, there can be some exceptions to the general rules so you should consult with an attorney if you are concerned about protecting your retirement plan assets from creditors. Page 10 of 29 ADV2A_LRI (08/13/2025) It is important to understand the differences between these types of accounts and to decide whether a rollover is the best option. Prior to proceeding, if you have questions contact your Investment Adviser Representative, or call our main number as listed on the cover page of this brochure. LRI Investments, LLC has special and additional fiduciary responsibilities under the Employee Retirement Income Security Act of 1974 (“ERISA1”) and the Internal Revenue Code Section 4975 (“IRC 4975”). As a fiduciary2 and party-in-interest3 to a Retirement Investor4, Advisor must conform to certain standards of conduct, including compliance with any applicable prohibited transaction rules and prohibited transaction exemptions (PTE’s) governing its relationship when providing fiduciary advice to a Retirement Investor. When LRI Investments, LLC provides investment advice regarding a retirement plan account or individual retirement account, the firm is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (ERISA) and/or the Internal Revenue Code (IRS), as applicable, which are laws governing retirement accounts. The way LRI Investments, LLC make money creates a conflict of interests, so the firm operates under a special rule that requires acting in a Client’s best interest and not put the firm’s interest ahead of a Client. Under this special rule’s provisions, LRI Investments, LLC must meet a professional standard of care when making investment recommendations (give prudent advice); never put the firm’s financial interests ahead of a Client when making recommendations (give loyal advice); avoid misleading statements about conflicts of interest, fees, and investments; follow policies and procedures designed to ensure that LRI Investments, LLC gives advice that is in a Client’s best interest; charge no more than is reasonable for services; and disclose the conflicts of interest. LRI Investments, LLC can alternatively provide educational services pertaining to retirement plan assets that could potentially be rolled-over to an IRA managed by the firm. Education is based on a particular Client’s financial circumstances. LRI Investments, LLC has an incentive to recommend a rollover based on the compensation received, which is mitigated by the fiduciary duty to act in a Client’s best interest and acting accordingly. Client Account Management Prior to engaging LRI Investments, LLC to provide investment advisory services, each Client is required to enter into an investment advisory agreement with that defines the terms, conditions, authority, and responsibilities. 1 ERISA is the comprehensive federal statute that governs the operation and administration of private pension and welfare benefits plans. The Department of Labor (“DOL”), and the Pension Benefit Guaranty Corporation (“PBGC”) are responsible for the interpretation and enforcement of ERISA. For solo-participant plans (such as Individual Retirement Accounts) the DOL has rulemaking authority, however, enforcement jurisdiction resides with the Internal Revenue Service. 2 Fiduciary: On December 15, 2020 the DOL issued its “final interpretation” of the five-part test under its 1975 regulation defining who is a fiduciary under ERISA, and they withdrew the Deseret Advisory Opinion (2005-23A). The final interpretation broadens the scope of who is an ERISA fiduciary such that recommendations to rollover qualified plans trigger the functional definition of an ERISA fiduciary. By virtue of Presidential Order Reorganization Plan No. 4 in 1978, the change to ERISA is mirrored in the IRC and thus also impacts IRAs. The final interpretation became effective on February 24, 2021 with an enforcement date of December 10, 2021. 3 Party-in-Interest: (This term is unique to ERISA. For the equivalent under the Internal Revenue Code see “disqualified person” above.) A person affiliated with the plan that is: any fiduciary to a plan; any person providing services to the plan; the employer whose Associated Persons are covered by the plan; an employee organization whose members are covered by the plan; a 50%, or more, owner of such employer; a spouse, ancestor, lineal descendent, or spouse of a lineal descendent of any of the persons above except an employee organization; a corporation, partnership, trust or estate of which 50% is owned directly or indirectly by persons above other than relations; an employee, officer, director or 10% or more, shareholder of any persons mentioned above, except a fiduciary or relative; and/or a 10% or more, partner or joint venture of any person above except a fiduciary or relative. 4 Retirement Investor: The definition of a “retirement investor” includes participants and beneficiaries of an ERISA plan, owners of solo-participant plans such as IRAs, and fiduciaries to a solo-participant or ERISA plan such as plan fiduciaries. The definition also includes Health Savings Accounts (“HSAs”), Medical Savings Accounts (“MSAs”) and Coverdell Education Savings Accounts (“Educational IRAs”). Page 11 of 29 ADV2A_LRI (08/13/2025) Held Away Accounts (Pontera Solutions Inc.) LRI Investments, LLC provides an additional service for accounts not directly held by our custody but where we do have discretion and can leverage an Order Management System[1] to implement portfolio strategy changes and opportunistic rebalancing strategies on behalf of the client. These are primarily 401(k) accounts and other assets we do not custody. We regularly review the available investment options in these accounts: implementing portfolio adjustments & rebalances as necessary. While managing employee retirement plan assets through an order management system, LRI Investments, LLC is confined to the guidelines and limitations of the employer plan. Assets Under Management Assets under management will be amended at least annually as of December 31st. Assets under Management Discretionary Total Non-Discretionary $1,132,278,720.00 $1,132,278,720.00 $0.00 Item 5 – Fees and Compensation Investment Management Fees are typically paid quarterly in advance (based on quarter end value and number of days in the quarter) or quarterly in arrears (based upon average daily value of 365 days), as selected on the client services agreement. Fees and will generally not exceed 2% of assets under management unless the scope, complexity, amount of time or expertise required warrant a higher fee. The fee is deducted based on a separate written authorization between the custodian and the Client. • Clients will receive quarterly statements from the Custodian that provides details of the advisory fees. • The investment advisory fee in the first period of service is pro-rated from the inception date of the account[s] to the end of the first quarter. • If the advisory agreement is terminated before the end of the quarterly period, Client is entitled to a pro-rated refund of any pre-paid quarterly advisory fee based on the number of days remaining in the quarter after the termination date. • Asset management fees are exclusive of and in addition to, brokerage fees, transaction fees, and other related costs and expenses. The firm will not have the authority or responsibility to value portfolio securities. • [1] https://pontera.com Page 12 of 29 ADV2A_LRI (08/13/2025) Financial Planning The fee for financial planning can be based on an hourly or a fixed rate depending on the nature of the planning. Fixed fees are generally paid 100% in advance or in equal monthly payments. Hourly fees are generally charged as they incur. • Hourly Fee: $150 to $350 • Fixed Fee: $650 to $2,500 The applicable fee is determined by the scope and complexity of a particular Client’s financial situation as well as the amount of time and expertise required. In some cases, a fee greater or lesser then the typical fee range may be warranted. Mutual Fund Share Class Disclosures LRI Investments, LLC strives to select the lowest cost share class available; however, certain mutual fund share classes charge a 12b-1 fee that generally amounts to an additional .25% expense ratio or more. The purpose of 12b-1 fees, as approved by the SEC, are to cover marketing expenses and shareholder services such as support services and “other expenses” such as legal, accounting and the administrative functions of the custodian. When selecting a mutual fund, Investment Advisor Representatives have a fiduciary duty to choose the share class that helps manage the overall fee structure of the account. The entire fee structure includes such fees as the asset management fee, the expense ratio and ticket charges. • Mutual funds typically offer multiple share classes, including lower-cost share classes that do not charge 12b-1 fees and are therefore usually less expensive. • Investment Advisor Representatives will consider investing Client funds in 12b-1 fee-paying share classes even when a lower-cost share class is available as appropriate to account for the overall fee structure and tax considerations as well as attributes of a fund not available for lesser fees. Discretionary Participant Account Management Fees are determined by the account value at the end of the previous quarter and billed to a Client’s taxable account or directly to the Client. Accounts initiated or terminated during a calendar quarter will be charged a pro-rated fee based on the amount of time remaining in the billing period. An account may be terminated with written notice at least 15 calendar days in advance. Compensation for Sales of Securities LRI Investments, LLC does not receive commission compensation for advisory services. Other Fees and Expenses Clients will pay the following separately incurred expenses, which we do not receive any part of: charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees and other fund expenses). If a Client’s assets are invested in mutual funds or other pooled investment products, Clients should be aware that there will be two layers of advisory fees and expenses for those assets. Client will pay an advisory fee to the fund manager and other expenses as a shareholder of the fund. Client will also pay Advisor the advisory fee with respect to those assets. Most of the mutual funds available in the program may Page 13 of 29 ADV2A_LRI (08/13/2025) be purchased directly. Therefore, Clients could generally avoid the second layer of fees by not using the management services of LRI Investments, LLC and by making their own investment decisions. Further information regarding fees assessed by a mutual fund is available in the appropriate prospectus. Termination A contract between LRI Investments, LLC and a Client may be cancelled at any time with thirty (30) days prior written notice. Clients will be given this brochure form ADV Part 2A, forty-eight hours in advance of signing an agreement or they will have five business days to unconditionally cancel the agreement. Item 6 – Performance-Based Fees and Side-By-Side Management LRI Investments, LLC does not accept performance-based fees, fees based on a share of capital gains on or capital appreciation of the assets of a Client (such as a Client that is a hedge fund or other pooled investment vehicle). LRI Investments, LLC also does not participate in side-by-side management, where an advisor manages accounts that are both charged a performance-based fee and accounts that are charged another type of fee, such as an hourly or flat fee or an asset-based fee. Item 7 – Types of Clients The advisory services offered by LRI Investments, LLC are available for individuals, high net worth individuals, individual retirement accounts (“IRAs”), banks and thrift institutions, pension and profit- sharing plans, including plans subject to Employee Retirement Income Security Act of 1974 (“ERISA”), trusts, estates, charitable organizations, state and municipal government entities, corporations and other business entities. Page 14 of 29 ADV2A_LRI (08/13/2025) Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss LRI Investments, LLC emphasizes continuous and regular account supervision. As part of our asset management service, we generally create a portfolio, consisting of individual stocks or bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The Client’s individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Each portfolio will be initially designed to meet a particular investment goal, which we determine to be suitable to the Client’s circumstances. Once the appropriate portfolio has been determined, it is subject to review and if necessary, rebalanced based upon the Client’s individual needs, stated goals and objectives. Each Client can place reasonable restrictions on the types of investments to be held in the portfolio. LRI Investments, LLC uses multiple forms of research to analyze financial data and market conditions such as the general financial health of a company, and/or the analysis of management or competitive advantages, past market data (primarily price and volume), business cycles as well as patterns and trends. LRI Investments, LLC will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, LRI Investments, LLC will buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. Risk of Loss Investing in securities involves certain investment risks. Securities can fluctuate in value or lose value up to the entire principal amount invested. Clients should be prepared to bear the potential risk of loss. LRI Investments, LLC will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. Investment Advisor Representatives monitor economic indicators to determine if adjustments to strategic allocations are appropriate. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account. The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. The firms’ methods of analysis and investment strategies do not represent any significant or unusual risks however all strategies have inherent risks and performance limitations. Clients should be aware of the following types of risks that apply to investing and are encouraged to discuss the specific risks applicable to their account holdings: Page 15 of 29 ADV2A_LRI (08/13/2025) the measure of risk associated with a particular security. It is also known as • Business Risk – unsystematic risk and refers to the risk associated with a specific issuer of a security. Generally speaking, all businesses in the same industry have similar types of business risk. More specifically, business risk refers to the possibility that the issuer of a particular company stock or a bond may go bankrupt or be unable to pay the interest or principal in the case of bonds. • Call Risk – the risk specific to bond issues and refers to the possibility that a debt security will be called prior to maturity. Call risk usually goes hand in hand with reinvestment risk because the bondholder must find an investment that provides the same level of income for equal risk. Call risk is most prevalent when interest rates are falling, as companies trying to save money will usually redeem bond issues with higher coupons and replace them on the bond market with issues with lower interest rates. • Credit Risk – the risk that an investor could lose money if the issuer or guarantor of a fixed income security is unable or unwilling to meet its financial obligations. • Currency/Exchange Rate Risk – the risk of a change in the price of one currency against another. • ETF Risks, including Net Asset Valuations and Tracking Error - ETF performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depositary Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. An ETF typically includes embedded expenses and related fees that reduce the fund's net asset value, and therefore directly affect the fund's performance and indirectly affect a Program Account’s performance or an index benchmark comparison. Expenses of an ETF generally include investment adviser management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses can change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses can vary. • Extraordinary Events – Terrorism and the United States’ involvement in armed conflict may negatively affect general economic fortunes, including sales, profits, and production. An unstable geopolitical climate and continued threats of terrorism and war could have a material effect on general economic conditions, market conditions, and market liquidity (i.e., depressed securities prices and problems with trading facilities and infrastructure). Additionally, a serious pandemic or natural disaster could severely disrupt the global, national, and/or regional economies. A resulting negative impact on economic fundamentals and consumer confidence may increase the risk of default of particular companies and negatively impact our clients. • Inflationary Risk – the risk that future inflation will cause the purchasing power of cash flow from an investment to decline. • Interest Rate Risk – the risk that fixed income securities will decline in value because of an increase in interest rates; a bond or a fixed income fund with a longer duration will be more sensitive to changes in interest rates than a bond or bond fund with a shorter duration. Page 16 of 29 ADV2A_LRI (08/13/2025) • Legislative Risk – the risk of a legislative ruling resulting in adverse consequences. • Liquidity Risk – the possibility that an investor may not be able to buy or sell an investment as and when desired or in sufficient quantities because opportunities are limited. • Market Risk – the risk that the value of securities may go up or down, sometimes rapidly or unpredictably, due to factors affecting securities markets generally or particular industries. • Mutual Fund Risks – A risk exists that the investment strategies employed by the mutual funds will not meet the stated investment objectives the fund is seeking to obtain. Mutual funds may invest in equities, fixed income, derivatives, and other asset classes; the risks associated with such investments are described in the fund’s prospectus. The performance of a mutual fund may not exactly match the performance of the index or market benchmark that the fund is designed to track due to the mutual fund incurring expenses and transaction costs not incurred by any applicable index or market benchmark. Expenses can change from time to time at the sole discretion of the issuer and expenses can vary. • Pandemic Risk – Large-scale outbreaks of infectious disease that can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. • Reinvestment Risk – the risk that falling interest rates will lead to a decline in cash flow from an investment when its principal and interest payments are reinvested at lower rates. • Social/Political – the possibility of nationalization, unfavorable government action or social changes resulting in a loss of value. • Taxability Risk – the risk that a security that was issued with tax-exempt status could potentially lose that status prior to maturity. Since municipal bonds carry a lower interest rate than fully taxable bonds, the bond holders would end up with a lower after-tax yield than originally planned. All investments involve varying degrees of risk, and it should not be assumed that future performance of any specific investment or investment strategy will be profitable or equal any specific performance level(s). Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Types of Investments LRI Investments, LLC generally manages Client portfolios that consist of mutual funds, Exchange Traded Equities (ETFs) and individual securities. • Mutual Funds – a pool of funds collected from many investors for the purpose of investing in securities such as stocks, bonds, money market instruments and similar assets. o Open-End Mutual Funds – a type of mutual fund that does not have restrictions on the amount of shares the fund will issue and will buy back shares when investors wish to sell. Investing in mutual funds carries the risk of capital loss and thus Clients may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Page 17 of 29 ADV2A_LRI (08/13/2025) o Closed-End Mutual Funds – a type of mutual fund that raises a fixed amount of capital through an initial public offering (IPO). The fund is then structured, listed, and traded like a stock on a stock exchange. Clients should be aware that closed-end funds available within the program are not readily marketable. In an effort to provide invest or liquidity, the funds may offer to repurchase a certain percentage of shares at net asset value on a periodic basis. Thus, Clients may be unable to liquidate all or a portion of their shares in these types of funds. o Alternative Strategy Mutual Funds – Certain mutual funds available in the program invest primarily in alternative investments and/or strategies. Investing in alternative investments and/or strategies may not be suitable for all investors and involves special risks, such as risks associated with commodities, real estate, leverage, selling securities short, the use of derivatives, potential adverse market forces, regulatory changes and potential illiquidity. There are special risks associated with mutual funds that invest principally in real estate securities, such as sensitivity to changes in real estate values and interest rates and price volatility because of the fund’s concentration in the real estate industry. • Equity – An investment that generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environment. • Exchange Traded Funds (ETFs) – An ETF is a portfolio of securities invested to track a market index similar to an index mutual fund, but the shares are traded on an exchange like an equity. An ETF share price fluctuates intraday depending on market conditions instead of having a net asset value (NAV) that is calculated once at the end of the day. The shares may trade at a premium or discount; and as a result, investors pay more or less when purchasing shares and receive more or less than when selling shares. The supply of ETF shares is regulated through a mechanism known as creation and redemption that involves large specialized investors, known as authorized participants (APs). Authorized participants are large financial institutions with a high degree of buying power, such as market makers, banks or investment companies that provide market liquidity. When there is a shortage of shares in the market, the authorized participant creates more (creation). Conversely, the authorized participant will reduce shares in circulation (redemption) when supply falls short of demand. Multiple authorized participants help improve the liquidity of a particular ETF and stabilize the share price. To the extent that authorized participants cannot or are otherwise unwilling to engage in creation and redemption transactions, shares of an ETF tend to trade at a significant discount or premium and may face trading halts and delisting from the exchange. The performance of ETFs is subject to market risk, including the complete loss of principal. ETFs also have a trading risk based on cost inefficiency if the ETFs are actively traded and a liquidity risk if the ETFs has a large price spread and low trading volume. In addition, investors buying or selling shares in the secondary market pay brokerage commissions, which may be a significant proportional cost not incurred by mutual funds. Additional types of investments will be considered per Client for asset allocation and risk management purposes. Page 18 of 29 ADV2A_LRI (08/13/2025) Item 9 – Disciplinary Information There are no material legal, regulatory, or disciplinary events involving LRI Investments, LLC or any of its Supervised Persons that are required to be disclosed. However, an administrative penalty was paid to the state of Florida for an oversight related to a filing requirement. Additional information is available on the Investment Advisor Public Disclosure website by searching CRD Number: 2115209. Item 10 – Other Financial Industry Activities and Affiliations Broker-Dealer Affiliation Certain Advisory Persons are also a registered representative of M Holdings Securities, Inc, a registered broker-dealer (CRD No. 43285), member FINRA/SIPC. In their separate capacity as a registered representative, commissions compensation is received for executing securities transactions. Clients are not obligated to implement any recommendation provided by such Advisory Persons. Insurance Agency Affiliations Certain Advisory Persons are also a licensed insurance professional. Implementations of insurance recommendations are separate and apart from one’s role with LRI Investments, LLC. As an insurance professional, certain Advisory Persons receive customary commissions and other related revenues from the various insurance companies whose products are sold. Commissions generated by insurance sales do not offset regular advisory fees. This causes a conflict of interest in recommending certain products of the insurance companies. Clients are under no obligation to implement any recommendations made by the Investment Advisor Representative in their capacity as an insurance agent. This chart is intended to explain the potential capacity a Financial Advisor can serve, and the type of compensation received. Capacity Compensation Investment Advisor Representatives Registered Representative Advisory Fee Commissions Insurance Agent Commissions Conflicts of interests exist because securities and insurance sales create an incentive to recommend products based on the compensation earned rather than the best interests of the Client. Such potential conflicts of interest are subject to review by the Chief Compliance Officer. Neither LRI Investments, LLC nor any of the management persons are registered or has a registration pending to register as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics LRI Investments, LLC has implemented a Code of Ethics (the “Code”) that defines our fiduciary commitment to each Client. This Code applies to all persons associated with the firm (our “Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our Client. The firm and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of the firm’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of our Code, please contact us at (860) 761-9790. Page 19 of 29 ADV2A_LRI (08/13/2025) Personal Trading with Material Interest LRI Investments, LLC does not act as principal in any transactions. In addition, the firm does not act as the general partner of a fund or advise an investment company. LRI Investments, LLC does not have a material interest in any securities traded in Client accounts. Personal Trading in Same Securities as Clients LRI Investments, LLC allows our Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities, we recommend (purchase or sell) to you presents a conflict of interest that, as fiduciaries, we must disclose to you and mitigate through policies and procedures. As noted above, we have adopted a Code of Ethics to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. Personal Trading at Same Time as Client Supervised Persons may not purchase or sell any security immediately prior to or immediately after a transaction being implemented for an advisory account, thereby preventing an employee from benefiting from transactions placed on behalf of advisory accounts. Item 12 – Brokerage Practices LRI Investments, LLC will recommend that Clients establish a brokerage account with an independent qualified custodian to maintain custody of assets and to effect trades. The custodian provides brokerage and custodial services to independent investment advisory firms, including LRI Investments, LLC. The Custodian is compensated by Clients through commissions, trails, or other transaction-based fees for trades that settle into accounts. For IRA accounts, a custodian generally charges an account maintenance fee. In addition, Custodians also charges Clients miscellaneous fees, such as account transfer fees. 1. Soft Dollars - Soft dollars are revenue programs offered by broker/dealers whereby an advisor enters into an agreement to place security trades with the broker in exchange for research and other services. The custodian makes available various products and services designed to assist the firm in managing and administering Client accounts. These services include software and other technology that provide access to Client account data (such as trade confirmation and account statements); facilitation of trade execution (and research reports or other information about particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making. These support services are provided based on the overall relationship without a minimum production level or value of assets held with the custodian. Consequently, it is not the result of soft dollar arrangements or any other express arrangements that involve the execution of Client transactions as a condition to receive the services. 2. Brokerage Referrals - LRI Investments, LLC does not receive any compensation from any third party in connection with the recommendation for establishing a brokerage account. 3. Transaction Fees -The Custodian charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). The Custodian enables LRI Investments, LLC to obtain many no-load mutual funds without Page 20 of 29 ADV2A_LRI (08/13/2025) transaction charges and other no-load funds at nominal transaction charges. The Custodian’s commission rates are generally discounted from customary retail commission rates. However, the commission and transaction fees charged by the Custodians may be higher or lower than those charged by other custodians and broker/dealers. 4. Best Execution - In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker/dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive rates, to the benefit of all Clients, we may not necessarily obtain the lowest possible commission rates for specific Client account transactions. 5. Aggregating and Allocating Trades - The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as price, size of order and difficulty of execution. LRI Investments, LLC does not aggregate purchases and sales for various Client accounts, but orders can be aggregated by the custodian. Item 13 – Review of Accounts For those Clients to whom LRI Investments, LLC provides investment advisory services, account reviews are conducted on an ongoing basis by the Investment Advisor Representative. All Clients (in person or via telephone) are encouraged to review financial planning issues (to the extent applicable), investment objectives and account performance with their Investment Advisor Representative. In addition, each Client relationship shall be reviewed at least annually. Reviews may be conducted more or less frequently at the Client’s request. Accounts may also be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account. The Client is encouraged to notify LRI Investments, LLC if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. Clients will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client can also establish electronic access to the Custodian’s website so they can view these reports and their account activity. Client brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. Item 14 – Client Referrals and Other Compensation LRI Investments, LLC is a fee-based advisory firm, that is compensated by its Clients to provide investment advice and not from any investment product or someone other than the Client. LRI Investments, LLC does not receive commissions or other economic benefit or compensation from product sponsors, broker/dealers or any un-related third party. Client Referrals from Solicitors LRI Investments, LLC does not engage paid solicitors for Client referrals. Page 21 of 29 ADV2A_LRI (08/13/2025) Item 15 – Custody LRI Investments, LLC does not accept or maintain actual custody of funds or securities. A qualified custodian is responsible to provide Clients with trade confirmations, tax forms and quarterly statements that include account balance(s). Clients are advised to carefully review the information provided by the custodian and notify their Investment Advisor Representative with any questions or if such information is not received. • Clients authorize the custodian by separate agreement to deduct advisory fees on behalf of LRI Investments, LLC. Item 16 – Investment Discretion Clients can determine to engage LRI Investments, LLC to provide investment advisory services on a discretionary basis. Prior to LRI Investments, LLC assuming discretionary authority over a Client’s account, the Client shall be required to execute an Investment Advisory Agreement, naming LRI Investments, LLC as the Client’s attorney and agent in fact, granting LRI Investments, LLC full authority to buy, sell, or otherwise effect investment transactions involving the assets in the Client’s name found in the discretionary account. Item 17 – Voting Client Securities LRI Investments, LLC does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. LRI Investments, LLC will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither the firm, nor its management, have any adverse financial situations to disclose and have not been subject to a bankruptcy or financial compromise. • The firm does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Page 22 of 29 ADV2A_LRI (08/13/2025) Item 1 – Cover Page Registered As: LRI Investments, LLC | CRD No. 323556 3825 PGA Blvd., Suite 303 Palm Beach Gardens, FL 33410 Phone: (561) 323-2265 Fax: (860) 761-9791 Appendix 1 – Wrap Fee Program Brochure February 14, 2025 This Form ADV2A - Appendix 1 (“Wrap Fee Brochure”) provides information about the qualifications and business practices for LRI Investments, LLC (“the firm") services when offering services according to a wrap program. This Wrap Fee Brochure shall always be accompanied by the firm’s Disclosure Brochure, which provides complete details on the business practices of the firm. If you did not receive the firm Disclosure Brochure or you have any questions about the contents of this Wrap Fee Brochure or the firm Disclosure Brochure, please contact us at (860) 761-9790. 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 the firm and its advisory persons are available on the SEC’s website at www.adviserinfo.sec.gov by searching for our firm name or by our CRD No. 323556. Registration does not imply a certain level of skill or training. Page 23 of 29 ADV2A_LRI (08/13/2025) Item 2 - Material Changes If the firm amends this brochure so that it contains material changes from the last annual update, the changes will be identified in this item. Clients will receive, at no charge, a summary of any material changes within 120 days of the firm's fiscal year-end and promptly (generally within 30 days) after any material changes throughout the year. Page 24 of 29 ADV2A_LRI (08/13/2025) Item 3 – Table of Contents Item 1 – Cover Page ……………………………………………………………………………………………………………………………………………..………..…..……….. 22 Item 2 – Material Changes ………………………………………………………………………………………………………………….……………….……………….…. 23 Item 3 – Table of Contents ……………………………………………..……………......................................................................................................... 24 Item 4 – Services, Fees and Compensation ……………………….……………………….……………………………………...……………….....……….. 25 Item 5 – Account Requirments and Types of Clients …………………………….……………………………..…………………………………...… 25 Item 6 – Portfolio Manager Selection and Evaluation ………………………….……………………………………………………..……..……….. 25 Item 7 – Client Information Provided by Portfolio Managers ………….……………………………………….………………………..…….. 26 Item 8 – Client Contact with Portfolio Managers ……………………………..………………………………….…………..…………….....………..… 26 Item 9 – Additional Information ……………………………………………………….……………………………………………………………..…...................… 26 Privacy Policy…………………………………………………………………………………………………………………………………...…………………………………………….27 Page 25 of 29 ADV2A_LRI (08/13/2025) Item 4 – Services, Fees and Compensation LRI Investments, LLC provides investment advisory services where the asset management fee and ticket charges are "wrapped" into a single payment. This Wrap Fee Program Brochure is provided as a supplement to the firm’s Disclosure Brochure (Form ADV 2A) to provide further details of the business practices and fee structure. This Wrap Fee Program Brochure references back to the firm’s Form ADV 2A in which this Wrap Fee Program Brochure serves as an Appendix. Please see Item 4 – Advisory Services of the Form ADV 2A for details on the firm’s investment philosophy and related services. • LRI Investments, LLC is the sponsor and portfolio manager of this Wrap Fee Program and receives investment advisory fees paid by Clients and pays the Custodian for the costs associated with the regular trading activity. • Fees are typically paid quarterly in advance (based on quarter end value and number of days in the quarter) or quarterly in arrears (based upon average daily value of 365 days), as selected on the client services agreement. Participation in this wrap fee program may cost more or less than purchasing such services separately. For example, a Client account with a high volume of trading is likely to benefit from the fee structure of a wrap fee program whereas a Client with a low volume of trading is likely to benefit more from a fee structure that charges a transaction fee per trade with a lower asset management fee or a brokerage account that does not charge an asset management fee for active management. Other Fees and Expenses Mutual funds and exchange-traded funds have separate operating costs that are described in each fund's prospectus. These fees and costs will generally be used to pay management fees, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. LRI Investments, LLC does not receive any of the fees charged by a mutual fund or ETF. A Client could invest in these products directly, without the services of LRI Investments, LLC, but would not receive the advisory services to assist in determining which products or features are most appropriate for their financial situation and objectives. Accordingly, the Client should review the fees charged by the fund[s] and the fees charged by the firm to fully understand the total costs. Only advisory fees are retained by LRI Investments, LLC. Item 5 – Account Requirements and Types of Clients Please see Item 7 – Types of Clients in the Form ADV 2A Disclosure Brochure. Item 6 - Portfolio Manager Selection and Evaluation LRI Investments, LLC serves as sponsor and portfolio manager for the services under this Wrap Fee Program. The firm does not charge performance-based fees. The selection of the wrap fee program for a Client is based on their preference for a model-based account or open architecture as well as account minimum requirements. The performance of the wrap fee program is calculated by the custodian and reviewed based on account statements and performance reports. There is no financial incentive to recommend one wrap fee program over another. LRI Investments, LLC does not accept proxy-voting responsibility. Clients will receive proxy statements directly from the Custodian. LRI Investments, LLC can assist in answering questions relating to proxies; however, the Client retains the sole responsibility for proxy decisions and voting. Page 26 of 29 ADV2A_LRI (08/13/2025) Item 7 – Client Information Provided to Portfolio Managers LRI Investments, LLC is the sponsor and sole portfolio manager for the Program. There is no other portfolio manager where Client information can be shared. Item 8 – Client Contact with Portfolio Managers LRI Investments, LLC is a full-service investment management advisory firm. Clients always have direct access to the Portfolio Managers at the firm. Item 9 – Additional Information The backgrounds, disciplinary information (none) and other financial industry activities and affiliations is available on the Investment Advisor Public Disclosure website at www.adviserinfo.sec.gov by searching for our firm name or by our CRD No. 323556. Please also see Item 9 of the firm Disclosure Brochure as well as Item 3 of each Investment Advisor Representatives Form ADV 2B Brochure Supplement (included with this Wrap Fee Program Brochure) for additional information on how to research the background information. LRI Investments, LLC has implemented a Code of Ethics that defines our fiduciary commitment to each Client. The details of the Code of Ethics can be found under Item 11 – Code of Ethics, Participation in Client Transactions and Personal Trading in the Disclosure Brochure (included with this Wrap Fee Program Brochure). Client accounts are monitored on a regular and continuous basis by the Chief Compliance Officer (“CCO”). Details of the review policies and practices are provided in Item 13 of the Form ADV Part 2A – Disclosure Brochure. Please see Item 14 – Other Compensation in the Form ADV Part 2A – Disclosure Brochure (included with this Wrap Fee Brochure) for details on additional compensation that may be received by the firm or its Investment Advisor Representatives. Each Investment Advisor Representative’s Form ADV 2B Brochure Supplement (also included with this Wrap Fee Brochure) provides details on any outside business activities and the associated compensation. • LRI Investments, LLC does not pay a referral fee for the introduction of Clients. • Financial information is available in Item 18 of the Form ADV Part 2A – Disclosure Brochure. Page 27 of 29 ADV2A_LRI (08/13/2025) Privacy Policy Our Commitment to You LRI Investments, LLC is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor , as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. LRI Investments, LLC (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. The firm does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisor s (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Employment Information and or Government ID Social security or taxpayer identification number Name, address and phone number(s) E-mail address(es) Account information (including other institutions) Date of birth Assets and liabilities Income and expenses Investment activity Investment experience and goals What Information do we collect from other sources? Custody, brokerage and advisory agreements Other advisory agreements and legal documents Transactional information with us or others Account applications and forms Investment questionnaires and suitability documents Other information needed to service your account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Page 28 of 29 ADV2A_LRI (08/13/2025) How do we share your information? LRI Investments, LLC shares Client personal information to effectlively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients. We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, consultants or other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes. LRI Investments, LLC does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where LRI Investments, LLC or the Client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users. Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s). Information About Former Clients. Advisor does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Other Important Information Information for California, North Dakota, and Vermont Customers. In response to applicable state law, if the mailing address provided for your account is in California, North Dakota, or Vermont, we will automatically treat your account as if you do not want us to disclose your personal information to non- affiliated third parties for purposes of them marketing to you, except as permitted by the applicable state law. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (860) 761-9790 or by email at info@linrip.com. Page 29 of 29 ADV2A_LRI (08/13/2025)