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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.
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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.
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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
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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)
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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.
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• 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
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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:
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•
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.
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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.
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• 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.
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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”).
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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
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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
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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.
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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:
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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.
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• 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.
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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.
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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.
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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
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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.
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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.
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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.
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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.
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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
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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.
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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.
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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.
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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.
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