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This Brochure provides information about the qualifications and business practices of Strategy Asset Management, LLC, a DBA under Peregrine Asset Advisers, Inc., a registered investment advisor with the Securities and Exchange. This document will refer to Peregrine Asset Advisers, Inc. (“PAA”) and DBA Strategy Asset Management (“Strategy”). Collectively, PAA and Strategy will be called “The Adviser”. If you have any questions about the contents of this Brochure, please contact us at 503-459-4651 and/or dan@peregrineaa.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority.
The Adviser is a Registered Investment Adviser. Registration as an Investment Adviser does not imply any level of skill or training. The oral and written communications we provide to you, including this Brochure, is information you use to evaluate us (and other advisers) which are factors in your decision to hire us or to continue a mutually beneficial relationship. Additional information about Peregrine Asset Advisers, Inc. is available on the SEC’s website at www.adviserinfo.sec.gov.
The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comPeregrine Asset Advisers, Inc.
and DBA Strategy Asset Management, LLC
497 SW Century Drive STE 103
Bend, Oregon 97702
541-513-2665
www.strategyassetmanagement.com
Updated December 31, 2025
2The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 2 - Material Changes
We offer or deliver information about our qualifications and business practices to clients on at least an annual basis, at a minimum. Pursuant to SEC Rules, we will ensure that you receive a summary of any material changes to this, and subsequent Brochures, within 120 days of the close of our business’ fiscal year.
This brochure serves to report any material changes since our last brochure:
- No Material Changes to report.
Consistent with the rules, we will ensure that you receive a summary of any material changes to this Brochure, and subsequent Brochures, within 120 days of the close of our business’ fiscal year. Furthermore, we will provide you with other interim disclosures about material changes as necessary.
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 3 - Table Of Contents
Item 1 – Cover Page ...............................................................................................................................
Item 2 – Material Changes ....................................................................................................................
Item 3 - Table of Contents ....................................................................................................................
Item 4 - Advisory Business ..................................................................................................................
Item 5 – Fees and Compensation ........................................................................................................
Item 6 – Performance-Based Fees and Side-By-Side Management ............................................
Item 7 – Types of Clients .......................................................................................................................
Item 8 – Methods of Analysis, Investment Strategies, Application of Investment Strategies, and Risk of Loss .....................................................................................................................................
Item 9 – Disciplinary Information ........................................................................................................
Item 10 – Other Financial Industry Activities and Affiliations .......................................................
Item 11 – Code of Ethics ........................................................................................................................
Item 12 – Brokerage Practices .............................................................................................................
Item 13 – Review of Accounts .............................................................................................................
Item 14 – Client Referrals and Other Compensation ......................................................................
Item 15 – Custody ...................................................................................................................................
Item 16 – Investment Discretion ..........................................................................................................
Item 17 – Voting Client Securities .......................................................................................................
Item 18 – Class Action Law Suits .........................................................................................................
Item 19 – Financial Information ............................................................................................................1
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 4 - Advisory Business
Firm Description
Advisory Services
Peregrine Asset Advisers, Inc. (“PAA”) and DBA Strategy Asset Management, LLC (“Strategy”), collectively (“The Adviser”) offers fee-only investment advisory, portfolio management, and investment consulting. PAA has been registered as an investment adviser since 2001. Dan Botti is the sole Principal of PAA and serves as the firm’s Chief Compliance Officer. PAA dba Strategy Asset Management, hereafter, Strategy is an Oregon limited liability company owned and managed by Gunnar Marino. Mr. Marino is an Investment Advisor Representative associated with PAA, offers investment advisory services exclusively through PAA, and utilizes Strategy Asset Management for marketing purposes. PAA files a separate, independent ADV Part 2A and 2B Brochure for Strategy clients. Strategy office(s) are located in Bend, Oregon.
The Adviser serves as a fiduciary for its clients. This means client interests supersede the interests of the Adviser or its personnel. Investment management will be applied according to this principle. The Adviser certifies to disclose conflicts of interest and seeks to resolve any conflicts with full disclosure.
This brochure is intended for clients and prospective clients of The Adviser. It discusses the services, fees, and conflicts for both Strategy and PAA. To understand the services, fees, and conflicts of Strategy, specifically, please refer to the Strategy Brochure.
PAA dba Strategy Asset Management provides investment advisory and portfolio management for individuals, families, businesses, non-profits, trusts, retirement plans, and family offices. This includes continuous advice to client(s) regarding the investment of client funds and, where appropriate, the selection of other advisers (including private fund managers) based on the individual needs of the client(s). We manage each portfolio with the intent to achieve consistent, absolute risk-adjusted returns while keeping the client(s) unique risk and performance expectations in mind.
Through our data-gathering process, we obtain the client(s) suitability information including, but not limited to, their respective objectives, goals, time horizon(s), risk tolerance, risk appetite, and liquidity needs. As appropriate, we also review and discuss client(s) prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated suitability, as well as tax considerations.
Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors, in writing, provided to Adviser at the time of enrollment in management services.
For some client(s) assets, non-discretionary management can be used, as agreed by client and Adviser. In this manner, Strategy will develop and screen a selection of investment choices for client(s). In return, these accounts pay a management fee, as disclosed in the fee schedule.
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 4 - Advisory Business (Continued)
The Adviser manages about $575 million of client assets as of December 31, 2025. The value of assets is calculated by taking the total market value of all the securities and cash held by our collective clients on the final business day of December 31, 2025.
The Adviser uses both Fidelity and/or Schwab to custody client accounts. Other brokers could be used in exclusive cases.
Most of the money management is performed on a discretionary basis. Usually, clients give us the authority to buy and sell securities on their behalf. A few clients request approval before any investments are traded. These non-discretionary assets under management with The Adviser total about $3.2 million as of December 31, 2025.
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 5 - Fees and Compensation
A. Annual Management Fees
Strategy
Maximum annual fees for portfolio management and investment advisory services are calculated as a percentage of account values and deducted quarterly.
Equity Portfolios: 0.90%
Balanced Portfolios: 0.85%
Management fees are charged in arrears and assessed quarterly based on the quarter-end value of the account, adjusted for cash flows. The management fee is deducted from the account after it is incurred unless our client has requested an invoice.
The management fee does not include brokerage fees, or any additional fees charged by brokers or incurred by our clients. Strategy does not receive any portion of the brokerage commissions as compensation.
Strategy’s fees for services are based upon a percentage of assets under management and range from 0.90% down to zero. Strategy accepts some accounts where no management fee is charged. These zero rate accounts require minimal ongoing and continuous management by Strategy and will usually contain only static security holdings, such as cash and/or cash equivalents. Fees are negotiable and billed quarterly, in arrears, at the end of each calendar quarter based upon the value of the client’s account at the end of the quarter.
Fees will be debited from the account in accordance with the client authorization in the investment advisory agreement. Fees are pro-rated for new and terminating accounts based on the number of days that the account was open during the quarter.
All advisory and account service fees are detailed in the client Investment Advisory Agreement. We do not charge prepayment of advisory fees for more than one quarter in advance. Advisory contracts may be terminated within 5 business days, without penalty.
The above fee schedule is included in the written Investment Advisory Agreement between Strategy and our clients. Each party may terminate the IA agreement upon 30 days written notice.
Client facts, circumstances, and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets, related accounts, portfolio style, account composition, reports, among other factors.6
The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comB. Brokerage Fees
C. Other Fees
Item 6 – Performance-Based Fees and Side-By-Side Management
It became standardized for brokerage firms to offer free commissions in 2019. Fidelity and Schwab both extend free brokerage fees for clients that agree to receive their documents via electronic delivery. Clients opting out of this method of delivery will pay brokerage fees as high as $4.95 per trade. Since Strategy can be an active manager, these costs can add up to be a considerable amount for any client not enrolled in electronic delivery. These are costs that clients are responsible for and separate from the fees charged by the Adviser.
See Item 12 – Brokerage Practices for more information on how the Adviser selects broker-dealers.
In addition to our advisory and service fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers. These may include brokerage commissions, transaction fees, money movement fees and margin charges.
Clients participating in separately managed account programs may be charged various program fees in addition to the advisory fee charged by our firm. Such fees may include the investment advisory fees of the independent advisers, which may be charged as part of a wrap fee arrangement. In a wrap fee arrangement, clients pay a single fee for advisory, brokerage and custodial services. Client’s portfolio transactions may be executed without commission charges in a wrap fee arrangement.
All fees paid to The Adviser for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. Mutual funds charge expenses within the structure of the funds. Dividends from foreign securities can also be taxed and foreign securities also levy registration fees on client accounts.
There are additional costs incurred if the Adviser recommends another investment manager to manage all, or a portion, of the client(s) portfolio, or a private fund. Clients are responsible for these fees, and these fees are separate from management fees charged by the Adviser.
There are no performance-based fee arrangements.
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 7 – Types of Clients
Item 8 - Methods of Analysis, Investment Strategies, Application of
Investment Strategies, and Risk of Loss
A. Methods of Analysis
B. Investment Strategies
The Adviser’s clients are individuals, families, businesses, trusts, and organizations. Some of our clients are high net worth people. The accounts managed include brokerage accounts, individual retirement accounts, trusts, business organizations, and pension and profit-sharing plans.
Strategy
Strategy does not impose a minimum dollar value of assets or other conditions for opening or maintaining an account.
Strategy applies a holistic approach to investment management. This means that many sources and tools are used to determine the construction of securities portfolios. Ultimately, securities chosen for purchase are based on a confluence of macroeconomic factors, business performance, fundamental analysis, technical analysis, cyclical trends, asset allocation, and qualitative analysis, and quantitative analysis.
Securities prices have a tendency to move in the same direction. Some securities selected for client portfolios may move inversely to the market or other stocks within client portfolios. These securities may be chosen intentionally even though they may fall in value in a rising market or rise in value in a falling market. The purpose of these securities is to protect an investment account from abrupt market declines and improve overall investment performance over time.
Strategy uses research and investment analysis from many sources. These sources include widely circulated publications and non-public economic research.
Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information.
Strategy uses several strategies to serve its clients.
Appreciation
The Adviser invests in securities with a purpose of achieving appreciation. This strategy is implemented with listed stocks, bonds, ETFs, and mutual funds. The holding period varies based8
The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comon the economic environment. Generally, this holding period is more than a year, although can be shorter due to economic market changes and trends.
Income:
Client investments can generate income. These include stocks, bonds, ETFs, mutual funds, certificate of deposits, cash-equivalent instruments, and more.
Trading
Strategy uses both passive, and active stock market trading as an investment approach. Strategy believes it offers a unique service by attempting to generate consistent trading profits, while remaining focused on realized capital gains in client(s) account(s) over time. This approach could consist of various holding periods and realized gains over time. Numerous variables will be used as consideration to determine the holding periods of securities in client(s) account(s).
Options
Strategy has the ability to use options and derivatives trading for clients, although rarely used. Options can be used to protect downside risk of a portfolio, used to increase income in a portfolio, and used to enhance the appreciation of a portfolio. If options strategies are used, they are limited to covered call writing and protective puts on positions existing in client(s) account(s). These strategies are rarely used by The Adviser and will only be utilized after full disclosure of risks to client(s), and the written approval of the aforementioned additional risks by the client.
Hedge Funds and Alternative Investments
The Adviser can place money with hedge funds and other advisors/managers. These investment alternatives require separate consent documents from our clients. The use of these managers is rare, and can result in additional fees outside of the managed account fees charged by Strategy.
Client accounts are managed by Strategy based on numerous determining factors.
Specific investment strategies can be implemented by Strategy in conjunction with the client. The considerations for determining the investment strategy are the suitability, financial needs, objectives, and goals for each client and their account(s).
The investment strategy adopted by Strategy seeks the highest return while minimizing risk, as much as possible. Typically, client accounts will hold similar securities, with variance due to existing positions in the portfolio and client(s) suitability considerations. There can be variations in securities, however, depending on the tenure of the client, existing positions in the portfolio, tax considerations, suitability, and the account size.
Accounts that are below the $100,000 threshold may be maintained, and managed, differently than larger accounts. They can hold fewer securities because there is less money to adequately diversify. In these accounts, exchange traded funds and mutual funds could be more frequently used.C. Application of Investment Strategies for Strategy Managed Clients
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comIndividual client circumstances and preferences can dictate particular trades that are made separately from all other clients with The Adviser. Client trades of the same security may differ from the overall client base of The Adviser. Suitability considerations, liquidity needs, income needs, investment interests, recent substantial deposits, risk requirements, general client preferences, or any other matter that distinguishes a client account, can affect the management of a particular account.
Investing in securities involves risk of loss that clients should be prepared to bear. The value of securities fluctuates daily. The Adviser may decide to sell any security that could result in a loss for a client. The Adviser regards investment losses as part of the investment process. Major market declines constitute the biggest risk to clients. These moves can outweigh timely and accurate security selection by The Adviser.
An example of this occurrence is when the entire stock market drops sharply over a very short period of time. There is also a risk that a decline in the stock market can take place relentlessly, over a longer period. Losses from short-term trading can also occur. These losses could exceed profits over a given period.
Substantial risk also exists in the bond market. Different issuers of bonds can have varying degrees of default risk, the risk an issuer of a bond could default. In the event of a bankruptcy to a bond issue, a total loss of principal could result.
If investment company services like ETFs and mutual funds are used, the management of these funds could pursue losing strategies, which could adversely impact clients.
Exchange traded funds that use leverage, known as leveraged ETFs, can be used in client accounts. These securities contain high risks from market movements.
There can also be high risks from owning illiquid or thinly-traded stocks. If The Adviser were to buy or sell one of these securities for its clients, there could be a detrimental movement in the price of the security, which could disadvantage investors.
Investment management necessitates additional tax preparation costs that accounts for trades made in taxable accounts and income earned off these securities. Occasionally, Master Limited Partnerships (MLPs) are used as investments. These MLPs generate K-1 tax forms for which additional tax reporting is required.
CPAs charge additional fees to account for K-1s. MLP income can also have a negative consequence on retirement accounts in that Unrelated Business Income (UBI) could be taxable even though the security is held in a retirement account.
D. Risk of Loss
E. Other Potentially Negative Considerations
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics
A. Code of Ethics
B. Participation in Client Transactions
C. Personal Trading
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be pertinent to evaluating the Adviser or the integrity of the Adviser’s management.
Clients can refer to the Investment Adviser Public Disclosure website to find any history of disciplinary actions against the Adviser, its staff, or affiliates. See www.adviserinfo.sec.gov.
The Adviser has not incurred any disciplinary or legal event that is involved with investment management. None of our staff has been subject to any disciplinary or legal action.
Strategy uses Fidelity and Schwab as brokers for client accounts. These institutions are the custodians of client assets.
Strategy may also use independent, separate affiliates to support its services to clients.
The Adviser has created a Code of Ethics that covers the business practices of all our personnel. Our Code of Ethics states that we are committed to conducting business in accordance with applicable laws, rules, regulations, and maintaining the highest standards of business conduct. The Adviser asserts that all its employees will be held accountable for the ethical and operational policies of the firm. The Adviser is committed to a process that will ensure that these standards are met. The Adviser regards the ideals of honesty, integrity, and trust as a minimum requirement for all employees. A copy of our Code of Ethics is available to any client upon request.
We do not participate in any investment pool or financial enterprise for which we benefit from client investments.
Our employees may invest in the same securities that are held by our clients. Employees are also allowed to disinvest or sell any security that our clients own.
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comWe forbid our employees from “front running” or trading ahead of our clients on our trades for clients in the same security. We also certify that our employees will not receive a better price on any security that The Adviser trades on the same day. Employees are allowed to buy or sell securities held by clients on any day that clients are not trading in the same security.
Our clients allow us to choose the broker(s) that will function as the custodian for our client accounts. Usually, either Fidelity or Schwab are chosen as custodian brokers for clients. The brokerage firms offer zero commission trading since 2019, unless clients require paper statements, as disclosed in Item 5 – Fees and Compensation.
In addition to providing transaction services, custodian brokers also provide services necessary for the ongoing and continuous management of investment accounts. This includes trading, record keeping, document management, brokerage statements, retirement plan services, dividend and interest collection, and tax reporting.
The Adviser may invest in the same security for many clients at the same time so that all clients receive the same price. Client suitability, individual needs, objectives, and risk tolerance are considered when allocating investments. Special client requests are followed when allocating investments. The Adviser determines the quantity of shares to be bought or sold or the percentage weighting for each security for each investment account.
Our clients may specify a different custodian. Additionally, brokers may refer clients to The Adviser and provide custody for these clients. A client making this designation should understand that the client might forego certain cost savings. In addition, a client should understand that accounts of this nature are often omitted from the standard allocation procedure and there may be fewer investment opportunities provided by Adviser. These accounts are not conveniently accessible to Adviser because Adviser only has custody arrangements with Fidelity and Schwab and cannot monitor other brokers as effectively.
The Adviser will protect the best interests of clients when dealing with trading errors or mistakes. Errors occur when a transaction is unintended. Item 12 – Brokerage Practices
A. Choosing a Broker
B. Order Allocation and Aggregation
C. Client Directed Brokerage
D. Trade Error Correction Policy
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comErrors can happen from trading the wrong intent (i.e., buy rather than sell) or trading the wrong number of shares or using a wrong account number. Errors can also result from inadvertent portfolio management such as buying a stock previously prohibited by the client or by neglecting to follow a pre-stated investment request by our client. The Adviser’s error policy is that errors be corrected immediately so that our client would not be negatively affected by Adviser’s error.
The Adviser will choose a broker, such as Fidelity or Schwab that meet high standards of record keeping, trade executions, research, and offer competitive commission rates. We do not receive any payment from choosing a broker.
The Adviser does not have any soft dollar arrangements.
The Adviser is responsible for investments made in client accounts and the continuous review of those accounts. Strategy may assign a single percentage weighting for each security amongst all of its managed accounts. This means multiple clients may own the same securities and the same weighting.
Investments allocated to client accounts are based on the financial condition of each client and prevailing economic factors that influence stock prices. These allocations can be mitigated by the perceived risk tolerance for each client. All three of these factors can change. There can be variance in client accounts with respect to the securities and their weightings.
Extensive research and experience is involved in managing the investments that comprise The Adviser’s portfolios. Strategy invests for long-term capital appreciation, long-term realized gains, and investment income. These are outlined in Item 8, B. All three strategies impact client portfolios. Client securities are bought and sold for a variety of reasons based on many sources of research. At times, the same stocks may be bought for some clients and sold for others depending on changing economic factors or client risk tolerance levels.
Investments for clients are made for various reasons and strategies. Holding periods vary. Realized gains in accounts are mostly long-term, more than one year. Individual clients can have different portfolios with different securities but, at times, clients can hold the same security, purchased on the same date, at the same price. Client tenure with The Adviser can contribute to a variance in the security holdings in account(s). E. Best Execution Policy
F. Soft Dollars
Item 13 – Review of Accounts
Review of Accounts - Triggering Factors for Strategy Managed Accounts
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comFor example, a new client of less than one year will not necessarily own the same securities as clients that have been with Strategy for a longer period. Additionally, existing positions in client(s) portfolios may contain varying levels of unrealized gains and tax considerations, resulting in different investment strategies and securities used.
Strategy uses a combination of “dynamic investment management”, a process where securities are traded in order to realize gains from investing or to minimize losses, and “passive investment management”, a process where securities are traded less frequently and used to perform similar to the broader market. This process is the cornerstone to continuous management and review of client accounts. We believe this process will reduce risk for client accounts, minimize tax consequences, and increase the likelihood of higher total return over time.
A consequence of trading is accounting for taxes. The Adviser may register a significant number of trades in the course of a single tax year. Since The Adviser works to realize capital gains, these gains may be subject to short-term capital gains taxes.
The Adviser provides written quarterly performance reports for its clients. These reports consist of a performance review highlighting the value of client accounts at the end of the quarter, showing contributions, withdrawals, capital appreciation, income, management fees paid, quarterly returns, annual returns and “since inception” returns. Also included in the quarterly report is a quarterly billing statement.
Strategy does not participate in any active referral arrangements and does not compensate employees or non-employees for referring clients. In the unlikely event of this potentially occurring, clients would be informed of any agreement initiated and the potential conflicts of interest.
Client assets are held at custodian brokers, whose websites allow clients to view their accounts online. Clients are encouraged to compare the reports from The Adviser to the statements, and reports, provided from their custodian brokers.
Clients are required to sign authorization documents in order to wire transfer or pay our funds to third parties. Clients will also be required to provide verbal confirmation for any Fed funds wire.
Item 14 – Client Referrals and Other Compensation
Compensation for Referrals
Item 15 – Custody
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 16 – Investment DiscretionItem 17 – Voting Client Securities
Item 18 – Class Action Law Suits
Generally, The Adviser has discretionary management, and the authority to determine, without obtaining specific client consent, the securities to be bought or sold, amount of the securities to be bought or sold, the timing of securities to be bought or sold, and broker or dealer to be used. Clients give us discretionary authority when they sign our Investment Advisory Agreement.
For clients enrolled in non-discretionary management, The Adviser does not have the authority to transact in the client’s account(s) enrolled in non-discretionary management without verbal consent of the client. Non-discretionary management does not give The Adviser the authority to place trades, nor transact in any manner, in the client’s account(s) without verbal approval from the client, prior to the transaction occurring.
We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write, or email us to discuss questions they may have about particular proxy votes or other solicitations.
Class action lawsuits are commonplace in the stock market. These class actions will affect many stocks, which may be used for client accounts. The Adviser has hired Chicago Clearing to complete all necessary documentation and make the appropriate filing when appropriate. In exchange for this service, client accounts give up 17.50% of the award as a fee for their administrative work. This percentage rose to compensate Chicago Clearing on SEC fair fund rule fair fund settlements, which prohibit a filing fee for the compensated shareholder. This change occurred in 2023.
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 19 – Financial Information
We are not required to present our clients with a balance sheet of our operations because we do not collect management fees beyond the current quarter.
Our own financial condition will not impede our ability to act in the client’s best interest in performing investment advisory services. We are not financially impaired in any way that would affect our duty to perform continuous and ongoing investment management in the best interest of our clients.
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This Brochure Supplement provides information about Gunnar Marino that supplements the Strategy Asset Management, LLC. Brochure. You should have received a copy of that Brochure. Please contact us at 541-513-2665 and/or g.marino@strategyam.com if you did not receive Strategy Asset Management, LLC.’s Brochure or if you have any questions about the contents of this supplement.
Additional information about Gunnar Marino is available on the SEC’s website at www.adviserinfo.sec.gov.The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comADV Part 2B: Brochure Supplement
Gunnar Marino, Investment Adviser Representative
Strategy Asset Management
497 SW Century Drive STE 103 Bend, Oregon 97702
541-513-2665
Updated December 31, 2025
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The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 1 - Educational Background and Business Experience
Gunnar Marino, Investment Adviser Representative
Strategy Asset Management, LLC | Founder | 2025–Present
Peregrine Asset Advisers, Inc. | Investment Adviser Representative | 2025-Present
Charles Schwab & Co., Inc. | VP - Financial Consultant | 2023-2025
Merrill Lynch | Registered Private Wealth Client Associate | 2021-2023
Fisher Investments | Private Client Group Regional Sales Associate | 2020-2021
Oregon State University | BA, Business | 201918
The [S] logo, StrategyAssetManagement®, and STRATEGYASSETMANAGMENT® are registered trademarks, used by permission of the owner, Strategy Asset Management, LLC 2025 www.strategyassetmanagement.comItem 2- Disciplinary Information
Item 3- Other Business Activities
Item 4- Additional Compensation
Item 5 - Supervision
Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice.
No disciplinary information is applicable to this Item.
Gunnar Marino does not participate in any external business involvement, or outside business activities (OBAs).
Management fees constitute the sole source of revenue for The Adviser.
Dan Botti has the responsibility of supervising all of the staff, including the Investment Advisers of Peregrine Asset Advisers and Strategy Asset Management. Any complaints about the firm, its personnel, or practices should be directed to him.
Dan Botti
503-459-4651
dan@peregrineaa.com
12-31-202519