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412 East Huron, Ann Arbor, MI 48104
734.929.2520 ♦ 877.929.2520
www.pollockinvestmentadvisors.com
FORM ADV PART 2A
BROCHURE
This brochure provides information about the qualifications and business practices of Pollock
Investment Advisors, LLC. If you have any questions about the contents of this brochure, please
contact James K. Pollock, CFA at (734) 929-2520 and/or at jim@pollockinvestmentadvisors.com.
The information in this brochure has not been approved or verified by the United States Securities
and Exchange Commission or by any state securities authority.
Additional information about Pollock Investment Advisors, LLC is also available on the SEC’s
website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Pollock Investment
Advisors, LLC is 153350.
Pollock Investment Advisors, LLC is a Registered Investment Adviser. Registration with the United
States Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
January 20, 2026
Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
Table of Contents
Material Changes .............................................................................................. 2
Advisory Business ............................................................................................. 2
Types of Clients ................................................................................................ 5
Fees and Compensation ................................................................................... 5
Performance-Based Fees and Side-By-Side Management ............................ 7
Client Referrals and Other Compensation ....................................................... 8
Methods of Analysis, Investment Strategies and Risk of Loss ...................... 8
Other Financial Industry Activities and Affiliations .................................... 12
Custody ........................................................................................................... 12
Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading ............................................................................................ 12
Investment Discretion .................................................................................... 13
Brokerage Practices ....................................................................................... 14
Review of Accounts ........................................................................................ 15
Voting Client Securities ................................................................................. 16
Financial Information .................................................................................... 16
Disciplinary Information ................................................................................ 16
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
Material Changes
This Brochure is our disclosure document prepared according to regulatory requirements.
Consistent with the rules, we will provide you with a summary of any material changes
to this and subsequent Brochures. We will provide you with other interim disclosures
about material changes as necessary. Since our last annual updating amendment dated
March 27, 2025, we have not had any material changes.
Advisory Business
Pollock Investment Advisors, LLC (the "Registrant" or "PIA") is an independent
investment adviser registered with the Securities & Exchange Commission. PIA’s primary
service is to provide investment management services and financial planning to
individuals, families, charities, trusts, estates, retirement plans, corporations and other
business entities including limited liability corporations and limited liability partnerships. In
addition to direct investment supervisory services, from time to time, the Registrant will
also place clients’ monies with third-party money managers and engage in financial
planning for clients. Principal owners of PIA are James K. Pollock, CFA and Robert N.
Pollock, Jr..
PIA offers investment advisory services to separate accounts for a range of clients.
These services include the evaluation and identification of a client's tolerance for risk,
as well as their long-term investment goals and objectives. These services include, but
are not limited to:
- Establishing investment goals and objectives, as well as long-term asset
allocation targets
Investing client assets consistent with long term goals and objectives
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- Monitoring the individual investment positions as well as the client's
consolidated portfolio of investable assets.
PIA will generally invest its clients' assets in some combination of exchange-traded funds,
no-load mutual funds, equities, limited partnerships, U.S. Treasury securities and other debt
instruments. In addition, PIA will provide clients with investment advice and strategy for
potential private-equity offerings, their incentive stock options and restricted stock units,
company and/or University retirement investment options, as well as college savings plan
investment strategies and options.
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
PIA will also provide a service of evaluating and recommending select investments in
private funds to those clients for whom it believes the offering to be suitable. Adviser
will establish general parameters of risk tolerance, liquidity, and asset allocation to
determine suitability. In general, Adviser will only recommend these investments to
clients who meet the SEC definition of an “accredited investor” and/or “qualified client”,
pursuant to the specifics of each individual private offering.
Additionally, as applicable, PIA provides advice on any type of investment held in a
client portfolio, or any investment that a client may have interest in at a later date.
PIA also offers financial planning services to some clients which complements their
investment advisory service. Based on the needs of the client, financial planning services
can include, but are not limited to the following:
- Preparation of an investment policy statement to help identify client’s long-term
goals, objectives, and risk tolerance.
Insurance review
- Review of retirement savings, long-term spending, and cash flow projections.
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- Coordinating tax and estate planning with clients’ tax and legal advisors. We identify
issues that need further professional input.
- Generational wealth transfers
- Charitable giving
- College savings plans
For certain assets custodied at SEI Private Trust Company, clients have the ability to obtain
a securities-backed line of credit (“SBLOC”) through The Bancorp Bank, “The Lender”.
The Bancorp Bank is not affiliated with PIA, SEI or any of its subsidiaries. Interested
Clients will need to complete a loan application and loan agreement through The Bancorp
Bank, and The Bancorp Bank will determine the Client’s eligible line of credit, subject to
the lender’s eligibility requirements and terms and conditions. Client assets will continue to
be custodied at SEI Private Trust Co. While client assets will be considered pledged as
collateral for the loan, under certain circumstances where PIA is able to, PIA will continue
to manage the assets consistent with the goals and objectives of the client.
PIA will generally only recommend an SBLOC after careful consideration and review with
the client. Each client has unique circumstances that will be evaluated on a case-by-case
basis. By utilizing a SBLOC the client’s portfolio remains invested consistent with their
objectives rather than changing the asset allocation to withdraw funds. The main risks to
the client in establishing an SBLOC are: 1) a decline in the market value of the collateral
assets, and 2) a default on the SBLOC. Depending on the specific event, clients could be
subject to a limitation on the amount of available credit, be required to deposit additional
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Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
assets, or make an immediate payment. In an extreme case of default, the forced liquidation
of securities is also a possibility. This can have significant negative tax ramifications for
the client.
PIA does not receive any fees or payments from the lender or SEI. If a client chooses to
utilize a line of credit instead of selling securities, PIA will benefit by receiving an advisory
fee on the greater total value of the securities, which is not reduced by any outstanding
amounts on the line of credit.
PIA does not render or provide tax or legal advice, nor do we receive any compensation
from any clients’ tax or legal advisors.
Prior to engaging the Registrant to provide investment advisory services, the client will be
required to enter into one or more written agreements with the Registrant setting forth the
terms and conditions under which the Registrant shall render its services (collectively the
"Agreement"). In addition, the Registrant will only implement its investment
management recommendations after the client has arranged for and furnished the
Registrant with all information and authorization regarding accounts with appropriate
financial institutions.
All investment advisory services provided to clients are individually tailored to meet their
objectives. At the onset of all client relationships, PIA evaluates factors that include but are
not limited to, a client’s current and future income needs, their current tax bracket if
applicable, their age and health as well as their ability to understand and identify risks. Where
appropriate, PIA incorporates the use of questionnaires that help identify risk profiles and
return objectives.
Client goals and objectives are reviewed and updated, at least on an annual basis, with all
clients. The Registrant's clients are advised to properly notify the Registrant if there are ever
any changes in their personal or financial situation, their investment objectives, or if they
wish to impose any reasonable restrictions on their account.
PIA does not participate in any wrap fee programs.
Assets Under Management
As of December 31, 2025, PIA had $355,488,705 under management; $328,399,676 on a
discretionary basis and $7,089,029 on a non-discretionary basis.
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
Types of Clients
As a condition for starting and maintaining a relationship the Registrant has a minimum
portfolio size of $500,000. The Registrant, in its sole discretion, may waive or raise its
minimum portfolio amount, based upon certain criteria including anticipated future earning
capacity, anticipated future additional assets, dollar amounts of assets to be managed, related
accounts, account composition, pre-existing client, account retention, and pro bono activities.
The Registrant shall only accept clients with less than the minimum portfolio size if, in the sole
opinion of the Registrant, the smaller portfolio size will not cause a substantial increase of
investment risk beyond the client's identified risk tolerance. The Registrant may aggregate the
portfolios of family members to meet the minimum portfolio size and minimum annual fee.
PIA generally provides investment advice and financial planning services to individuals,
trusts, estates, charitable organizations, pension and profit-sharing accounts, as well as
corporations and select business entities other than those listed above.
Fees and Compensation
The Registrant typically charges clients for investment advisory services an asset-based
fee, calculated as a percentage of the value of the client's assets under management with
the Registrant, or a fixed fee. Under certain circumstances, the Registrant will provide
investment advisory services on an hourly basis. The Registrant’s fees for investment
advisory services are set forth in our investment advisory agreement with the client.
For the asset-based fee, the annual fee shall be prorated and is typically charged
monthly, in arrears, based upon the market value of the assets on the last day of the
current month. The billable balance is based upon the custodian’s market value placed
on the assets under management, including cash and cash equivalents. In absence of a
custodial value, PIA and client agree to seek the opinion of an unaffiliated third party.
At the Registrant’s discretion, fees will be charged quarterly.
The annual fee shall vary depending upon the market value of the assets under
management, and any breakpoints. Generally, the Registrant's fee schedule is as follows:
Assets Under Management
$0 - $3,000,0000
$3,000,000 - $5,000,000
Over $5,000,000
Advisory Fees
1.00%
.80%
.50%
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
The Registrant, in its sole discretion, may negotiate to waive its stated account minimum or
charge a lesser management fee based upon certain criteria (i.e., anticipated future earning
capacity, anticipated future additional assets, dollar amount of assets to be managed, related
accounts, account composition, pre-existing client, account retention, pro bono activities,
etc.)
The Registrant's Agreement and/or the separate agreements with SEI Private Trust
Company, Fidelity, and/or TIAA (“SEI”, “Fidelity”, and/or "TIAA", or the
“Custodian”), authorizes the Registrant through the Custodian to debit the client's
account for the amount of the Registrant's fee and to directly remit that management fee
to the Registrant in accordance with applicable custody rules. The Custodian(s)
recommended by the Registrant have agreed to send a statement to the client, at least
quarterly, indicating all amounts disbursed from the account including the amount
of management fees paid directly to the Registrant.
The client may make additions to and withdrawals from the account at any time, subject to
the Registrant's right to terminate an account. Clients may withdraw account assets on notice
to the Registrant, subject to the usual and customary securities settlement procedures.
However, the Registrant designs its portfolios as long-term investments and assets
withdrawals can impair the achievement of a client's investment objectives. Asset
withdrawals can also have adverse tax consequences for clients.
For the initial month or quarter of investment management services, the first advisory
billing will typically be calculated on a pro-rata basis. The Agreement between the Registrant
and the client will continue in effect until terminated by either party pursuant to the terms
of the Agreement. The Registrant's fee shall be prorated through the date of termination
and any remaining balance shall be charged or refunded to the client, as appropriate, in a
timely manner.
Third Party Money Management
In addition to actively managing the Client’s assets, where appropriate, PIA will also place
clients’ monies with a third-party money manager to act as a sub-adviser to the account,
particularly in the area of fixed income management. In this arrangement, clients will be
responsible for paying fees directly to the third-party money manager at its set rate. These
fees will be in addition to the fees paid to the Registrant, and are established by the sub-
adviser and detailed in quarterly account statements.
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
Payment of Fees
For the asset-based fee, the annual fee shall be prorated and charged monthly or
quarterly, in arrears, based upon the market value of the assets on the last day of the
current month/quarter. The billable balance is based upon the custodian’s market value
placed on the assets under management. In absence of a custodial value, PIA and client
agree to seek the opinion of an unaffiliated third party.
Advisory fees are deducted from clients' assets as detailed in the Investment Advisory
Agreement. The Registrant, in its sole discretion, will bill clients directly for fees incurred
instead of deducting fees from client accounts.
Select accounts will pay fees quarterly at the sole discretion of The Registrant.
Please note:
- Clients pay the transaction costs associated with management of the account,
including transaction fees and charges imposed directly by a mutual fund or exchange
traded fund in the account, which shall be disclosed in the fund's prospectus (e.g.,
fund management fees and other fund expenses), deferred sales charges, odd-lot
differentials, transfer taxes, wire transfer fees and other related expenses.
- The Registrant shall not receive any portion of these commissions, fees, and costs,
and they are in addition to Registrant's fees.
- Advisory fees are billed monthly or quarterly in arrears.
- Custody fees for client assets held at SEI Private Trust Company have been
implemented with their new wealth platform. These fees were implemented for
accounts opened after September 30, 2019. PIA will absorb the cost of these custody
fees, which will be an offset again investment advisory fees charged to the client. The
result of this is that accounts opened before September 30, 2019 will pay transaction
costs for trades while accounts opened after September 30, 2019 will not pay any
transaction costs. PIA and SEI reserve the right to change this in the future.
Performance-Based Fees and Side-By-Side Management
PIA does not accept performance-based fees.
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
Client Referrals and Other Compensation
PIA does not directly or indirectly compensate any person for client referrals.
Methods of Analysis, Investment Strategies and Risk of Loss
Independent and employee owned, PIA provides fundamental investment advisory and
financial planning services to our clients. Our primary investment strategy is to construct
and manage diversified, low turnover, tax efficient portfolios that are tailored to the unique
set of goals and objectives of each our clients.
To achieve the long-term goals of our clients, our investment strategy could best be
described as a top-down approach with a bottom-up focus on security and/or manager
selection. We define top down as a focus on the major macro-economic forces that affect
markets, investors, and securities. Such forces include, but are not limited to, taxation,
population trends, money supply and interest rates. The bottom-up focus would include an
evaluation of investment specific factors on a security-by-security basis.
The methods of analysis we utilize in formulating our investment advice focuses on an
interview process with clients. PIA works closely with clients, as well as their legal and tax
advisors where appropriate, to identify each client’s long-term planning and investment
goals, their investment time horizon, as well as their tolerances for risk. The initial interview
and meeting establishes the framework for our working relationship. Most importantly, this
framework serves as a reminder during periods of market euphoria or duress, of a client’s
long-term goals and why they invest.
Clients are advised that investing involves risk of loss. This risk of loss is something that
clients should be prepared to bear. All investments present the risk of loss of principal –
the risk that the value of the securities (e.g., stocks, mutual funds, and ETFs), when sold
or otherwise disposed of, will be less than the price paid for the securities. Even when
the value of the securities when sold is greater than the value when purchased, there is
the risk that the appreciation will be less than inflation. In other words, the purchasing
power of the proceeds can be less than the purchasing power of the original investment.
Investments such as those primarily used by Registrant for client portfolios (including,
but not limited to, stocks, mutual funds, and ETFs) are not deposits in a bank and are not
insured or guaranteed by the Federal Deposit Insurance Corporation or any other
governmental agency.
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Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
Investment Strategy - Individual Equity Securities
PIA will construct and manage portfolios of individual securities for those clients whose risk
tolerances will allow such a strategy. A portfolio of individual securities will typically be
more concentrated and have a higher risk of loss than a more diversified mutual fund
strategy.
This is a long-term approach to stock investing. Equities are generally selected from a
universe of large, mid and small capitalization domestic companies. Companies are selected
and retained based on factors that include:
financial strength (low debt, return on equity, strong cash flows)
- historical and forecast sales and earnings growth and stability
- valuation
- historical and forecast dividend growth
-
Portfolios of individual securities will differ from market benchmarks with respect to sector
weightings and therefore exhibit greater variability of returns.
Portfolios are constructed to typically have low turnover. Low turnover can positively
impact investment performance due to lower brokerage, transaction and tax costs.
Investment Strategy - Mutual Funds and Exchange Traded Funds (ETFs)
PIA will construct and manage portfolios utilizing mutual funds and/or ETFs for those
clients whose risk tolerances will allow such a strategy. A portfolio that includes mutual
funds and/or ETFs will typically be more diversified than a strategy that utilizes individual
securities.
Mutual funds and/or ETFs are selected and retained in portfolios based on a number of
factors including:
Investment style
Investment performance
-
- Consistent investment philosophy and methodology
- Portfolio Manager tenure
- Assets under management
- Fee structure
-
Individual mutual funds and/or ETFs are selected in a range of investment styles and asset
classes. This would include but is not limited to fixed income as well as equity mutual funds.
Specific investment styles include, but are not limited to, large, mid and small company
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Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
funds, international, emerging and frontier market funds, high yield, corporate, municipal
and government bond funds, as well as alternative (i.e. managed futures, long/short,
commodity) funds.
Portfolios typically include a number of funds and/or ETFs to improve
diversification.
Investment Strategy - Third Party Money Managers
Under certain circumstances, PIA will utilize a third-party money manager for select clients.
These managers will typically maintain an investment competency that complements the core
investment strategy of PIA. These third-party managers will primarily manage a portion of
client portfolios within certain risk parameters as directed by PIA. The third-party
managers will manage, but are not limited to, equity and fixed income securities.
Third party money managers are selected and retained based on a number of factors
including:
Investment style
Investment performance
-
- Consistent investment philosophy and methodology
- Portfolio Manager tenure
- Assets under management
- Fee structure
-
Third party managers encompass a range of investment styles and asset classes. This would
include but is not limited to fixed income as well as equity managers. Specific investment
styles include, but are not limited to, large, mid and small company managers, international
and emerging market managers, government, corporate, and municipal bonds, high yield
bonds and commodity managers.
Portfolios utilizing third party managers involve more risk depending upon the nature of the
underlying investment style and the level of diversification utilized by the third-party
manager.
Investment Strategy – Private Funds
Where appropriate, PIA will also provide a service of evaluating and recommending
select investments in private funds to those clients for whom it believes the offering to
be suitable. Private funds are generally subject to a high degree of risk (including the
potential for complete loss of principal), are not suitable for all investors, and typically
have high fees, limited liquidity and delays in tax reporting. By themselves, private funds
do not constitute a balanced investment portfolio. Clients should carefully review and
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
consider potential risks before investing in private funds, including carefully reviewing
all disclosure documents, private offering memoranda, prospectuses, or other offering
materials and/or consulting tax or legal counsel, if appropriate.
Investment Strategy – Cash and Equivalents
From time to time, PIA invests its clients’ uninvested assets in cash equivalents, such as
government or corporate money market funds. Such funds have historically been priced at
par with no risk of capital gain or loss. There can be no assurances that such investments
will not change in value in the future. Losses are possible, although the risk is low.
At select times, The Registrant in its discretion will utilize short-term taxable or tax-exempt
bond funds as an alternative to cash and equivalents. Such funds have historically generated
a higher interest rate return for investors, with only moderately higher risk. While there is
the potential for capital losses or gains for investors, under certain circumstances, the
higher interest rate on such securities will compensate for a loss.
Cybersecurity
The computer systems, networks and devices used by PIA and service providers to us
and our clients to carry out routine business operations employ a variety of protections
designed to prevent damage or interruption from computer viruses, network failures,
computer and telecommunication failures, infiltration by unauthorized persons and
security breaches. Despite the various protections utilized, systems, networks, or devices
potentially can be breached. A client could be negatively impacted as a result of a
cybersecurity breach.
Cybersecurity breaches can include unauthorized access to systems, networks, or
devices; infection from computer viruses or other malicious software code; and attacks
that shut down, disable, slow, or otherwise disrupt operations, business processes, or
website access or functionality. Cybersecurity breaches may cause disruptions and
impact business operations, potentially resulting in financial losses to a client;
impediments to trading; the inability by us and other service providers to transact
business; violations of applicable privacy and other laws; regulatory fines, penalties,
reputational damage, reimbursement or other compensation costs, or additional
compliance costs; as well as the inadvertent release of confidential information.
Similar adverse consequences could result from cybersecurity breaches affecting issuers
of securities in which a client invests; governmental and other regulatory authorities;
exchange and other financial market operators, banks, brokers, dealers, and other
financial institutions; and other parties. In addition, substantial costs may be incurred by
these entities in order to prevent any cybersecurity breaches in the future.
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
Other Financial Industry Activities and Affiliations
PIA does not have any additional financial industry activities or affiliations to report.
Custody
PIA does not maintain physical custody of client funds or securities nor does it accept
the delivery of funds or securities in the form of cash or in the name of the firm. However,
PIA will be deemed to have custody of client funds under Rule 206(4)-2 of the Investment
Advisers Act of 1940 because, in certain cases, it has arrangements that authorize it to
have its fees deducted from client accounts. Qualified custodians send quarterly, or more
frequent, account statements. Clients should carefully review these statements.
Code of Ethics, Participation, or Interest in Client Transactions and
Personal Trading
Code of Ethics
PIA has adopted a code of ethics ("CODE") designed to comply with Rule 204A-I under
the Investment Advisors Act of 1940 ("Advisor's Act").
This Code establishes rules of conduct for all employees of Pollock Investment Advisors,
LLC ("PIA") and is designed to, among other things, govern personal securities trading
activities in the accounts of employees. The Code is based upon the principle that PIA and
its employees owe a fiduciary duty to PIA's clients to conduct their affairs, including their
personal securities transactions, in such a manner as to avoid (i) serving their own personal
interests before those of clients (ii) taking inappropriate advantage of their position in the
firm and (iii) any actual or potential conflicts of interest or any abuse of their position of
trust and responsibility.
The Code is designed so that the high ethical standards long maintained by Pollock
Investment Advisors, LLC continue to be applied. The purpose of the Code is to preclude
activities which lead to or give the appearance of conflicts of interest, insider trading and
other forms of prohibited or unethical business conduct. The excellent name and
reputation of our firm continues to be a direct reflection of the conduct of each employee.
A copy of our Code of Ethics is available to any client or prospective client upon request.
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Form ADV Part 2A
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SEC File No.: 801- 71361
January 20, 2026
Personal Trading
The Registrant and investment advisory representative persons associated with the
Registrant are permitted to buy or sell securities that it also recommends to clients
consistent with the Registrant's policies and procedures.
Generally, the Registrant and its associated persons will trade simultaneously with clients
in block trades. If a limited security, the clients' transactions will always go first. Neither
the Registrant nor any associated person shall receive preferential treatment in trading or
receive a better price than the clients if done simultaneously.
The Registrant has adopted a Code of Ethics that sets forth the standards of conduct
expected of its associated persons and requires compliance with applicable securities
laws ("Code of Ethics"). In accordance with Section 204A of the Advisers Act, its Code
of Ethics contains written policies reasonably designed to prevent the unlawful use of
material non-public information by the Registrant or any of its associated persons. The
Code of Ethics also requires that certain of the Registrant's personnel (called "Access
Persons") report their personal securities holdings and transactions and obtain pre-
approval of certain investments such as initial public offerings and limited offerings.
Clients may contact the Registrant to request a copy of its Code of Ethics.
Investment Discretion
PIA provides discretionary management to its clients which means that PIA places the trades
in client accounts without contacting the client prior to making the trade in order to obtain the
client’s permission. PIA’s discretionary authority includes the ability to determine the security
to buy or sell, and the amount of the security to buy or sell. Clients give PIA discretionary
authority when they sign the discretionary advisory agreement with the firm. Clients may limit
the authority by giving PIA written instructions or restrictions.
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
Brokerage Practices
Research and Other Soft Dollar Benefits
PIA exercises discretion over its client account, including brokerage selection. For this PIA
has determined to use SEI as primary custodian and broker-dealer for client trades. PIA will
also use TIAA and/or Fidelity as the custodian for clients' University retirement plan
assets. The brokerage commissions and/or transaction fees charged by SEI, TIAA,
Fidelity or any other designated custodian or broker-dealer are exclusive of and in addition
to the Registrant’s fee.
Factors which the Registrant considers in recommending SEI, TIAA, Fidelity, or any other
custodian or broker-dealer, to clients include their respective financial strength, reputation,
execution, pricing, research, and service. SEI, Fidelity, and TIAA enable the Registrant to
obtain many mutual funds without transaction charges and other securities at nominal
transaction charges. The commission and/or transaction fees charged by SEI, TIAA,
Fidelity, or any other custodian or broker-dealer may be higher or lower than those charged
by other broker-dealers.
In addition, PIA as a member of SEI’s Strategic Advisor Council may receive other benefits
from SEI, which could include the waiver of custodial fees for client accounts, a check
scanner, access to a video facility, lists of SEI vetted providers whose services can be offered
at a discount, entrance to its advisory conference, along with payment of meals and hotel
expenses related to that conference.
The commissions paid by Registrant's clients shall comply with the Registrant's duty to
obtain "best execution." However, a client may pay a commission that is higher than
another qualified broker-dealer might charge to affect the same transaction where the
Registrant determines, in good faith, that the commission is reasonable in relation to the
value of the brokerage and research services received. 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 among others, the value of the research provided, execution
capability, commission rates, and responsiveness. Consistent with the foregoing, while
the Registrant will seek competitive rates, it may not necessarily obtain the lowest
possible commission rates for client transactions.
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
Brokerage for Client Referrals
Registrant does not direct brokerage in exchange for client referrals.
Directed Brokerage
Generally, PIA does not accept client or directed brokerage arrangements.
Trade Aggregation
Trades are consolidated where appropriate in order to obtain consistent execution for all
clients.
Trade Errors
Registrant corrects all trade errors through an Error Account at SEI. If there is a loss due
to a trade error by the Registrant, the Registrant will make the client whole. If there is a
gain in correcting the trade error, the gain will be retained by SEI to offset any future trade
error loss.
Review of Accounts
The Registrant monitors client portfolios as part of an ongoing process while regular account
reviews are conducted on at least an annual basis. Such reviews are conducted by James K.
Pollock, Robert N. Pollock, Jr., and Nicklaus M. Areddy, or their designee(s). All investment
advisory clients are encouraged to discuss their needs, goals, and objectives with the
Registrant and to keep the Registrant informed of any changes thereto. The Registrant shall
contact ongoing investment advisory clients at least annually to review its previous services
and/or recommendations and to discuss the impact resulting from any changes in the client's
investment objectives.
Clients receive regular reports for all accounts from the custodian at least quarterly. In
addition, PIA provides periodic reports to clients as well as select written communication.
The frequency of these reports is based on the individual desires of the client, as well as
the desire of the Registrant to communicate account and/or topical information. Since PIA
sends its own reports directly to clients, we urge clients to compare the custodial statements
with the reports received from PIA for completeness and accuracy.
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Pollock Investment Advisors, LLC
Form ADV Part 2A
Brochure
IARD/CRD No: 153350
SEC File No.: 801- 71361
January 20, 2026
Voting Client Securities
Registrant votes client proxies. As described in our proxy voting policies, PIA casts most
of its proxy votes, particularly on routine matters, in accordance with the company
management recommendations unless we believe that the position of the management of a
company is not be in the best interest of shareholders. As a general rule, PIA votes against any
proposals which would reduce the rights or options of shareholders, reduce shareholder
influence over the board of directors and management, reduce the alignment of interests
between management and shareholders, or reduce the value of shareholders’ investments.
PIA generally votes in favor of ratification of accountants, changing corporate names and
similar matters. It generally withholds voting authority on unspecified ‘other matters’ that
are listed on a proxy card. Records concerning proxy votes will be maintained in
Registrant’s office and are available for viewing upon client request.
Financial Information
PIA has not been the subject of a bankruptcy petition at any time during the past ten years.
PIA has no financial circumstances to report.
Disciplinary Information
Neither PIA, its employees, nor its owners, James K. Pollock, Robert N. Pollock, Jr. and
Nicklaus M. Areddy, have any disciplinary information to report.
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