RACHOR INVESTMENT ADVISORY SERVICES, LLC

Part 2A of Form ADV: Firm Brochure Rachor Investment Advisory Services, LLC 120 N. Bridge Street, Suite A P.O. Box 10 Linden, MI 48451 Telephone: 810-732-7777 Email: helpme@rias.net Website: www.rias.net October 8, 2025 This brochure provides information about the qualifications and business practices of Rachor Investment Advisory Services, LLC. If you have any questions about the contents of this brochure, please contact us at 810-732-7777 or helpme@rias.net. 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 Rachor Investment Advisory Services, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 105495.  ITEM 2: MATERIAL CHANGES In this section, we discuss only material changes since the last annual update of our Brochure. There are no material changes to report at this time. Each year, pursuant to SEC rules, we will ensure that you receive a summary of all material changes, if any, to this and subsequent Brochures within 120 days of the close of our fiscal year. We may also provide other ongoing disclosure information about material changes, as necessary. We will provide you our brochure, at any time, without charge. Additional Information To request a copy of our Brochure, please contact us at 810-732-7777 or helpme@rias.net. Additional information about Rachor Investment Advisory Services, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 105495. The SEC’s web site also provides information about any persons affiliated with us who are registered, or are required to be registered, as one of our investment adviser representatives of us. Part 2A of Form ADV ii Rachor Investment Advisory Services, LLC  ITEM 3: TABLE OF CONTENTS COVER PAGE .................................................................................................................... i ITEM 2: MATERIAL CHANGES ......................................................................................... ii ITEM 3: TABLE OF CONTENTS ........................................................................................iii ITEM 4: ADVISORY BUSINESS ........................................................................................ 1 ITEM 5: FEES AND COMPENSATION .............................................................................. 3 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............. 7 ITEM 7: TYPES OF CLIENTS ............................................................................................ 7 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 7 ITEM 9: DISCIPLINARY INFORMATION ......................................................................... 12 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................ 12 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ............................................... 13 ITEM 12: BROKERAGE PRACTICES .............................................................................. 14 ITEM 13: REVIEW OF ACCOUNTS ................................................................................ 16 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION .................................. 17 ITEM 15: CUSTODY ........................................................................................................ 17 ITEM 16: INVESTMENT DISCRETION ........................................................................... 18 ITEM 17: VOTING CLIENT SECURITIES ........................................................................ 18 ITEM 18: FINANCIAL INFORMATION ............................................................................. 18 Part 2A of Form ADV iii Rachor Investment Advisory Services, LLC  ITEM 4: ADVISORY BUSINESS Rachor Investment Advisory Services, LLC (referred to in this Brochure as "Rachor," "us," "we," or "our") is a federally registered investment adviser located in Linden, Michigan. Rachor through our predecessors began conducting business in 1984. We are currently wholly owned by RIAS Holding Company Incorporated; whose sole shareholder is Tod G. Fisher. Our Advisory Services Rachor offers personalized discretionary and nondiscretionary investment advisory services to clients based on the client’s individual investment goals, financial objectives, and risk tolerance. As explained in more detail below, our Diversified Strategy is offered on a discretionary basis while the Concentrated Strategy is offered on a nondiscretionary basis through third party private money managers. We meet with each client before any assets are invested to develop, with the client, the asset allocation referred to as the investment style, for each of the client’s account(s). We also educate our clients with regard to the long-term nature of the Diversified and Concentrated Strategies (the “Strategies”). After consultation with our client, the assets are invested in accordance with the agreed upon investment style(s). Client requests for restrictions on investing in certain securities or types of securities will be implemented on a case-by-case basis, although it is anticipated that such restrictions may inhibit Rachor’s ability to implement either Strategy. We offer financial planning services to our clients as part of our investment advisory services. These services may include, but are not limited to:  lifetime cash flow planning (written/online year-by-year hypothetical plan/projection, including goals and objectives),  estate planning, with the assistance of your attorney(s), including gift and wealth transfer planning, tax planning, with the assistance of your accountant(s) and/or attorney(s),  insurance planning, with the assistance of your insurance agent(s), and   other financial matters that may arise (mortgages, student loans, closely held businesses). Financial planning services are available on an as requested or as needed basis and are provided at no extra expense for our investment advisory clients. We act under the fiduciary duty of care and loyalty applicable to a registered investment adviser. Our duty of care means we provide investment advice, based on the client’s objectives, in the best interest of our client. Under the duty of loyalty, we Part 2A of Form ADV 1 Rachor Investment Advisory Services, LLC  must eliminate or make full and fair disclosure of our conflicts of interests which might incline us—consciously or unconsciously—to render advice which is not disinterested. If we manage a joint account on your behalf (e.g., husband and wife, parent, and child, etc.), our services will be based upon the identified financial needs and objectives that all or any one of the persons executing our agreement (collectively, the “Joint Clients”) communicate to us. Joint Clients are collectively responsible for determining and advising us if only one or more of the Joint Clients is permitted to give us instructions, authorizations, or to otherwise control the account. Unless we are directed otherwise in writing, we are permitted to rely upon any authorization, instruction, or direction from any one of the Joint Clients until this authority is limited or revoked in a written notice delivered to us signed by all Joint Clients. Diversified Strategy  Our investment advisory service includes ongoing supervisory and management services of the client assets and trading securities on a discretionary basis. This means that we determine the securities to buy and sell for the client’s account without obtaining specific consent prior to each transaction.  Diversified Strategies are diversified, primarily exchange traded funds (“ETFs”), mutual funds, stocks and/or bonds. The strategies have low rates of turnover (buying and selling), and allow for aggressive, moderate, conservative, and defensive allocations to increase/decrease volatility in accordance with the client’s objectives and guidelines. Concentrated Strategy offered through Private Money Managers  For certain clients, the investment advisory services include conducting due diligence upon and recommending, on a non-discretionary basis, third party managers to manage parts of such clients’ portfolios. Such Private Money Managers are typically dually registered as investment adviser representatives and registered representatives of an “unaffiliated financial firm.”  The Private Money Managers’ strategies are not diversified having a relatively small number of holdings, typically stocks. The strategies have a very high rate of turnover (active buying and selling), are expensive and volatile and in the case of non-qualified accounts, may use leverage. Funds invested in a “Concentrated” strategy should be considered only for “long-term” investing.  Clients receive a separate Part 2A of Form ADV for each unaffiliated financial firm and a Part 2B of Form ADV for each Private Money Manager before or at the time the client engages the Private Money Manager. Part 2A of Form ADV 2 Rachor Investment Advisory Services, LLC  Advisory Services for Qualified Plans As part of our services to qualified retirement plans, we act as a fiduciary as defined in Sections 3(21)(A) of ERISA to such plans. If the “responsible plan fiduciary,” as defined in ERISA Section 402(a)(2)) engages us as a 3(21) advisor, we will review the investment options available to the plan and recommend an ERISA Section 3(38) investment manager (the “3(38) Manager”) to act as an investment manager for such qualified ERISA plan. As a 3(21) advisor, we will not have discretion or the authority to invest and reinvest plan assets or to engage the recommended 3(38) Manager on the plan’s behalf. It is ultimately the responsible plan fiduciary’s duty to select and give the 3(38) Manager discretionary authority to manage the plan’s assets. This means that the responsible plan fiduciary shifts its fiduciary responsibility to the 3(38) Manager for the selection of the plan’s investments. A tri-party investment advisory agreement between the responsible plan fiduciary, the 3(38) Manager and us will govern this relationship. Based on the plan’s investment policy statement or other guidelines established by the plan we (a) recommend the qualified default investment alternative (“QDIA”) for plan participants that fail to direct the investment in their accounts, and provide reports, information and recommendations, to assist in the monitoring of the investments; (b) recommend and monitor the “Model Portfolios created by the 3(38) Manager. If requested in the tri-party investment advisory agreement, we will provide additional non-ERISA fiduciary services such as investment education to the responsible plan fiduciary, assist in selecting and reviewing other service providers, and conduct group plan participant education and enrollment meetings. Assets Under Management As of December 31, 2024, we managed $205,615,996 in client assets on a discretionary basis. We have an additional $234,600,225 under advisement as of December 31, 2024. ITEM 5: FEES AND COMPENSATION Diversified and Concentrated Strategy Fees Rachor establishes the specific manner in which we charge our fees in the written investment advisory agreement signed with us prior to beginning our relationship with the client. Rachor standard fee schedule for assets invested in the Diversified and Concentrated Strategies is as follows: Assets Under Management On the first $2,500,000 On the next $2,500,000 On the next $2,500,000 On the next $2,500,000 On the next $2,500,000 Total Annual Fee 1.0000% 0.5000% 0.2500% 0.1250% 0.0625% Part 2A of Form ADV 3 Rachor Investment Advisory Services, LLC  On the next $2,500,000 On the next $2,500,000 On the next $2,500,000 On the next $2,500,000 and greater 0.0313% 0.0157% 0.0079% 0.0040% Our fees are billed, in advance, at the beginning of each calendar quarter, based upon the value of the client's account, including cash and cash equivalents, at the close of business on the last day of the calendar quarter, as reported in our portfolio accounting software. If the investment advisory agreement is executed at any time other than the first day of a calendar quarter, our fees will be pro-rated for the number of days which the agreement was in effect. Such pro-rata adjustments are not made when a client adds or withdraws assets to or from their account. Clients generally authorize Rachor, in the investment advisory agreement, to bill our fees to the custodian of his or her account and grants the custodian permission to directly debit our fees from the account. If necessary, we may liquidate investments in the client’s account to pay our fee. Rachor will provide notice for investment advisory fees to each client, the notice will be in the form of an invoice. If the client provides us such authorization, we will provide the custodian with the request for payment and the client will receive periodic statements from the custodian showing each fee deduction from his or her account. Advisory Services for Qualified Plans The 3(38) Manager determines its fee, and the fee arrangement will be agreed upon in the tri-party investment advisory agreement between the responsible plan fiduciary, the 3(38) Manager and Rachor. The 3(38) Manager utilizes both tiered and breakpoint pricing models. In tiered pricing, specified rates are applied to assets within each of the rate brackets and added together to make up the fee. In breakpoint pricing, once the highest asset bracket is reached, the rate assigned to that bracket is applied to all assets. Management fees for qualified plans are billed quarterly, in advance. Rachor charges a flat annual fee of 0.55%. Generally, the fee schedule for the 3(38) Manager and the combined annual fee is as follows: Assets Under Management 3(38) Manager Annual Fee Combined Annual Fee On the first $1,000,000 0.20% 0.75% $1,000,001 to $5,000,000 0.15% 0.70% $5,000,001 to $10,000,000 0.08% 0.63% Over $10,000,000 0.05% 0.60% Part 2A of Form ADV 4 Rachor Investment Advisory Services, LLC  Additional Information We retain the discretion to negotiate alternative fees on a client-by-client basis. The specific annual fee schedule is identified in the investment advisory agreement between Rachor and each client. We may change our fees at any time, and we always have the right to amend our fees. Any changes will become effective after we provide the client with 30 days’ prior written notice unless the client terminates our agreement. We provide employees, some family members, and friends the same services for a fee lower than those charged to clients that are not related to the firm. These fees are not available to our general clients. A client agreement may be terminated at any time, by either party, for any reason upon receipt of written notice. Upon termination, Rachor will promptly refund the client a pro-rata portion of the prepaid, unearned fees, calculated to the date of termination. Except for any advisory fees due and owing upon termination, Rachor will not be entitled to any additional termination charge or termination fee. Termination of our agreement shall not affect liabilities or obligations incurred or arising from transactions initiated under our agreement prior to the termination date, such as the purchase of investments by us for the client’s account. After the termination date, Rachor will have no further duties or obligations to the client under our agreement. Our agreement will not terminate in the event of the client’s death, disability, or incompetency. However, in the event of client’s death, disability or incompetency, client’s executor, guardian, attorney-in-fact, or other authorized representative may terminate our agreement by giving us written notice, with such termination being effective upon our receipt of such notice. Additional Fees and Expenses In addition to Rachor’s investment advisory fees, clients invested in the Diversified and Concentrated Strategies will incur the following additional costs of third- party professionals engaged to assist Rachor in helping the client achieve their investment objectives. These services may include accounting, legal, tax or actuarial services. Diversified Strategy Fees  The ETFs we generally use, in connection with assets invested in the Diversified Strategy, charge their shareholders various advisory fees and expenses associated with the establishment and operation of the funds. These fees will generally include a management fee, shareholder servicing, and other fund expenses. Consequently, for any type of fund investment, it is important for you to understand that you are directly and indirectly paying two levels of advisory fees and expenses: one level of fees to the fund and one level of advisory fees to us. Part 2A of Form ADV 5 Rachor Investment Advisory Services, LLC   Rachor utilizes Dimensional Fund Advisors (“DFA”) funds to implement the Diversified Strategies. When selecting a fund family, we will consider a variety of factors including its expense ratios and asset class attributions. The asset allocation recommended to the client, may vary depending on the client’s needs, as described under “Item 8: Methods of Analysis, Investment Strategies and Risk of Loss.”  While clients could invest in other funds directly, without our services, in such cases, a client would not receive the services provided by our firm which are designed, among other things to assist the client in determining which funds are most appropriate to the client’s financial condition and objectives. Qualified Plans In addition to the fee arrangement outlined in the tri-party agreement, plans are also subject to custodian, brokerage, and third-party administration fees, and other expenses incurred in connection with the services of these third parties to the plan. Concentrated Strategy offered through Private Money Managers Fees  For assets invested in accordance with the Concentrated Strategy, the fees of the Private Money Managers recommended by Rachor, together with any custodian, brokerage and other expenses such as an “activity assessment fee” incurred in connection with their services are more fully described in the unaffiliated financial firm’s Part 2A of Form ADV which the client receives before or at the time the Private Money Manager is engaged by the client.  If a non-retirement account is invested in the Concentrated Strategy, the Private Money Manager will typically charge the client a commission-based fee, which is charged on each transaction entered into which is taken out of the client’s account at the time of the trade. Such commissions are approximately range from 1.5% to 2% of the trade value per transaction. Certain non-retirement accounts also pay the broker a transaction fee on a sliding scale of up to four cents per share.  Historically, the turnover in the accounts managed by the Private Money Managers has been high and the annual commissions charged by such Private Money Managers has typically ranged from 3% to 6% (sometimes significantly higher) of the average account balance. Further, to the extent a Private Money Manager uses leverage or sells securities short, clients will pay interest on margin loan balances, while interest will not be paid on cash balances maintained in escrow to repurchase short position securities. Both the commissions charged, and the turnover of the portfolios managed by Private Money Managers are expected to continue to be high.  If a retirement account (e.g., IRA, Roth IRA, 401(k), etc.) is invested in the Concentrated Strategy, the Private Money Manager will typically charge a fee Part 2A of Form ADV 6 Rachor Investment Advisory Services, LLC  based on a percentage of assets under management. The charges, which range from 2.25% to 2.5% annually, are billed and taken out of the client’s account on a monthly basis. As explained in the unaffiliated financial firm’s Part 2A of Form ADV, this fee covers the Private Money Managers’ investment advisory services, most execution costs, and other services, such as custody, recordkeeping, and reporting. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT Rachor does not charge performance-based fees and does not provide side-by- side management of client accounts. A performance fee arrangement is a method of compensating an investment adviser on the basis of a share of the gains or appreciation of the client’s assets under management. Side-by-side management is when an investment adviser manages mutual funds and private funds, “particularly when managed pursuant to similar strategies and/or by the same portfolio managers.” ITEM 7: TYPES OF CLIENTS Rachor offers advisory services to the following types of clients:  High net worth individuals, Individuals (other than high net worth individuals), and Trusts;  Qualified Retirement Plans (i.e., 401(k), pension, church plans, etc.);  Charitable organizations; and  Corporations or other businesses not listed above. Minimum Account Requirements We do not require a minimum account size for investing with Rachor. However, the recommended, but not required, minimum per client household is $100,000. We generally waive this requirement if, for example, you anticipate future additional assets, have other related accounts, or we have a historical relationship. Private Money Managers impose minimum account or investment thresholds. The Private Money Managers may also restrict clients from investing all of their investable assets in their Concentrated Strategies. With some exceptions, Rachor recommends that a client invests a minimum of $50,000 when opening accounts to be managed by Private Money Managers. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS The investment advisory services include: (1) making asset allocation recommendations and placing trades, on a discretionary basis, to implement such Part 2A of Form ADV 7 Rachor Investment Advisory Services, LLC  recommendations as part of a Diversified Strategy; and (2) for certain clients, conducting due diligence upon and recommending Private Money Managers to manage parts of such clients’ portfolios as part of a Concentrated Strategy. Methods of Analysis When managing Rachor’s Diversified Strategy, we utilize DFA academic research to determine which asset class attributions should be over weighted, such as:  Equity exposure versus fixed income exposure International equity exposure versus domestic equity exposure   Small cap equity exposure versus large cap equity exposure  Value equity exposure versus growth equity exposure  Real estate exposure  Profitability and momentum within equity exposures Rachor also considers the effects of transaction costs associated with trading specific investment products and we work to reduce the effects of these costs on a portfolio’s performance. Advisory Services for Qualified Plans Qualified Plan clients should refer to the ERISA Section 3(38) investment manager’s Part 2A of Form ADV for a description of the methods of analysis and risks pertaining to that manager’s strategy or strategies. Investment Strategies Diversified Strategy  In the case of the Diversified Strategy, Rachor’s advice is based on an analysis of past performance and risk factors for various equity and fixed income asset classes, and an understanding of each client’s short-term, mid- term, and long-term expected withdrawal rate. Rachor generally recommends using a “less aggressive” asset class for portions of a client’s short-term and mid-term expected withdrawal rates. Each client’s own level of comfort with equity asset classes may also affect Rachor’s recommendations. Concentrated Strategy offered through Private Money Managers  In the case of the Concentrated Strategy, Rachor’s advice is based on an analysis of Private Money Manager’s past performance, risk factors, the lack of commonly held positions between Private Money Managers, the number of Part 2A of Form ADV 8 Rachor Investment Advisory Services, LLC  positions held over time in managed portfolios, and (when applicable) the amount of leverage historically employed. Risk of Loss All investing involves a risk of loss that clients should be prepared to bear. Obtaining higher rates of return on investments typically entails accepting higher levels of risk. We work with you to attempt to identify the balance of risks and rewards that is appropriate and comfortable for you. However, it is still your responsibility to ask questions if you do not fully understand the risks associated with any investment or investment strategy. Additional risks associated include:  Market Risk. The price of a security (e.g., ETFs and mutual funds) may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security's particular underlying circumstances. For example, political, economic, and social conditions have the ability to trigger market events.  Cybersecurity. The computer systems, network and devices used by Rachor and service providers to us and our clients, to conduct routine business operations, employ a variety of protections designed to prevent damage or interruption. Despite the various protections utilized systems, networks, or devices potentially can be breached. 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. Diversified Strategy  In the case of the Diversified Strategy, securities are purchased with the idea of holding them in a client's account for a year or longer. A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, the values of securities may decline sharply in value before any decision to sell (if at all) is made.  International securities. Investments in international market securities include exposure to risks such as currency fluctuations, foreign taxes and regulations, and the potential for illiquid markets and political instability. Part 2A of Form ADV 9 Rachor Investment Advisory Services, LLC   Exchange-Traded Funds. ETFs face market-trading risks, including the potential lack of an active market for shares, losses from trading in the secondary markets and disruption in the creation/redemption process of the ETF. Any of these factors may lead to liquidity risk and/or the fund's shares trading at either a premium or a discount to its "net asset value".  Performance of Underlying Managers. We select ETFs and mutual funds, in the client's portfolios. However, we depend on the Underlying Manager of such funds to select individual investments in accordance with their stated investment strategy and on their decisions regarding the allocation of the fund's assets.  Real Estate Industry. The value of securities in the real estate industry can be affected by changes in real estate values and rental income, property taxes, and tax and regulatory requirements. Also, the value of securities in the real estate industry may decline with changes in interest rates. Investing in REITs and REIT-like entities, including investing in funds that hold these types of entities, involves certain unique risks in addition to those risks associated with investing in the real estate industry in general. REITs and REIT-like entities are dependent upon management skill, may not be diversified, and are subject to heavy cash flow dependency and self-liquidation. Also, because REITs and REIT-like entities typically are invested in a limited number of projects or in a particular market segment, these entities are more susceptible to adverse developments affecting a single project or market segment than more broadly diversified investments. Concentrated Strategy through Private Money Managers  Clients should refer to Part 2A of Form ADV of the unaffiliated financial firm for a description of the risks pertaining to the Private Money Managers’ strategies, however, common risks associated with such strategies are described below.  In the case of the Concentrated Strategy, Rachor will not have a role in the management of accounts managed by Private Money Managers, and it will likely not have the opportunity to evaluate in advance the specific decisions made by such managers. As a result, the rates of return to clients will primarily depend upon the choice of investments and other investment and management decisions of Private Money Managers, and returns could be adversely affected by the unfavorable performance of such managers. Rachor depends on third party managers to develop the appropriate systems and procedures to control investment and operational risks, either of which could cause client accounts to suffer financial losses.  Long-term purchases. Certain Private Money Managers purchase securities with the idea of holding them in the client's account for a year or longer. A risk in a long-term purchase strategy is that by holding a security for this length of Part 2A of Form ADV 10 Rachor Investment Advisory Services, LLC  time, the manager may not take advantage of short-term gains that could be profitable to a client. Moreover, if predictions are incorrect, a security may decline sharply in value before a decision to sell is made.  Margin transactions. Certain Private Money Managers will purchase stocks for client portfolios with money borrowed from a broker-dealer. This allows the client to purchase more stock than they would be able to with their available cash and/or without selling other holdings. A risk in margin trading is that, in volatile markets, securities prices can fall very quickly. If the value of the securities in a client account minus what the client owes the broker-dealer falls below a certain level, the broker will issue a “margin call,” and the client will be required to sell its position in the security purchased on margin or add more cash to their account. In some circumstances, clients may lose more money than they originally invested.  Short sales. Certain Private Money Managers may employ short sales. Shares of a stock are borrowed for the portfolio from someone who owns the stock on a promise to return the shares at a future date. Those borrowed shares are then sold. On a future date, the same stock is bought, and the shares are returned to the original owner. Short selling may be engaged in expectation that the stock will go down in price after the shares are borrowed and sold. If the manager is correct and the stock price has gone down since the shares were borrowed from the original owner, the client account realizes the profit. Alternatively, a manager may use short positions to reduce the risk of certain long positions. Short selling results in some unique risks: o Losses can be infinite. A short sale loses when the stock price rises, and a stock is not limited (at least, theoretically) in how high it can go. For example, if a manager shorts 100 shares at $50 each, hoping to make a profit but the shares increase to $75 per share, the client would lose $2,500. On the other hand, the price of a stock cannot fall below $0, which limits the client’s potential upside. o Short squeezes can wring out profits. As stock prices increase, short seller losses may also increase as short sellers rush to buy the stock to cover their positions. This increase in demand, may in turn further drive prices up, increasing client losses. o Even if a manager is correct in determining that the price of a stock will decline, the client runs the risk of incorrectly determining when the decline will take place, i.e., they could be right too soon. Although a company may be overvalued, it could conceivably take some time for the price to come down; during which the client is vulnerable to interest payments to the stock lender, margin calls, and investment losses. o History has shown that over the long term, most stocks appreciate. Even if a company barely improves over time, inflation should drive its share price up somewhat. In fact, short selling may not be appropriate in times of Part 2A of Form ADV 11 Rachor Investment Advisory Services, LLC  inflation for that very reason, as prices may adjust upwards regardless of the value of the stock. There is therefore a risk that inflation could cause investment losses, even if the manager were correct in their assessment about the company issuing the stock.  Option writing. Options may be used as an investment strategy in the accounts managed by certain Private Money Managers. An option is a contract that gives the buyer or seller the right, but not the obligation, to buy or sell an asset (such as a share of stock) at a specific price on or before a certain date. The two types of options are calls and puts. A call gives the holder the right to buy an asset at a certain price within a specific period of time. A call is likely to be bought if it is anticipated that the stock will increase substantially before the option expires. A put gives the holder the right to sell an asset at a certain price within a specific period of time. A put is likely to be bought if it is anticipated that the price of the stock will fall before the option expires. Purchasing put and call options, as well as writing such options, are highly specialized activities and entail greater than ordinary investment risks. ITEM 9: DISCIPLINARY INFORMATION Rachor is required to disclose any legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Our firm and our management personnel have no reportable disciplinary events to disclose. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Rachor is licensed in the State of Michigan as a public accounting firm. Michigan law requires that any business owned 50% or more by a C.P.A. (including via attribution) that provides accounting services be licensed as a public accounting firm. Rachor only provides limited accounting services including tax planning and some tax preparation. Rachor does not provide attestation (audit, review, compilation) services. Rachor does not charge fees for accounting services. As described under “Item 5: Fees and Compensation,” Rachor only earns fees from providing investment advisory services. Both Tod G. Fisher, Rachor’s CEO and Bridget Walter are licensed in the State of Michigan as a Certified Public Accountant (“C.P.A.”). Tod Fisher and Patricia Walton serve as board members for certain foundations where the foundation is also a client of Rachor. As a representative of Rachor, our advisers provide the board of directors with an investment review, performance returns and investment recommendations, including recommendations to engage certain Private Money Managers. Decisions to engage Private Money Managers, open new accounts or change current accounts are at the discretion of the foundation’s officers and board of directors. When the board of directors vote on whether or not to continue to retain Rachor Part 2A of Form ADV 12 Rachor Investment Advisory Services, LLC  as an investment adviser to the foundation, our advisers abstain from voting to mitigate the conflict of interest. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Rachor has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our advisers and employees (collectively, “supervised persons”), including compliance with applicable state and federal securities laws, rules, and regulations. Rachor and our supervised persons owe a duty of loyalty, fairness, and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. We endeavor to follow not just the letter of the law, but the spirit of the law. Our Code also provides for oversight, enforcement, and recordkeeping provisions. Any supervised person of Rachor who (i) is involved in making securities recommendations to clients, or (ii) has access to such recommendations that are nonpublic, is considered an “access person” for purposes of our Code of Ethics. Our Code of Ethics includes policies and procedures for the submission, by the firm’s access persons, for review all reportable securities over which access person has any beneficial ownership interest, including accounts held by immediate family members sharing the same household. Access persons provide quarterly reportable securities transactions as well as initial and annual reportable securities holdings reports. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Rachor and our access persons may buy or sell, for their personal accounts, securities identical to those that we buy and sell for our clients, pursuant to the Diversified Strategy. This is viewed as presenting a potential conflict of interest; however, we believe the potential for a conflict is mitigated as the securities bought, sold, or held are publicly traded and widely held and the amounts bought, sold, or held by Rachor or our access persons are too small to affect the market. In addition, when appropriate, we will aggregate the purchase and sale transactions for Rachor or our access persons with client accounts. Additional information regarding the aggregation of orders may be found below under “Item 12: Brokerage Practices.” Our Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of our access persons will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing access persons to invest for their own accounts. Generally, Rachor does not recommend a Private Money Manager to a client unless the manager has a five-year performance history record on file with us. We obtain this record, when our access person(s), invest their assets with a new Private Part 2A of Form ADV 13 Rachor Investment Advisory Services, LLC  Money Manager who is made available on the Concentrated Strategy platform. Personal investing with a Private Money Manager, limited private offering or an initial public offering requires the prior approval of the Chief Compliance Officer. The Chief Compliance Officer seeks prior approval from the Compliance Director. A copy of our Code of Ethics is available to our advisory clients and prospective clients, at no charge. You may request a copy by email sent to helpme@rias.net, or by calling us at 810-732-7777. ITEM 12: BROKERAGE PRACTICES With regard to client assets invested in accordance with the Diversified Strategy, Rachor recommends and has established a relationship with Raymond James & Associates, Inc., member New York Stock Exchange/SIPC for custodial and brokerage services. We are independently owned and operated and are not affiliated with Raymond James. Raymond James will hold client assets in a brokerage account and buy and sell securities in the client’s account upon our instruction. While we recommend that clients use Raymond James as custodian/broker, clients will decide whether to do so and will open their account with Raymond James by entering into an account agreement directly with them. Clients, including qualified plans, are under no obligation to engage Raymond James and are free to select their own broker-dealer/custodian. The client will be responsible for negotiating commission rates with the chosen broker or custodian in such circumstances. Clients should be aware that directed brokerage arrangements will prohibit Rachor from placing security transactions on the client’s behalf. In addition, Rachor is unable to seek best execution, and therefore, clients may pay higher transaction costs than available elsewhere. For our clients’ accounts that Raymond James maintains, Raymond James generally does not charge the client separately for custody services but is compensated by charging clients commissions or other fees on trades that it executes or that settle into the client’s Raymond James account. Certain trades (for example, ETFs) may not incur Raymond James commissions or transaction fees. Clients may designate a cash sweep option with respect to their accounts. Raymond James and its affiliates will be compensated by earning interest on the uninvested cash in the Raymond James Bank Deposit Program or other sweep option selected by the client. Although we are not required to execute all trades through Raymond James, Rachor believes that trade away fees and/or other costs may negate any savings that could be received by using a different broker. In recommending Raymond James, we consider not only the commission rate and execution capabilities, financial responsibility and responsiveness to instructions, but also the full range of services provided by Raymond James, including back-office, administrative, custodial support, reporting and related services. These services include software and other technology that: Part 2A of Form ADV 14 Rachor Investment Advisory Services, LLC   provide us access to client account data, such as trade confirmations and account statements; facilitate trade execution;   provide pricing and other market data; facilitate payment of our fees from our clients’ accounts; and   assist with back-office functions, recordkeeping, and client reporting. Accordingly, clients may pay commissions in excess of those which Raymond James (or another broker) may charge for transactional services alone, in recognition of the additional services provided. As a result, we receive a benefit because we do not have to produce or pay for certain products or services being provided by Raymond James. This benefit provides an incentive to recommend Raymond James based on our interest in receiving certain products or services, thus giving rise to a conflict of interest. We believe this conflict is mitigated because we must determine in good faith that the amount of any commission paid is reasonable in relation to the value of the brokerage and research services provided, viewed in terms either of a particular transaction or our overall responsibilities with respect to accounts as to which we exercise investment discretion. In addition, we have an obligation to make a determination that any services we receive provide lawful and appropriate assistance in the performance of our investment decision-making responsibilities. Soft Dollar Arrangements We have not and do not intend to enter into any contractual third-party soft-dollar arrangements, such as committing to place a specific level of brokerage with a specific firm in return for which the brokerage firm will pay for various research related products or services for us that are generally available for cash purchase. However, as noted above, Raymond James does provide us certain services that assist us in managing and administering clients’ accounts but will not necessarily directly benefit a client’s specific account. Aggregation of Orders Investment advisers may aggregate (“block”) the purchase or sale of securities for various client accounts for their administrative convenience and, in some transactions, to obtain better execution for the aggregated order than might be achieved by processing each of the transactions separately. As discussed above, when Rachor places a block order, Rachor and our access persons may also partake in the transaction. Each account that participates in a block order will participate at the average share price for all transactions ordered by Rachor in that security on a given business day. Normal commission rates apply at the respective account level. Such aggregation of orders is done under the expectation that it will, on average, improve Part 2A of Form ADV 15 Rachor Investment Advisory Services, LLC  execution. If an aggregated order is not filled in its entirety, it will be allocated among participating accounts on a pro rata basis. Under certain circumstances we do not block trades such as:  transactions for open-end mutual funds which buy and sell at net asset values set by the mutual fund at the end of each trading day; to invest funds that are deposited into client accounts throughout the day;   to raise cash for distribution or transfer as requested, as these requests will be filled upon receipt or as soon as administratively possible; and  client directed trades. Dimensional Fund Advisers As stated above under “Item 8: Methods of Analysis, Investment Strategies and Risk of Loss,” Rachor invests client assets in ETFs and mutual funds advised by Dimensional Fund Advisors. DFA provides Rachor with resources such as educational events, ability to access academic research, and marketing support. None of the service provided by DFA is dependent on investing a specified amount of client assets in their funds. ITEM 13: REVIEW OF ACCOUNTS Our advisers review all client accounts at least annually. Accounts are reviewed in the context of each client's stated investment style. In addition, we monitor the accounts, managed in our Diversified Strategies, monthly for excessive cash and quarterly for opportunities to rebalance the account to the client’s agreed upon asset allocation. Additional reviews may be triggered by material changes in the client's individual circumstances. Clients are provided with activity and securities holdings reports for each of their accounts, on at least a quarterly basis, from their account custodian. As agreed upon with the client, Rachor provides a monthly or quarterly report for each of the Strategies the client is invested in. The report includes the market value and the performance for each of the client's accounts. We urge you to review your statements carefully and compare such official custodial records to your statements that we provide to you as described below in “Item 15: Custody.” As described in more detail under “Item 4: Advisory Business,” we may be engaged as a 3(21) advisor to qualified retirement plans. We will review the investment options, including the Model Portfolios, available to the plan, on a periodic basis. Upon request, we will provide reports to the responsible plan fiduciary. Part 2A of Form ADV 16 Rachor Investment Advisory Services, LLC  ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Rachor does not engage promoters or pay related or unaffiliated persons for referring clients to Rachor. Rachor will, when appropriate or requested, recommend unaffiliated professionals such as CPAs and attorneys to our clients. We may also receive referrals from these same unaffiliated professionals or others for our services. While recommending other professionals that may refer clients to us presents a conflict of interest, you are under no obligation to act upon our recommendations and are not required to engage these professionals. You retain absolute discretion over the decision to engage other professionals and may accept or reject any of our recommendations. Rachor does not accept or allow our related persons to accept any form of compensation, including cash, sales awards, or other prizes, from a non-client in conjunction with the advisory services we provide to our clients. Rachor's compensation comes from clients only. ITEM 15: CUSTODY Rachor does not custody client funds or securities, but requires they be held by a qualified custodian. We previously disclosed under "Item 5: Fees and Compensation" of this Brochure that our firm debits advisory fees directly from client accounts. If a client provides us with this authorization, we are deemed to have constructive custody of the client’s account. We are also deemed to have custody when a client establishes a letter of instruction or other standing asset transfer authorization arrangement with their qualified custodian, authorizing us to disburse funds to one or more third parties specifically designated by the client. In addition, if a client and/or client trust retains an officer or employee of Rachor as trustee and/or durable power of attorney, we are deemed to have custody. In the event that a client and/or client trust has retained or retains an officer or employee of Rachor as trustee and/or durable power of attorney, and Rachor acts as investment advisor to the client and/or client trust, the trust beneficiary(ies) or trust grantor(s) will receive statements directly from the account custodian or brokerage firm. Under these circumstances, as required by the custody rule, we have engaged an independent public accounting firm to conduct surprise examinations of these accounts. At least quarterly, clients will receive statements from the qualified custodian that holds and maintains their investment assets. The statement shows all transactions within each account during the reporting period. In addition to the periodic statements that clients receive directly from their custodians, as described above in “Item 13: Review of Accounts,” Rachor sends monthly or quarterly statements to our clients. Our statements may vary from custodial statements due to items such as the timing of posting and settlement of transactions, and reporting dates. You should notify us promptly if you do not receive statements from all your account custodian(s) on at least a quarterly basis. We urge you to carefully compare the account balances contained in Part 2A of Form ADV 17 Rachor Investment Advisory Services, LLC  the official custodial records to the balances reflected on your statement received directly from us, as described above in the “Item 13: Review of Accounts.” Clients should contact Rachor directly if they believe that there may be an error in their fee calculation or inconsistencies with the custodian’s statements. ITEM 16: INVESTMENT DISCRETION When clients hire Rachor to provide discretionary investment advisory services, through our Diversified Strategies, Rachor places trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Rachor’s discretionary authority includes the ability to do the following without contacting the client:  determine the security to buy or sell; and/or  determine the amount of the security to buy or sell. Clients grant Rachor discretionary trading authority when they sign a discretionary advisory agreement and may limit this authority by giving Rachor written instructions. Clients may also change/amend such limitations by once again providing Rachor with written instructions. As described above under “Item 4 Advisory Business,” we recommend the Concentrated Strategies on a nondiscretionary basis through third party private money managers. ITEM 17: VOTING CLIENT SECURITIES As a matter of firm policy, Rachor does not accept authorization for responding to proxies or offer advice with respect to annual or special meetings of shareholders of securities held in client accounts. Clients will arrange and are responsible for instructing each custodian on where his or her proxy solicitation materials should be forwarded for response and voting. ITEM 18: FINANCIAL INFORMATION Rachor has never been the subject of a bankruptcy proceeding, does not solicit fees of $1,200 or more six months or more in advance, nor do we have any financial commitments that would impair our ability to meet contractual or fiduciary commitments to you. 31639749 Part 2A of Form ADV 18 Rachor Investment Advisory Services, LLC