Overview
- Headquarters
- Linden, MI
- Average Client Assets
- $1.2 million
- SEC CRD Number
- 105495
Fee Structure
Primary Fee Schedule (2026 ADV PART 2A)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $2,500,000 | 1.00% |
| $2,500,001 | $5,000,000 | 0.50% |
| $5,000,001 | $7,500,000 | 0.25% |
| $7,500,001 | $10,000,000 | 0.12% |
| $10,000,001 | $12,500,000 | 0.06% |
| $12,500,001 | $15,000,000 | 0.03% |
| $15,000,001 | $17,500,000 | 0.02% |
| $17,500,001 | $20,000,000 | 0.01% |
| $20,000,001 | and above | 0.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $37,500 | 0.75% |
| $10 million | $46,875 | 0.47% |
| $50 million | $51,010 | 0.10% |
| $100 million | $53,010 | 0.05% |
Clients
- HNW Share of Firm Assets
- 64.83%
- Total Client Accounts
- 1,043
- Discretionary Accounts
- 1,043
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection
Regulatory Filings
Additional Brochure: 2026 ADV PART 2A (2026-03-17)
View Document Text
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
March 17, 2026
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 with 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 .............................................................................. 4
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .............. 7
ITEM 7: TYPES OF CLIENTS ............................................................................................ 8
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS 8
ITEM 9: DISCIPLINARY INFORMATION ......................................................................... 13
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ................ 13
ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING ............................................... 14
ITEM 12: BROKERAGE PRACTICES .............................................................................. 15
ITEM 13: REVIEW OF ACCOUNTS ................................................................................ 18I
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION .................................. 19
ITEM 15: CUSTODY ........................................................................................................ 19
ITEM 16: INVESTMENT DISCRETION ........................................................................... 20I
ITEM 17: VOTING CLIENT SECURITIES ........................................................................ 21
ITEM 18: FINANCIAL INFORMATION ............................................................................. 21
EXHIBIT............................................................................................................................ 22
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 Diversified Strategies and the
long-term nature of the Concentrated Strategies (collectively, 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.
Part 2A of Form ADV
1
Rachor Investment Advisory Services, LLC
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
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”), and occasionally, 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.
Part 2A of Form ADV
2
Rachor Investment Advisory Services, LLC
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.
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.
Recommendation of Other Professionals
When requested and in conjunction with our investment advisory services, we
may recommend that clients work with other professionals, such as CPAs or attorneys,
to implement our advice. If our services to you include the recommendation of other
professionals, you will typically sign an agreement with them in addition to the
investment advisory agreement you signed with us. As disclosed below under “Item 14:
Client Referrals and Other Compensation,” clients are under no obligation to act upon
any of our recommendations. We do not receive any compensation from the
professionals or from any financial products we recommend to you.
Assets Under Management
As of December 31, 2025, we managed $238,062,651 in client assets on a
discretionary basis. We have an additional $245,636,031 under advisement as of
December 31, 2025.
Part 2A of Form ADV
3
Rachor Investment Advisory Services, LLC
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:
Total Annual Fee
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
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
1.0000%
0.5000%
0.2500%
0.1250%
0.0625%
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 on 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,
Part 2A of Form ADV
4
Rachor Investment Advisory Services, LLC
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 are 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%
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. However, our employees do not receive reduced
fees from the Private Money Managers or broker/custodians we recommend to our
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.
Part 2A of Form ADV
5
Rachor Investment Advisory Services, LLC
Additional Fees and Expenses
In addition to Rachor’s investment advisory fees, clients will incur the following
additional charges imposed by broker-dealers/custodians, including, but not limited to,
IRA administration fees, transfer taxes, wire transfer and electronic fund fees, check
writing fees, SEC expenses on securities transactions, custodial termination fees, and
other fees and taxes on brokerage accounts and securities transactions. Such fees are
not paid to our advisers or to Rachor.
Clients that enter into an agreement with other professionals such as CPAs and
attorneys will be subject to the fee arrangement with that professional.
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 as disclosed in the fund prospectus. A copy of the
prospectus is available from the fund. ETFs do not charge a load, are traded
directly on an exchange and unless waived by the broker-dealer, are subject
to brokerage commissions. Mutual funds are subject to “ticket charges” which
is paid by the client directly to the broker-dealer. Consequently, for any type
of fund investment, including mutual funds, 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.
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.”
Generally speaking, clients may purchase many funds directly, without using
Rachor’s services and without incurring our advisory fees. However, we
recommend a number of funds and have access to institutional shares that
are not available to the general public.
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.
Part 2A of Form ADV
6
Rachor Investment Advisory Services, LLC
Advisory Services to 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 2.0% 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 have typically ranged from 3.0% to 6.0%
(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
based on a percentage of assets under management. The charges, which
range from 2.25% to 2.50% 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
Part 2A of Form ADV
7
Rachor Investment Advisory Services, LLC
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 $250,000.
Private Money Managers impose minimum account or investment thresholds.
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
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
Part 2A of Form ADV
8
Rachor Investment Advisory Services, LLC
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
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 are
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:
Part 2A of Form ADV
9
Rachor Investment Advisory Services, LLC
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.
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.
Part 2A of Form ADV
10
Rachor Investment Advisory Services, LLC
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
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
Part 2A of Form ADV
11
Rachor Investment Advisory Services, LLC
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
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
Part 2A of Form ADV
12
Rachor Investment Advisory Services, LLC
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. Because we provide certain tax services at no additional charge to advisory
clients, we have an incentive for clients to maintain the advisory relationship.
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 (our advisers) 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, including our advisers, as applicable. When the board of
directors vote on whether or not to retain or continue to retain Rachor as an investment
adviser to the foundation, our advisers abstain from voting to mitigate the conflict of
interest. Our advisers are not compensated for his/her role on the board, however;
Rachor does receive an advisory fee when the foundation is our client.
Part 2A of Form ADV
13
Rachor Investment Advisory Services, LLC
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, of 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 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
Money Manager who is made available on the Concentrated Strategy platform.
Personal investing with a Private Money Manager, limited private offering or an initial
Part 2A of Form ADV
14
Rachor Investment Advisory Services, LLC
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.
As disclosed in Item 4: Advisory Business, the Private Money Managers for the
Concentrated Strategies are typically registered as investment adviser representatives
and registered representatives of an unaffiliated financial firm. The Private Money
Managers brokerage practices are described in the unaffiliated financial firm’s Part 2A of
Form ADV.
For qualified retirement plan clients, Rachor does not recommend the broker-
dealer/custodian, the 3(38) investment manager will make the recommendation.
Brokerage and Custodial Services
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 require 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.
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, ticket charges, 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. 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.
Clients may designate a cash sweep option with respect to their accounts. The
cash sweep program is a service that allows clients to earn interest on cash awaiting
investment (“Cash Sweep Program”). The Cash Sweep Program is offered by Raymond
James at no additional charge or cost to you. The Cash Sweep Program is a service
that automatically invests, or “sweeps,” the client’s eligible uninvested cash (“excess
Part 2A of Form ADV
15
Rachor Investment Advisory Services, LLC
funds”) from their brokerage account into a liquid investment. The Cash Sweep Program
is not intended for long-term investments and interest rates or yields on the Cash
Sweep Program may be higher or lower than the yield or interest rate available in other
sweep programs at other institutions. 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. We do not receive
revenue sharing from sweep options.
Soft Dollar Arrangements
We have not and do not intend to enter into any formal contractual third-party
soft-dollar arrangement, such as committing to placing 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. Therefore, as
a matter of policy and practice, we do not receive research or other products or services
other than execution from a broker-dealer or a third party in connection with client
securities transactions. However, as noted below, Raymond James does provide us
with certain non-cash benefits that assist us in managing and administering clients’
accounts but will not necessarily directly benefit a client’s specific account.
In selecting Raymond James, we consider not only the commission rate and
execution capabilities, financial responsibility and responsiveness to instructions, but
also the full range of standard non-cash benefits provided by Raymond James,
including back-office, administrative, custodial support, reporting, and related services.
These services also include software and other technology that:
provide us with 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
Part 2A of Form ADV
16
Rachor Investment Advisory Services, LLC
transaction or our overall responsibilities with respect to accounts as to which we
exercise investment discretion. Periodically, Rachor evaluates custodial options and
execution capabilities, range of brokerage services, quality, and cost of services
available from Raymond James and occasionally compares Raymond James execution
and services to other firms in the discount broker-dealer sector.
Directed Brokerage
As noted above, Rachor does not recommend the broker-dealer/custodian for
qualified retirement plan clients. The Plan Fiduciary may direct us to utilize a specified
broker-dealer of its choice to effect transactions for or with the Plan account. However,
in such circumstances, the client will be responsible for negotiating commission rates
with the chosen broker or custodian. Clients should be aware that using directed
brokerage arrangements will prohibit Rachor from placing security transactions on the
client’s behalf. In addition, Rachor is unable to seek best execution. We will not monitor
the performance of or the services provided by the brokers and dealers so designated.
Clients may pay higher commissions or other transaction costs or greater spreads or
receive less favorable net prices on transactions for the account than would otherwise
be the case.
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
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-ended 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 brokerage trades.
Part 2A of Form ADV
17
Rachor Investment Advisory Services, LLC
Trade Error Policy
Rachor has a responsibility to effect orders correctly, promptly and in the best
interests of our clients. For purposes of this policy, Rachor has defined a trade error to
mean:
funds arrive in an account and are not invested in a timely fashion;
purchase or sale of the wrong security (e.g., DSAR instead of DFAC);
purchase or sale of an incorrect amount of shares of a security;
purchase or sale of a security at a price not in accordance with instructions; or
purchase of a security when the intent was to sell, or vice versa.
Our policy is to seek to identify and correct trade errors as promptly as possible
without disadvantaging the client or benefiting us. If a trade error results in a gain, the
gain will remain in the client’s account, unless it is not permissible for the client to retain
the gain. In all cases, where a trading error results in a gain, we will not be given the
benefit of the net profit.
If a trade error occurs and it results in a loss in the client’s account; the client’s
account is reimbursed for the entire amount of the loss as soon as practical after the
discovery of the error. If the loss is $50 or greater, we will reimburse the client for the
loss. If the loss is under $50, Raymond James will absorb the loss. We maintain
appropriate records for all trade errors.
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”). We prioritize broad diversification, low-cost
investing, and an evidence-based approach when selecting funds for our clients. Over
the years, we have evaluated different fund families, but DFA continues to remain our
preferred fund family.
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
Part 2A of Form ADV
18
Rachor Investment Advisory Services, LLC
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.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
Rachor does not engage promoters or pay related or unaffiliated persons for
referring clients to Rachor. Rachor does not receive compensation (cash or non-cash)
from Private Money Managers or their firms for recommending clients.
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 client’s investment advisory fees only.
ITEM 15: CUSTODY
Rachor does not custody client funds or securities, but requires them to 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.
Part 2A of Form ADV
19
Rachor Investment Advisory Services, LLC
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
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.
Part 2A of Form ADV
20
Rachor Investment Advisory Services, LLC
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.
33621940
Part 2A of Form ADV
21
Rachor Investment Advisory Services, LLC
EXHIBIT
ITEM 2: MATERIAL CHANGES
Under the Amendments to the Form ADV Rachor Investment Advisory Services (“Rachor”)
may provide you with this summary of Material Changes, dated March 17, 2026, detailing any
material changes that we made to our Brochure since our last annual update February 28, 2025, in
lieu of sending a full copy of our Brochure to all of our clients. In addition to grammatical and other
non-material changes, we made the following amendments to our Form ADV Part 2A.
Item 5: Fee and Compensation
We expanded our disclosure to provide additional detail regarding fees and expenses that
clients may incur when engaging other professionals, such as broker-dealers/custodians, certified
public accountants, and attorneys. We also enhanced our discussion by comparing the fees and
expenses associated with investing in exchange-traded funds (ETFs) and mutual funds.
Item 7: Types of Clients
While we continue not to impose a minimum account size requirement, we increased our
recommended minimum household investable asset value to $250,000.
Item 8: Methods of Analysis
We updated our disclosure regarding the use of Dimensional Fund Advisors (DFA) funds
within our Diversified Strategies. While we continue to utilize DFA funds, over time, changes in the
overall characteristics of the DFA core mutual funds as compared to the core ETFs no longer
represent a meaningful difference except for trading costs. In light of Raymond James’ elimination of
ETF trading commissions, discretionary accounts invested in our Diversified Strategies now primarily
utilize DFA ETFs.
Item 10: Other Financial Industry Activities and Affiliations
We enhanced our disclosure to address certain incentives and conflicts associated with
providing tax services to advisory clients at no additional cost. We also clarified that certain advisers
serve as uncompensated board members for foundations; however, Rachor receives advisory fees
when such foundations are clients.
Item 12: Brokerage Practices
Cash Sweep Program. We added disclosures describing the purpose and services offered
through the Cash Sweep Program. We also clarified that we do not receive revenue sharing or
additional compensation when clients utilize a cash sweep option.
Soft Dollar Arrangements. We enhanced our disclosure regarding the benefits we receive from
Raymond James, including additional detail about products and services provided. We also expanded
our discussion of how we evaluate Raymond James’ custodial and execution capabilities in fulfilling
our fiduciary duty to clients.
Directed Brokerage. We updated our disclosure to explain that plan sponsors may direct
brokerage for qualified plan assets and to describe the associated limitations and potential impacts of
directing brokerage.
Trade Error Policy. While our policy to identify and correct trade errors promptly, without
disadvantaging clients or benefiting the firm, remains unchanged, we revised our disclosure to define
what constitutes a trade error and to provide additional detail regarding Raymond James’ trade error
policy.
Item 14: Client Referrals and Other Compensation
We updated our disclosures to clarify that, from time to time, we may recommend unaffiliated
professionals (such as certified public accountants or attorneys) and may receive client referrals from
such professionals. We further clarified that we do not pay or receive referral fees in connection with
these arrangements and do not receive compensation from any financial products, Private Money
Managers or their affiliated firms for recommending clients.
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.