Vanderpol Investments LLC

VanderPol Investments LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of VanderPol Investments LLC. If you have any questions about the contents of this brochure, please contact us at (616) 315-2550 or by email at: mark.vanderpol@vanderpolinvestments.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about VanderPol Investments LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. VanderPol Investments LLC’s CRD number is: 168174. 1723 68th St. SE, Suite B Caledonia, MI 49316 (616) 315-2550 VanderPolInvestments.com mark.vanderpol@vanderpolinvestments.com Registration does not imply a certain level of skill or training. Version Date: 03-25-2026  Item 2: Material Changes The material changes in this brochure from the last amendment of VanderPol Investments LLC on 05/22/2025 are described below. Material changes relate to VanderPol Investments LLC’s policies, practices or conflicts of interests. • • • • Item 5: The Firm will now charge fees quarterly in arrears. Item 12: We typically do not allow clients to direct which custodian/broker/dealer to utilize. Item 15: Certain clients have established third-party standing letters of authorization (“SLOAs”) with their qualified custodian which results in the Firm having custody over those accounts. We comply with the conditions set forth in applicable regulatory guidance designed to exempt us from the surprise examination requirement. Item 17: The Firm will be rescinding its obligation to vote proxies on behalf of all its clients effective April 1st, 2026. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes .................................................................................................................................................... i Item 3: Table of Contents ................................................................................................................................................... ii Item 4: Advisory Business ................................................................................................................................................. 5 A. Description of the Advisory Firm ............................................................................................................................ 5 B. Types of Advisory Services ....................................................................................................................................... 5 Portfolio Management ............................................................................................................................................... 5 Pension Consulting Services ..................................................................................................................................... 7 Participant Account Management (Discretionary) .................................................................................................. 7 Services Limited to Specific Types of Investments .................................................................................................. 8 C. Client Tailored Services and Client Imposed Restrictions ...................................................................................... 8 D. Wrap Fee Programs .................................................................................................................................................. 8 E. Assets Under Management ....................................................................................................................................... 8 Item 5: Fees and Compensation ........................................................................................................................................ 8 A. Fee Schedule.............................................................................................................................................................. 8 Portfolio Management ............................................................................................................................................... 8 Portfolio Management – Institutional Intelligent Portfolios ................................................................................... 9 Pension Consulting Services Fees ........................................................................................................................... 10 Educational Seminars/Workshops ......................................................................................................................... 10 B. Payment of Fees ....................................................................................................................................................... 10 Payment of Portfolio Management ......................................................................................................................... 10 Payment of Pension Consulting Services Fees ....................................................................................................... 11 Payment of Educational Seminar/Workshop Fees ................................................................................................ 11 C. Clients Are Responsible For Third Party Fees ....................................................................................................... 11 D. Prepayment of Fees ................................................................................................................................................. 11 E. Outside Compensation For the Sale of Securities to Clients ................................................................................. 11 Item 6: Performance-Based Fees and Side-By-Side Management ................................................................................. 11 Item 7: Types of Clients ................................................................................................................................................... 11 Minimum Account Size ........................................................................................................................................... 12 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss ..................................................... 12 A. Methods of Analysis and Investment Strategies ............................................................................................. 12 iii  Methods of Analysis ................................................................................................................................................ 12 Fundamental analysis.............................................................................................................................................. 12 Cyclical analysis ...................................................................................................................................................... 12 Investment Strategies .............................................................................................................................................. 12 B. Material Risks Involved.................................................................................................................................... 12 Methods of Analysis ................................................................................................................................................ 12 Fundamental analysis.............................................................................................................................................. 12 Cyclical analysis ...................................................................................................................................................... 12 Investment Strategies .............................................................................................................................................. 13 C. Risks of Specific Securities Utilized ................................................................................................................. 13 Item 9: Disciplinary Information ..................................................................................................................................... 15 A. Criminal or Civil Actions ................................................................................................................................. 15 B. Administrative Proceedings ............................................................................................................................. 15 C. Self-regulatory Organization (SRO) Proceedings ........................................................................................... 15 Item 10: Other Financial Industry Activities and Affiliations........................................................................................ 15 A. Registration as a Broker/Dealer or Broker/Dealer Representative ............................................................... 15 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading B. Advisor......................................................................................................................................................................... 15 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests ............. 16 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ... 16 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................. 16 A. Code of Ethics ................................................................................................................................................... 16 B. Recommendations Involving Material Financial Interests ............................................................................. 16 C. Investing Personal Money in the Same Securities as Clients .......................................................................... 16 D. Trading Securities At/Around the Same Time as Clients’ Securities ............................................................ 17 Item 12: Brokerage Practices............................................................................................................................................ 17 A. Factors Used to Select Custodians and/or Broker/Dealers ........................................................................... 17 1. Research and Other Soft-Dollar Benefits ..................................................................................................... 17 2. Brokerage for Client Referrals ...................................................................................................................... 19 3. Clients Directing Which Broker/Dealer/Custodian to Use ....................................................................... 19 B. Aggregating (Block) Trading for Multiple Client Accounts ........................................................................... 19 Item 13: Reviews of Accounts ......................................................................................................................................... 20 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews .............................................. 20 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts .......................................................... 20 iv  C. Content and Frequency of Regular Reports Provided to Clients ................................................................... 20 Item 14: Client Referrals and Other Compensation ....................................................................................................... 20 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or A. Other Prizes) ................................................................................................................................................................ 20 B. Compensation to Non – Advisory Personnel for Client Referrals ................................................................. 20 Item 15: Custody .............................................................................................................................................................. 21 Item 16: Investment Discretion ....................................................................................................................................... 21 Item 17: Voting Client Securities (Proxy Voting) ........................................................................................................... 21 Item 18: Financial Information ........................................................................................................................................ 22 A. Balance Sheet .................................................................................................................................................... 22 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients 22 C. Bankruptcy Petitions in Previous Ten Years ................................................................................................... 22 A. Material Relationships That Management Persons Have With Issuers of Securities (If Any) ...................... 22 v  Item 4: Advisory Business A. Description of the Advisory Firm VanderPol Investments LLC (hereinafter “VPI”) is a Limited Liability Company organized in the State of Michigan. The firm was formed in May 2013, and the principal owner is Mark A. VanderPol. B. Types of Advisory Services VPI provides investment advisory services to individuals, and high net worth individuals concerning various securities including equities, fixed income, and derivatives. As a registered investment adviser, we are held to the highest standard of client care - a fiduciary standard. As a fiduciary we always put our client's interests first and must fully disclose any potential conflict of interest. We do not directly hold customer funds or securities and all transactions are sent to our qualified custodian which executes, compares, allocates, clears, and settles them. Our custodian also maintains our clients' accounts and may grant clients access to them. We accept and enter trades on both a discretionary and a non-discretionary basis. VPI offers the following services to advisory clients: Portfolio Management VPI offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. This service may include financial planning, tax planning or other unrelated consulting for those clients that desire extra service. VPI creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). VPI can review all financial issues for our clientele, allowing for a balanced approach towards investments and risks in life. We will consider any additional insurance they may need, and the most appropriate investment strategy to achieve any and all of their goals. Portfolio management services include, but are not limited to, the following: • Customized Portfolio Management • Automatic Rebalancing • Periodic Reviews and Adjustments • Access to a Broad Range of Investments • Transparent Reporting and Communication • Educational Resources and Support For clients who maintain assets of more than $250,000 in management with VPI will also receive: • Tax Optimization Strategies 5  • Estate Planning • Charitable Gift Planning • Insurance Planning • Tax Planning VPI evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. VPI seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of VPI’s economic, investment or other financial interests. To meet its fiduciary obligations, VPI attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and, accordingly, VPI’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is VPI’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings (“IPOs”) and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Model Portfolios VPI maintains twelve model portfolios that range from high risk to low risk that are implemented in a variety of ways depending on cost effectiveness, client tax situations, and successful execution of strategy. These portfolios may be made up of ETFs, mutuals funds, individual stocks and or individual bonds. VPI emphasizes a Pastor-Stambaugh Model within each of these model portfolios that emphasizes small-capital weighted, value-oriented, illiquid equities relative to an appropriate benchmark. VPI considers the global equities benchmark of MSCI ACWI USD NR to be an appropriate measure of its equity’s exposure and the Barclays US Aggregate Bond index an appropriate measure of its fixed income exposure and provides performance reports against these benchmarks to individual accounts based on the current percentage of equities held in the account rounded to the nearest ten percent and the remainder measured against the fixed income benchmark. In our most basic models, VPI utilizes only low-cost ETFs that are highly diversified and are our favorite selection within their asset class. Going another step further, VPI may allocate those securities differently across Roth IRAs compared to traditional IRAs or taxable accounts in order to potentially generate higher after-tax returns. With more scale, VPI may find it more beneficial to incur a small custodial transaction fee for more precise implementation of the overall strategy and utilize mutual funds with large factor tilts in conjunction with extremely low-cost index ETFs. When accounts are large enough for effective implementation, VPI may use a stratified sampling direct-indexing technique to provide optimal tax loss harvesting or donation options within the large 6  cap US equities and or international equities allocations. Finally, VPI may utilize alternative investments (private equity funds, private real estate funds, private credit funds, hedge funds) to hopefully earn the illiquidity premium illustrated within the Pastor-Stambaugh model. Financial Planning and Consulting Services VPI provides financial planning and consulting services to the Client on an hourly or flat fee basis. Services shall include, but not be limited to, personal budgeting advice, evaluations of capital expenditure opportunities within their business, and other finance- related consulting services as requested by the Client. The exact nature of the services to be provided will be determined on a case-by-case basis, allowing for a broad interpretation of the financial consultancy remit. VPI also offers stand alone service plans, Essential Plan and Premium Plan. The plans are a standalone service and include life insurance & tax concerns & retirement planning & education planning & Estate Planning (Premium Only). Pension Consulting Services VanderPol Investments offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans) based on the demographics, goals, objectives, time horizon, and/or risk tolerance of the plan’s participants. Pension consulting services may involve the direct investment management of one or more 401(k) participant accounts, provide the selection and monitoring process for the various mutual funds offered to plan participants, develop and maintain an Investment Policy Statement for the plan, and/or provide group and individual employee education on investment options, asset allocation, and retirement planning. Participant Account Management (Discretionary) VPI uses a third party platform, Pontera, to facilitate management of atypical accounts, such as current 401k’s and other defined contribution plan participant accounts, with discretion. The platform allows VPI to avoid having custody of client funds since VPI does not have direct access to client log-in credentials to affect trades. VPI is not affiliated with the platform in any way and receives no compensation from them for using their platform. A link will be provided to the client allowing them to connect an account(s) to the platform. Once client account(s) is connected to the platform, VPI will review the current account allocations. When deemed necessary, VPI will rebalance the account considering client investment goals and risk tolerance, and any change in allocations will consider current economic and market trends. The goal is to improve account performance over time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least quarterly, and allocation changes will be made as deemed necessary. VPI may also provide its clients newsletters for no additional charge. 7  Services Limited to Specific Types of Investments VPI generally limits its investment advice to mutual funds, equities, fixed income securities, ETFs (including ETFs in the gold and precious metal sectors), real estate funds (including REITs), non-U.S. securities, hedge funds, private equity funds, private credit funds and venture capital funds. C. Client Tailored Services and Client Imposed Restrictions VPI offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels), and cost efficient implementation for its clients. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent VPI from properly servicing the client account, or if the restrictions would require VPI to deviate from its standard suite of services, VPI reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. VPI does not participate in any wrap fee programs. E. Assets Under Management VPI has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $118,125,821 $0.00 December 31, 2025 8  Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Total Assets Under Management Annual Fee Up to $1,000,000 1.00% Next $1,000,001 0.750% Next $8,000,000 0.625% Additional Amounts 0.500% These fees, which cover portfolio management and overall planning for client finances, are generally negotiable and the final fee schedule is attached as Exhibit II of the contract. VPI uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Financial Planning and Consulting Services Fees The Client agrees to pay VPI a flat fee, as specified in Exhibit A of the Hourly Consulting Agreement. Any services rendered beyond the agreed-upon flat fee will be billed at an applicable hourly rate as shown on the table below and within Exhibit A in arrears. Exhibit A will also include a breakdown of each advisor’s rates and expected quarterly use for your desired services. Mark VanderPol, CFP Noah Hoekstra General $250 Budgeting, Research Hourly Rate $450 Typical Services Business Consulting, Capital Expenditures, Estate Communication Richard Toth, CFA, CAIA $350 Valuations, Porter’s Five Forces Report, Industry Outlooks 9  When the Client agrees to a VPI Service Plan, rates specified below, they will agree to the plan fee. The fee will be paid 100% in arrears. The Client will be invoiced and fees will be payable via cash, check, or wire. Service Plan Flat Fee Essential Plan $5,000 Premium Plan $25,000 Pension Consulting Services Fees VPI offers ongoing consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). These fees are negotiable depending upon the needs of the client and complexity of the situation and will not exceed 1.00% Fees are paid quarterly in arrears. Clients may terminate the contract with thirty days written notice. Educational Seminars/Workshops VPI provides periodic educational seminars and workshops to clients and the general public. Termination of Agreement Clients may terminate the agreement without penalty within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with fifteen (15) days’ written notice. B. Payment of Fees Payment of Portfolio Management The fees are withdrawn directly from the client’s accounts with client’s written authorization, or, in VPI’s sole discretion, may instead be billed to the client. Fees are paid quarterly in arrears. VPI may agree to other permissible methods of payment, in its sole discretion. Payment of Financial Consulting Services Fees VPI will invoice the Client quarterly for the hourly fee. Payment is due quarterly in arrears. For the Financial Planning Plans, VPI will invoice the Client for the flat fee. The fee will be invoiced and payable via cash, check, or wire and will be paid in arrears. 10  Payment of Pension Consulting Services Fees Pension Consulting Fees are withdrawn directly from the client’s accounts with client’s written authorization or may be invoiced and billed directly to the client and clients may select the method in which they are billed. Payment of Educational Seminar/Workshop Fees Educational seminars and workshops are offered free of charge. C. Clients Are Responsible For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by VPI. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees VPI collects its fees in arrears. It does not collect fees in advance. E. Outside Compensation For the Sale of Securities to Clients Neither VPI nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management VPI does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients VPI generally provides advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Corporations ❖ Charitable Organizations ❖ Pension and profit-sharing plans 11  Minimum Account Size In general, we require a minimum of $250,000 to open and maintain an account with us. This minimum may be waived at our discretion. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis VPI’s methods of analysis include fundamental analysis and cyclical analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Cyclical analysis involved the analysis of business cycles to find favorable conditions for buying and/or selling a security. Investment Strategies VPI uses long term trading, short term trading, short-term purchases, short sales, margin transactions, and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns and 2) if too many investors begin to implement this strategy, it changes the very cycles these investors are trying to exploit. 12  Investment Strategies VPI’s use of short term trading, short sales, margin transactions, and options trading generally holds greater risk and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Short term trading risks include liquidity, economic stability and inflation, in addition to the long term trading risks listed above. Frequent trading, can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering s margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options writing or trading involves a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value and the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized VPI’s use of short sales, margin transactions, and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned below). Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and capital gains if the value of the stock increases. The value 13  of equity securities may fluctuate in response to specific situations for each company, industry market conditions and general economic environments. Hedge Funds often engage in leveraging and other speculative investment practices that may increase the risk of investment loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary and include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile, and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). The price of Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) may be negatively impacted by several factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Non-traded REITs: Risks associated with investing in these investments include, but are not limited to illiquid markets, potentially significant material downside pricing revisions which can be considerably below initial offering price, the potential for significantly longer than anticipated liquidity events, potential reduction or even complete elimination 14  of dividends, if a secondary market does exist, potentially extremely large spreads between the bid and ask, risks related to non-traded REIT’s corporate structure, potential conflicts of interest by the REIT's management, Federal Income Tax risks, large penalties for premature withdrawal, IPO pricing issues, etc. These and other risks are listed in the REIT prospectus. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option writing also involves risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Interval Funds: An interval fund is a non-traditional type of closed-end mutual fund that periodically offers to buy back a percentage of outstanding shares from shareholders. Investments in an interval fund involve additional risk, including lack of liquidity and restrictions on withdrawals. During any time periods outside of the specified repurchase offer window(s), investors will be unable to sell their shares of the interval fund. There is no assurance that an investor will be able to tender shares when or in the amount desired. There can also be situations where an interval fund has a limited amount of capacity to repurchase shares, and may not be able to fulfill all purchase orders. In addition, the eventual sale price for the interval fund could be less than the interval fund value on the date that the sale was requested. While an internal fund periodically offers to repurchase a portion of its securities, there is no guarantee that investors may sell their shares at any given time or in the desired amount. As interval funds can expose investors to liquidity risk, investors should consider interval fund shares to be an illiquid investment. Investment should be avoided where an investor has a short-term investing horizon and/or cannot bear the loss of some, or all, of the investment. There can be no assurance that an interval fund investment will prove profitable or successful. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. 15  B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither VPI nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither VPI nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Mark Vanderpol is the Managing Member of Celestial Divide, an Inheritance Division Assistance Saas LLC. Through this activity, Mr. Vanderpol may assist personal representatives, attorneys, or other financial professionals in evaluating the division of assets in matters such as estates or divorce proceedings. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections VPI does not utilize nor select third-party investment advisers. All assets are managed by VPI management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics VPI has a written Code of Ethics that covers the following areas: Prohibited Purchases and 16  Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Our Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests VPI does not recommend that clients buy or sell any security in which a related person to VPI or VPI has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of VPI may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of VPI to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. VPI will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of VPI may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of VPI to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, VPI will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on VPI’s duty to seek “best execution,” which is the obligation to seek to execute securities transactions for a Client on terms that are the most favorable to the Client under the circumstances. The client will not necessarily pay the lowest commission or commission equivalent, and VPI may also consider the market expertise and research access provided by the payment of commissions, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the 17  brokers to aid in the research efforts of VPI. VPI will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. Schwab Institutional, a division of Charles Schwab & Co., Inc. 1. Research and Other Soft-Dollar Benefits While VPI has no formal soft dollars program in which soft dollars are used to pay for third party services, VPI may receive research, products, or other services from its broker/dealer. Schwab Advisor Services (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. Through Schwab Advisor Services, CS&Co provides us and our clients, both those enrolled in the Program and our clients not enrolled in the Program, with access to its institutional brokerage services – trading, custody, reporting and related services – many of which are not typically available to CS&Co retail customers. CS&Co also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. CS&Co’s support services described below are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. The availability to us of CS&Co’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Here is a more detailed description of CS&Co’s support services: CS&Co’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. CS&Co’s services described in this paragraph generally benefit the client and the client’s account. CS&Co also makes available to us other products and services that benefit us but may not directly benefit the client or its account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at CS&Co. In addition to investment research, CS&Co also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and • account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate payment of our fees from our clients’ accounts; and • provide pricing and other market data; • • assist with back-office functions, recordkeeping and client reporting. CS&Co also offers other services intended to help us manage and further develop our business enterprise. These services include: • educational conferences and events 18  technology, compliance, legal, and business consulting; • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants and insurance providers. CS&Co may provide some of these services itself. In other cases, it will arrange for third- party vendors to provide the services to us. CS&Co may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. CS&Co may also provide us with other benefits such as occasional business entertainment of our personnel. 2. Brokerage for Client Referrals VPI receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use VPI typically requires clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. Client accounts enrolled in the Program are maintained at, and receive the brokerage services of, CS&Co., a broker- dealer registered with the Securities and Exchange Commission and a member of FINRA and SIPC. While clients are required to use CS&Co. as custodian/broker to enroll in the Program, the client decides whether to do so and opens its account with CS&Co. by entering into a brokerage account agreement directly with CS&Co. We do not open the account for the client. If the client does not wish to place his or her assets with CS&Co., then we cannot manage the client’s account through the Program. CS&Co. may aggregate purchase and sale orders for ETFs across accounts enrolled in the Program, including both accounts for our clients and accounts for clients of other independent investment advisory firms using the Platform. B. Aggregating (Block) Trading for Multiple Client Accounts If VPI buys or sells the same securities on behalf of more than one client, it might, but would be under no obligation to, aggregate or bunch, to the extent permitted by applicable law and regulations, the securities to be purchased or sold for multiple Clients in order to seek more favorable prices, lower brokerage commissions or more efficient execution. In such case, VPI would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. VPI would determine the appropriate number of shares to place with brokers and will select the appropriate brokers consistent with the Adviser’s duty to seek best execution, except for those accounts with specific brokerage direction (if any). 19  Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts are reviewed at least annually only by Mark A. VanderPol, President, with regard to clients’ respective investment policies and risk tolerance levels. The client may be able to come in at any time and receive an updated investment plan. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Review may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client will receive at least annually a written report that details the client’s account including assets held and asset value, which report will come from VPI. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) We receive an economic benefit from Schwab in the form of the support products and services it makes available to us. These products and services, how they benefit us, and the related conflicts of interest are described above under Item 12 Brokerage Practices. The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. B. Compensation to Non – Advisory Personnel for Client Referrals VPI may enter into written arrangements with third parties to act as solicitors for the Adviser’s investment management services and any such arrangements will be fully disclosed. Clients do not pay additional fees because of any referral arrangements. Item 15: Custody VPI, with client written authority, has limited custody of client’s assets through direct fee deduction of VPI’s fees only. If the client chooses to be billed directly by Schwab or the client’s 20  chosen custodian, VPI would have custody over that account and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion In addition, pursuant to a standing letter of authorization (“SLOA”) certain clients have granted VPI limited discretion to disburse funds to one or more third parties, as specifically designated by the client. After granting VPI with this limited authorization, the client then instructs the qualified custodian for the client's account to accept VPI’s direction on the client's behalf to move money to the third party designated by the client on the SLOA. The qualified custodian takes that instruction in writing directly from the client, and VPI’s authority is limited by the terms of that instruction. VPI is authorized to act merely as an agent for the client. The client retains full power to change or revoke the arrangement. VPI does not have discretion as to the amount, payee or timing of transfers under the SLOA. VPI provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client outlines the discretionary authority for trading. Where investment discretion has been granted, VPI generally manages the client’s account and makes investment decisions without consultation with the client as to what securities to buy or sell, when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, the price per share. In some instances, VPI’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to VPI. Item 17: Voting Client Securities (Proxy Voting) The Firm does not perform proxy voting services on the client’s behalf. Clients are encouraged to read through the information provided with the proxy voting documents and to make a determination based on the information provided. Upon the client’s request, Firm representatives may provide limited clarifications of the issues presented in the proxy voting materials based on his or her understanding of issues presented in the proxy voting materials. However, clients have the ultimate responsibility for making all proxy voting decisions. 21  Item 18: Financial Information A. Balance Sheet VPI neither requires nor solicits prepayment of more than $1200 in fees per client, six months or more in advance and therefore does not need to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients None. C. Bankruptcy Petitions in Previous Ten Years VPI has not been the subject of a bankruptcy petition in the last ten years. A. Material Relationships That Management Persons Have With Issuers of Securities (If Any) Neither VPI, nor its management persons, has any relationship or arrangement with issuers of securities. 22