Vestura, LLC

Vestura, LLC Firm Brochure This brochure provides information about the qualifications and business practices of Vestura, LLC. If you have any questions about the contents of this brochure, please contact us at (920-430-3775) or by email at: jperkins@vestura.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 Vestura, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Vestura, LLC’s CRD number is: 142926 1200 Centennial Centre Blvd, Ste 100 Hobart, Wisconsin, 54155 (920) 430-3775 www.vestura.net jperkins@vestura.net Registration does not imply a certain level of skill or training. Version Date: 03/19/2026  Item 2: Material Changes There are no material changes in this brochure from the last annual updating amendment of Vestura, LLC on February 6, 2025. Material changes relate to Vestura, LLC’s policies, practices or conflicts of interests only. ii  Item 3: Table of Contents Table of Contents Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................1 A. Description of the Advisory Firm ................................................................................................................1 B. Types of Advisory Services ...........................................................................................................................1 Investment Supervisory Services ..................................................................................................................1 Services Limited to Specific Types of Investments .....................................................................................1 C. Client Tailored Services and Client Imposed Restrictions ........................................................................1 D. Wrap Fee Programs ........................................................................................................................................2 E. Amounts Under Management ......................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................3 A. Fee Schedule ....................................................................................................................................................3 Investment Supervisory Services Fees ..........................................................................................................3 B. Payment of Fees ...............................................................................................................................................3 Payment of Investment Supervisory Fees ....................................................................................................3 C. Clients Are Responsible For Third Party Fees ............................................................................................3 D. Prepayment of Fees ........................................................................................................................................4 E. Outside Compensation For the Sale of Securities to Clients .....................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................4 Item 7: Types of Clients ..........................................................................................................................................4 Minimum Account Size ..................................................................................................................................4 Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss .......................................4 A. Methods of Analysis and Investment Strategies ..................................................................................4 Methods of Analysis ........................................................................................................................................4 Charting analysis .............................................................................................................................................5 Fundamental analysis .....................................................................................................................................5 Technical analysis ............................................................................................................................................5 Investment Strategies ......................................................................................................................................5 B. Material Risks Involved ...........................................................................................................................5 iii  Methods of Analysis ........................................................................................................................................5 Fundamental analysis .....................................................................................................................................5 Technical analysis ............................................................................................................................................5 Investment Strategies ......................................................................................................................................5 C. Risks of Specific Securities Utilized ........................................................................................................6 Item 9: Disciplinary Information ...........................................................................................................................6 Item 10: Other Financial Industry Activities and Affiliations ...........................................................................6 A. Registration as a Broker/Dealer or Broker/Dealer Representative ..................................................6 Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity B. Trading Advisor ..................................................................................................................................................6 Registration Relationships Material to this Advisory Business and Possible Conflicts of C. Interests .................................................................................................................................................................6 D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections ..............................................................................................................................................................6 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................7 A. Code of Ethics ............................................................................................................................................7 B. Recommendations Involving Material Financial Interests .................................................................7 C. Investing Personal Money in the Same Securities as Clients ..............................................................7 D. Trading Securities At/Around the Same Time as Clients’ Securities ...............................................7 Item 12: Brokerage Practices ..................................................................................................................................7 A. Factors Used to Select Custodians and/or Broker/Dealers................................................................7 1. Research and Other Soft-Dollar Benefits ............................................................................................8 2. Brokerage for Client Referrals .............................................................................................................8 3. Clients Directing Which Broker/Dealer/Custodian to Use ............................................................8 B. Aggregating (Block) Trading for Multiple Client Accounts ...............................................................8 Item 13: Reviews of Accounts ................................................................................................................................8 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ................................8 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts ..............................................8 C. Content and Frequency of Regular Reports Provided to Clients .......................................................9 Item 14: Client Referrals and Other Compensation ............................................................................................9 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) .....................................................................................................................................9 iv  B. Compensation to Non –Advisory Personnel for Client Referrals ......................................................9 Item 15: Custody ......................................................................................................................................................9 Item 16: Investment Discretion ..............................................................................................................................9 Item 17: Voting Client Securities (Proxy Voting) ................................................................................................9 Item 18: Financial Information .............................................................................................................................10 A. Balance Sheet ...........................................................................................................................................10 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ..................................................................................................................................................................10 C. Bankruptcy Petitions in Previous Ten Years .......................................................................................10 v  Item 4: Advisory Business A. Description of the Advisory Firm This firm has been in business since March 6, 2007, and the principal owner is Jason Douglas Perkins. B. Types of Advisory Services Vestura, LLC (hereinafter “Vestura”) offers the following services to advisory clients: Investment Supervisory Services Vestura offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Vestura creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring Vestura evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Vestura will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Services Limited to Specific Types of Investments Vestura limits its investment advice and/or money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, real estate, hedge funds, third party money managers, REITs, private placements, government securities. Vestura may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Vestura offers the same suite of services to all of its clients. However, specific client financial plans and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and 1  risk tolerance levels) and is used to construct a client specific plan to aid in the selection of a portfolio that matches restrictions, needs, and targets. 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 Vestura from properly servicing the client account, or if the restrictions would require Vestura to deviate from its standard suite of services, Vestura reserves the right to end the relationship. D. Wrap Fee Programs Vestura does not participate in any wrap fee programs. E. Amounts Under Management Vestura has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $336,749,300 $0 12/31/2025 2  Item 5: Fees and Compensation A. Fee Schedule Investment Supervisory Services Fees Total Assets Under Management Annual Fee 1.50% $0 - $1,999,999 $2,000,000 - $4,999,999 1.20% $5,000,000 - $9,999,999 0.90% $10,000,000 - $24,999,999 0.80% $25,000,000 and Above 0.70% These fees are negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Fees are paid monthly in arrears, and clients may terminate their contracts with thirty days’ written notice. Because fees are charged in arrears, no refund policy is necessary. Clients may terminate their accounts without penalty within 5 business days of signing the advisory contract. Advisory fees are withdrawn directly from the client’s accounts with client written authorization. B. Payment of Fees Payment of Investment Supervisory Fees Advisory fees are withdrawn directly from the client’s accounts with client written authorization. Fees are paid monthly in arrears. C. Clients Are Responsible For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by Vestura. Please see Item 12 of this brochure regarding broker/custodian. 3  D. Prepayment of Fees Vestura collects its fees in arrears. It does not collect fees in advance. E. Outside Compensation For the Sale of Securities to Clients Neither Vestura nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or services fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management Vestura 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 Vestura generally provides investment advice and/or management supervisory services to the following Types of Clients:  Individuals  High-Net-Worth Individuals  Pension and Profit Sharing Plans  Corporations or Business Entities Minimum Account Size There is an account minimum, $5,000,000, which may be waived by the investment advisor, based on the needs of the client and the complexity of the situation. Item 8: Methods of Analysis, Investment Strategies, and Risk of Investment Loss A. Methods of Analysis and Investment Strategies Methods of Analysis Vestura’s methods of analysis include charting analysis, fundamental analysis, and technical analysis. 4  Charting analysis involves the use of patterns in performance charts. Vestura uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies Vestura uses long term trading, short term trading, and margin transactions 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 Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in solely using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. 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. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not work long term. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Frequent trading, when done, can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Short term trading and margin transactions generally hold greater risk and clients should be aware that there is a chance of material risk of loss using any of those strategies. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 5  C. Risks of Specific Securities Utilized Vestura generally seeks investment strategies that do not involve significant or unusual risk beyond that of the general domestic and/or international equity markets. However, it will utilize Margin transactions. Margin transactions generally hold greater risk of capital loss and clients should be aware that there is a chance of material risk of loss using any of those strategies. Past performance is not a guarantee of future returns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business or the integrity of our management. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither Vestura nor its representatives are registered as a broker/dealer or as representatives of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither Vestura nor its representatives are registered as a FCM, CPO, or CTA. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither Vestura nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections Vestura does not utilize nor select other advisors or third party managers. All assets are managed by Vestura management. 6  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics We have a written Code of Ethics that covers the following areas: Prohibited Purchases and 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. Clients may request a copy of our Code of Ethics from management. B. Recommendations Involving Material Financial Interests Vestura does not recommend that clients buy or sell any security in which a related person to Vestura has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of Vestura may buy or sell securities for themselves that they also recommend to clients. Vestura will always document any transactions that could be construed as conflicts of interest and will always transact client business before their own 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 Vestura may buy or sell securities for themselves at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers The Custodian, Schwab Institutional, a division of Charles Schwab & Co., Inc., was chosen based on their relatively low transaction fees and access to a broad spectrum of investment choices. Vestura will never charge a premium or commission on transactions, beyond the actual cost imposed by Custodian. 7  1. Research and Other Soft-Dollar Benefits Vestura receives no research, product, or service other than execution from a broker- dealer or third-party in connection with client securities transactions (“soft dollar benefits”). 2. Brokerage for Client Referrals Vestura 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 Vestura will not allow clients to direct Vestura to use a specific broker-dealer to execute transactions. Clients must use Vestura recommended custodian (broker- dealer). Not all investment advisers require their clients to direct brokerage. By requiring clients to use our specific custodian, Vestura may be unable to achieve most favorable execution of client transactions and this may cost clients money over using a lower-cost custodian. B. Aggregating (Block) Trading for Multiple Client Accounts Vestura maintains the ability to block trade purchases across accounts but will rarely do so. While block trading may benefit clients by purchasing larger blocks in groups, we do not feel that the clients are at a disadvantage due to the best execution practices of our custodian. Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Client accounts are reviewed at least quarterly by Jason Perkins. Jason Perkins is the chief advisor and is instructed to review clients’ accounts with regards to their investment policies and risk tolerance levels. All accounts at Vestura are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews 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). 8  C. Content and Frequency of Regular Reports Provided to Clients Each client will receive at least quarterly a written report detailing the clients account which may come from the custodian. 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) Vestura does not receive any economic benefit, directly or indirectly from any third party for advice rendered to Vestura clients. B. Compensation to Non –Advisory Personnel for Client Referrals Vestura does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody Vestura does not take custody of client accounts at any time. Custody of client’s accounts is held primarily at Schwab Institutional, a division of Charles Schwab & Co., Inc. Clients will receive account statements from the custodian and should carefully review those statements. Vestura urges clients to compare the account statements they receive from the custodian with those they received from Vestura. Item 16: Investment Discretion For those client accounts where Vestura provides ongoing supervision, Vestura maintains limited power of authority over client accounts with respect to securities to be bought and sold and amount of securities to be bought and sold. All buying and selling of securities is explained to clients in detail before an advisory relationship has commenced. Item 17: Voting Client Securities (Proxy Voting) Vestura will accept voting authority for client securities in certain cases. When Vestura does accept voting authority for client securities, it will always seek to vote in the best interests of its clients. Vestura does not maintain preapproved voting guidelines but relies on the investment committee to determine the appropriate course of action in voting client securities that is in the best interest of the client. Clients may direct Vestura on how to vote client securities by communicating their wishes in writing or electronically to Vestura. When voting client proxies the investment committee will always hold the interests of the clients above its own interests. 9  Clients of Vestura may obtain the voting record of Vestura on client securities by contacting Vestura at phone number or e-mail address listed on the cover page of this brochure. Clients may obtain a copy of Vestura’s proxy voting policies and procedures upon request. Item 18: Financial Information A. Balance Sheet Vestura does not require nor solicit prepayment of more than $1,200 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 Neither Vestura nor its management have any financial conditions that are likely to reasonably impair our ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years Vestura has not been the subject of a bankruptcy petition in the last ten years. 10