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Form ADV Part 2A
March 20, 2026
von Borstel & Associates, Inc.
308 East 3rd Street
The Dalles, Oregon 97058
(541) 296-6669
vonborstel.com
Item 1 – Cover Page
This brochure provides information about the qualifications and business practices of von Borstel & Associates, Inc. For any
questions about the contents of this brochure, please contact us at (541) 296-6669 or email staff@vonborstel.com.
The information in this brochure has not been approved or verified by the United States Securities and Exchange
Commission (“SEC”) or by any state securities authority. Additional information about von Borstel & Associates, Inc. is also
available on the SEC’s website at www.adviserinfo.sec.gov and our CRD number is 309746.
von Borstel & Associates, Inc. is a registered investment advisor. Registration as an investment advisor does not imply any
certain level of skill or training.
Item 2 – Material Changes
This is provided further to our last brochure dated March 19, 2025, and updates our assets under
management and removes information on Intelligent Portfolios that we are no longer utilizing in item 4.
We have added information in Item 4 and Item 10 regarding our use of Holistiplan to help clients. We
have added information on proxy and organizational voting in Item 17. We have also clarified
information on our use of Dimensional Fund Advisor Funds in Item 4, Item 8 and Item 10.
In the future, this section will discuss specific material changes that are made to the Brochure and
provide clients with a summary of such changes. Following the SEC and state rules, we will ensure that
clients receive a summary of any materials changes to this and subsequent Brochures within 120 days
of the close of the Advisor’s fiscal year. We will provide other ongoing disclosure information about
material changes as necessary.
Item 3 – Table of Contents
Form ADV Part 2A .............................................................................................................................. 1
Item 1 – Cover Page ....................................................................................................................... 1
Item 2 – Material Changes .............................................................................................................. 2
Item 3 – Table of Contents ............................................................................................................... 2
Item 4 – Advisory Business ............................................................................................................. 3
Item 5 – Fees and Compensation .................................................................................................... 4
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................ 5
Item 7 – Types of Clients ................................................................................................................. 5
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................ 5
Item 9 – Disciplinary Information ..................................................................................................... 7
Item 10 – Other Financial Industry Activities and Affiliations ............................................................ 7
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...... 8
Item 12 – Brokerage Practices ........................................................................................................ 8
Item 13 – Review of Accounts ....................................................................................................... 10
Item 14 – Client Referrals and Other Compensation ...................................................................... 10
Item 15 – Custody ......................................................................................................................... 10
Item 16 – Investment Discretion .................................................................................................... 10
Item 17 – Voting Client Securities .................................................................................................. 10
Item 18 – Financial Information ..................................................................................................... 10
Form ADV Part 2B ......................................................................................................................... 11
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Item 4 – Advisory Business
von Borstel & Associates, Inc. (“we,” “us,” or “Advisor”) was initially registered as an investment advisor
in 1992 under the name Oregon Trail Financial Services, Inc. After changing the name to von Borstel
& Associates, Inc. in 2014, we withdrew registration in 2017. After utilizing two other advisory firms for
a few years, we have registered in 2020 for Financial Planning and Investment Management Services.
We are solely owned by Wayne von Borstel, who has been helping individuals with financial services
since 1985. All Financial Planning and Investment Management Services are provided through our
investment advisor representatives (“Representatives”).
Financial Planning
We provide clients with a comprehensive evaluation of their current financial state. Through careful
analysis we will help clients reach their financial goals and objectives by projecting future cash-flows,
asset values and withdrawal plans. Clients purchasing this service from us will receive written or
electronic reports, or verbal directions for making financial decisions. In general, financial planning may
include the evaluation of family records, budgeting, personal liability, estate information and financial
goals. Educational, insurance and estate planning issues may also be included in the financial plan.
Tax and cash flow analysis may also be provided, as well as income tax and spending analysis for past,
current and future years. We may illustrate the impact of various investments on a client's current
income tax and future tax liability. We may also assist clients with retirement analysis by reviewing and
proposing current strategies and investment plans to help the client achieve their financial goals. During
the planning process, investments will be reviewed for the appropriateness, including standard and
alternative investment choices, and the impact these investments may have on the client’s financial
plan. Additionally, advice may be given to assist clients with death and disability situations, including
cash needs at death, income needs of surviving dependents, estate planning and disability income
analysis.
We gather information through in-depth personal interviews and questionnaires. Information gathered
includes a client's current financial status, tax status, future goals, returns objectives and attitudes
towards risk. We carefully review documents and questionnaires completed by the client to prepare the
financial plan or recommendations. We may utilize an unaffiliated third-party software program for tax
strategy suggestions called Holistiplan. Should a client choose to implement the recommendations or
suggestions in the plan, we suggest they work closely with their attorney, accountant, insurance agent,
and/or other financial services providers for execution of the plan. Implementation of financial plan
recommendations are entirely at the client's discretion. Neither we or our Representatives provide any
tax, accounting or legal advice.
Typically, our recommendations or financial plan will be presented to the client within 90 days of the
contract date, provided that all information needed to prepare the financial plan has been provided by
the client.
Investment Management Services (“The Vision to Wealth Process™”)
Investment Management Services, also known as “The Vision to Wealth Process™”, provides
continuous advice and investment management for a client based on their individual needs. During
our personal interviews and data-gathering process, we determine the client’s individual objectives,
time horizon, risk tolerance, and liquidity needs to develop their personal investment strategy. We then
create and manage a portfolio based on that strategy.
We manage these advisory accounts on a discretionary basis. Clients may impose reasonable
restrictions on investing in certain securities, types of securities, or industry sectors. Our investment
recommendations are not limited to any specific product or services. Generally, investments used
include stocks, bonds, mutual funds, exchange traded funds, fee-based annuities, options, unit-
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investment trusts, third-party managers or other investments available through the custodian
(“Custodian”) selected by the client.
Our investment philosophy is heavily influenced by the 'Evidence-Based' or 'Factor' investing approach
popularized by Dimensional Fund Advisors (“DFA”). Consequently, most client portfolios will consist
largely or exclusively of DFA mutual funds or ETFs.
In some cases when appropriate for the client, we may recommend insurance products that are “fee-
based”, meaning, there are no commissions earned for us or the Representative. The fee-based
insurance products are offered through various insurance companies and are utilized to provide
additional diversification for client investments.
Advisor also provides investment consulting services to certain broker/dealers’ customers (“Brokerage
Customers”) who provide written consent requesting to receive the Advisor’s services. Brokerage
Customers have entered into a written advisory agreement with the Advisor.
Our discretionary assets under management as of December 31, 2025 was $680,192,461.
Item 5 – Fees and Compensation
Financial Planning
Our fee for Financial Planning can range from $1,000 to $25,000 per plan. Our standard Financial
Planning fee (“Planning Fee”) is $5,000 with a minimum of $1,000. The Planning Fee can be adjusted
depending on the level of service provided, experience of the Representatives, or asset level of the
client. The Planning Fee is clearly stated in the Financial Planning Agreement the client signs to engage
our services and may be adjusted based on the level of assets of the client. If requested by client, we
may also be engaged for planning/consultations on an hourly basis up to $500 per hour. Any clients
who engage us for hourly planning will receive a detailed invoice describing services provided and fees
charged, and any fee not paid within 30 days will be assessed a late fee of $200. We will accept check
or payments electronically through third-party payment processing firm, or bank transfers when
authorized by the Client.
Investment Management Services
For Investment Management Services our fee (“Advisory Fee”) is based upon a percentage of the
assets under management (“Assets”). Our maximum fee schedule is noted below and is generally not
negotiable, although it is possible that we could have clients on a different fee schedule:
1.15% on the first $500,000, plus
0.97% on the next $500,000, plus
0.83% on the next $3,000,000, plus
0.35% on the next $3,000,000, plus
0.28% on amounts over $7,000,000
Our Advisory Fee is tiered, which means a client pays each Advisory Fee rate for the level of Assets
we are managing. For example, if a client has us manage $700,000 the annual Advisory Fee will be
$7,960: [1.15% * $500,000 = $5,750 plus 0.97 * $200,000 = $1,940]. Clients utilizing special programs
may be charged less than the Advisory Fee noted above.
The Advisory Fee is calculated quarterly and in arrears on the average daily balance of the Assets
during the previous quarter. Advisory Fees are usually deducted from client accounts. The Assets
used in the Advisory Fee calculation will include all positions in the accounts, cash, declared and paid
dividends, accrued income and interest payments, unless the position is specifically excluded or
restricted from billing in writing by the client.
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Clients are also responsible for the transaction charges, fees and other expenses charged and imposed
by the Custodian who holds the client assets, which includes, but is not limited to transactional fees,
wire and transfer fees, commissions, account transfer fees (outbound); returned check fees;
international security transfer fees; overnight mail and check fees; Rule 144 transfer fees; transfer agent
fees and other fees charged by the Custodian and independent of our Advisory Fee. Additionally, any
fees charged by third-party money managers or insurance companies that provide fee-based annuities
are separate from and in addition to our Advisory Fees.
In addition to our Advisory Fee, clients may also incur, relative to all mutual fund and exchange traded
fund purchases, charges imposed at the fund level (e.g., management fees and other fund expenses).
Accordingly, clients should review the fees charged by the investments, Custodian, third-party
managers, insurance companies and the Advisory Fee to fully understand the total amount of the fees
being paid. Additionally, the investments selected for the clients are not exclusively available to us and
could be obtained through other unaffiliated firms and potentially at a lower fee.
Additionally, some Representatives are licensed insurance agents (“Agents”) with separate and
unaffiliated insurance companies. The Agents can purchase or sell insurance products or services
(including fixed annuities) for separate and additional compensation. This compensation is not credited
against the Advisory Fees paid to us. This may create a conflict of interest in selling a product that
produces a commission that would be larger than the Advisory Fee. In all cases, we must make
recommendations that are in the best interest of the client. In the event we recommend a fee-based
annuity, the value of that annuity will be included in the Advisory Fee calculation and billed to a client’s
taxable account, billed directly, or paid by the insurance company.
We receive an advisory fee from Brokerage Customers who have provided written consent to a broker-
dealer to receive our investment advisory services and have entered into a written advisory contract.
The advisory fee is calculated in advance based on the value of the assets under management from
Brokerage Customers as of the end of the previous quarter. The maximum advisory fee will not exceed
1% annually. This advisory fee is paid by the broker-dealer and is not charged to the client separately.
Item 6 – Performance-Based Fees and Side-By-Side Management
We do not charge fees that are based upon a share of capital gains or capital appreciation of Assets.
Item 7 – Types of Clients
We provide advisory services to a variety of clients including individuals, trusts, corporations, estates
and broker-dealers. We have a minimum Financial Planning Fee of $1,000. We also have a minimum
asset size of $500,000.00. We may waive these minimums at our sole discretion.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis:
Our investment philosophy is based upon Modern Portfolio Theory (“MPT”). MPT states that assets
should be selected on the basis of how they interact with one another, rather than how they perform in
isolation.
We rely heavily on the academic research provided by DFA. While we believe this research is sound,
our reliance on a single source for our primary investment methodology may result in a lack of
diversification across different investment 'schools of thought.
Additionally, we utilize numerous sources of information to provide advice, including but not limited to:
financial newspapers and magazines, websites, research materials and software prepared by third
parties, annual reports, prospectuses and filings with the SEC, company press reports, as well as our
proprietary analysis of data and information.
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It is important to know that all methods of analysis include specific risks, including timing errors,
inaccurate information, economic impacts and other factors that can impact client investment
performance.
Investment Strategies:
We may utilize long term purchases (securities held at least a year) and short term purchases
(securities sold within a year) when implementing investment advice. Short term purchases may
increase costs and may also increase the tax obligation of the portfolio. Investments may also be made
on margin, which may increase the costs due to the interest payments on the margin loan balance.
Option strategies may also be implemented, which carries the risk of expiration with no value, as well
as called equity positions, which could create a risk of taxation.
The types of securities include, but are not limited to the following: equities, fixed income (corporate
debt, municipal bonds, certificates of deposit, etc.), mutual funds, unit investment trusts, options,
exchange traded funds, U.S. Government issues securities, real estate investment trusts, limited
partnerships, direct participation programs, variable annuities, variable life insurance and fixed
annuities. We only sell annuities and life insurance policies where we are licensed and/or registered.
Risk Information:
Financial Planning: Risks associated with the financial planning process include the possibility that the
investment performance, interest rates, inflation assumptions, and longevity assumptions used in the
development of client’s financial plan turn out to be materially different than the actual future investment
performance, interest rate, inflation and life span. Differences between the assumptions used in the
plan and actual events can materially affect the results of the financial plan over long periods of time.
While we base our assumptions on historical information, clients must acknowledge that past
performance or events might not be indicative of the future returns.
Investing: Investing is not without risk, and involves the risk of loss of principal which clients should be
prepared to bear. We use several strategies to try to reduce risk, including diversifying a portfolio across
multiple asset classes. Despite these strategies, every asset class has experienced severe declines in
value, sometimes over many years.
Asset Class Risk: Securities in client portfolios or in underlying investments such as mutual funds may
underperform in comparison to the general securities markets or other asset classes.
Issuer Risk: Client account performance depends on the performance of individual securities selected
in client accounts. Any issuer may perform poorly or be unable to continue operations, causing the
value of its securities to decline or default.
Management Risk: The performance of client accounts is subject to the risk that our investment
management strategy may not produce the intended results.
Market Risk: Client accounts can lose money over short periods due to short-term market movements
and over longer periods during market downturns. The value of a security may decline due to general
market conditions, economic trends, or events that are not specifically related to the issuer of the
security or to factors that affect a particular industry or industries.
Passive Investment Risk: We may use a passive investment strategy that is not actively managed
where we do not attempt to take defensive positions in declining markets.
Liquidity Risk: A security may not be able to be sold at the time desired which can impact performance.
Interest Rate Risk: An increase in interest rates may cause the value of fixed income securities and
funds that hold these securities to decline in value. Securities with longer durations tend to be more
sensitive to interest rate changes, usually making them more volatile than securities with shorter
durations.
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Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next
year, because purchasing power is eroding at the rate of inflation.
Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the
currency of the investment’s originating country. This is also referred to as exchange rate risk.
Reinvestment Risk: This is a risk that future proceeds from fixed income investments may have to be
reinvested at a potentially lower rate of return (i.e. interest rate).
Business Risk: These risks are associated with a particular industry or a particular company within an
industry.
Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability,
because the company must meet the terms of its obligations in good times and bad.
Item 9 – Disciplinary Information
In 2022, Mr. Wayne von Borstel, the principal owner of von Borstel & Associates, Inc., entered into an
agreement with FINRA, a former regulator, agreeing to the imposition of a suspension and fine
(deferred) based upon recordkeeping issues related to his time at LPL Financial. Mr. von Borstel was
permitted to resign from LPL Financial and has worked to create robust recordkeeping and compliance
systems at von Borstel & Associates, Inc. Mr. von Borstel is always happy to discuss any questions
related to this matter and more information is available at https://adviserinfo.sec.gov/
Item 10 – Other Financial Industry Activities and Affiliations
As noted above, some Representatives are also licensed to sell insurance and may receive
commissions from the sales of insurance products such as life, disability and fixed annuities. Should a
client wish to purchase insurance from the Representatives with assets that are not advisory assets,
the client will pay the premium or commission on those assets that are separate and distinct from any
Advisory Fee. This could create a conflict for the Representative to sell a product to make a
commission—but in all cases the client interests must be placed before ours. Representatives, when
acting as an insurance Agent may also receive commission trails from the sale of insurance products.
As noted earlier, we utilize Holistiplan, a third-party tax planning and analysis software, to assist in
providing financial planning and tax-efficient investment strategies to our clients. We pay a subscription
fee to Holistiplan for access to their platform, but we do not receive any referral fees, commissions, or
other monetary compensation from Holistiplan for using their services or recommending their reports
to clients. Holistiplan performs automated "scans" of client tax returns to identify potential planning
opportunities, such as Roth conversions, tax-bracket management, and charitable giving strategies.
While Holistiplan provides data analysis, we remain solely responsible for the investment advice and
financial planning recommendations provided to you. The use of this software does not create a
material conflict of interest, as our firm’s compensation is not tied to the specific software used or the
implementation of any specific tax strategy identified by the platform. It is important to note that
Holistiplan is a software tool and does not provide legal, tax, or accounting advice. Clients are
encouraged to consult with their qualified tax professional or CPA regarding the implementation of any
strategy identified through the Holistiplan analysis.
As noted earlier, we primarily utilize the investment products of DFA as the primary building blocks for
client portfolios. A significant conflict of interest exists because our investment advice is primarily limited
to the universe of mutual funds and ETFs managed by DFA. We do not typically research or recommend
other fund families, even if another firm offers a similar product with better performance or lower internal
expenses. To maintain access to DFA’s institutional funds, our firm’s advisors must attend DFA
educational sessions and maintain a thorough understanding of their "factor-based" investment
philosophy. This creates an incentive for our firm to continue using DFA products to justify the time and
resources invested in that relationship, rather than conducting an exhaustive search of the entire
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market. We mitigate this conflict by periodically reviewing DFA’s funds against relevant benchmarks to
ensure they remain a viable option for our clients. However, you should be aware that you may be able
to find similar investment strategies elsewhere at a lower cost or with different performance
characteristics.
As noted above, we have agreement(s) with broker-dealers to provide investment advisory services to
Brokerage Customers. Broker-dealers pay us compensation for providing investment advisory services
to Brokerage Customers following Brokerage Customers executing a written advisory agreement. This
relationship presents conflicts of interest. Potential conflicts are mitigated by Brokerage Customers
consenting to receive investment advisory services from us; by us not accepting or billing for additional
compensation on broker-dealers’ assets under management beyond the advisory fees disclosed in Item
5; and by us not engaging as, or holding itself out to the public as, a securities broker-dealer. We are
not affiliated with any broker-dealer.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and
Personal Trading
We have implemented policies and procedures to govern our employees and to mitigate the conflicts
of interest we encounter when providing our advisory services to clients. These include:
• A Code of Ethics that each employee is required to review and sign an acknowledgement of
receipt and understanding (upon hire, and annually);
• Prohibitions on the misuse of material non-public information;
• Personal securities trading policies and procedures (governing not only our employee but also
the members of their household and any other securities or brokerage accounts where they have
beneficial ownership of with a spouse, family member or other person). Employees are not
allowed to:
o Trade on inside information.
o “Front-run” or trade in anticipation of client transactions.
o Trade or participate in any activity prohibited under the federal securities laws.
o Place their interests in front of clients.
We strive to achieve the highest ethical and fiduciary standards (in dealing with Clients, the public,
vendors, prospective clients and each other). As a fiduciary, we have an affirmative duty to act with
integrity, competence and care; this includes disclosing all potential and actual conflicts of interest.
It may be possible for the Representative to buy or sell securities in their personal accounts that were
also purchased in client accounts. Advisor has a strict policy against using the trade flow of clients to
economically benefit the Representative or Advisor. Advisor monitors the transactions of
Representative’s accounts to ensure that client interests are placed first.
We perform services for various other clients. We may give advice or take actions for our clients that
differ from the advice given to other clients. The timing or nature of any action taken for all clients or
other sponsors may also vary. For more information or to request a copy of our Code of Ethics, please
contact us at (541) 296-6669.
Item 12 – Brokerage Practices
We recommend Schwab as a Custodian. We are independently owned and operated and are not
affiliated with Schwab or any Custodian. Schwab holds client assets and provides us access to its
institutional brokerage—trading, custody, reporting and related services. While we recommend
Schwab to hold your assets and assist you in buying and selling securities when instructed, you will
need to open an account with them by filling their account agreement. If you decline to open an account
with Schwab, we may decline to manage your assets; however, we will do our best to review the
circumstances.
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Factors we have used to recommend Schwab include trading costs, transition assistance (assistance
with client paperwork and various benefits and payments for offsetting account transfer fees,
technology, compliance, reputation, quality, set-up fees, marketing and mailing costs, office space
expenses, staffing, etc.), electronic access to trading and client accounts, an existing and historical
relationship, assistance with purchasing or discounts on software, products and services, compliance,
invitations or admissions to marketing or educational seminars and conferences, research, technology
and other support that may benefit us, but not the client. This could create a conflict that the
recommendation of Schwab is based on the benefits we receive and not based on Schwab providing
the best execution for transactions in client accounts. We believe, however, that our decision to
recommend Schwab as Custodian is in the best interests of our clients. Our selection is primarily
supported by the scope, quality, and price of Schwab’s services and not Schwab’s services that benefit
only us.
Schwab Advisor Services is Schwab’s business serving independent investment advisory firms like us.
They provide us and our clients with access to their institutional brokerage services (such as trading,
custody, reporting, and related services), many of which are not typically available to Schwab retail
customers. Schwab also makes available various support services that benefit us but may not directly
benefit our clients’ accounts. These products and services assist us in managing and administering our
clients’ accounts. Many of these products and services may be used to service all or some substantial
number of our accounts, including accounts not maintained at Schwab.
Schwab’s products and services that assist us in managing and administering clients’ accounts include
software and other technology that (i) provide access to client account data (such as trade confirmations
and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple
client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of our fees
from our clients’ accounts; and (v) assist with back-office functions, recordkeeping, and client reporting.
Schwab also offers other services intended to help us manage and further develop our business
enterprise. These services may include: (i) compliance, legal and business consulting; (ii) publications
and conferences on practice management and business succession; and (iii) access to employee
benefits providers, human capital consultants and insurance providers. Schwab may provide some of
these services itself, or in some cases will arrange for third-party vendors to provide these services to
us. Schwab may discount or waive fees for some of these services or pay all or a part of the fees of a
third-party providing these services to us. Schwab may also provide other benefits to our employees
such as educational events or occasional business entertainment. In evaluating whether to recommend
that our clients custody their assets at Schwab, we take into account the availability of some of the
foregoing products and services and other arrangements as part of the total mix of factors we consider
and not solely on the nature, cost or quality of custody and brokerage services provided by Schwab,
which can create a conflict of interest since our recommendation that our clients maintain accounts at
Schwab may be based in part on the availability to us of all or some of the products or services
described above.
Schwab generally does not charge clients separately for custody services, but may be compensated
by fees or commissions on trades executed in your account. Of course, certain trades may not incur
commissions. We have determined that having Schwab execute client trades is most effective and is
within our duty to seek “best execution.” That means that we seek a balance of favorable terms beyond
cost when selecting broker dealers and custodians.
In some cases, the Representative may aggregate or block trade multiple client accounts. Doing so
allows some efficiency in the transactions, although it does not ensure that clients will receive a better
execution price than if the trade was enacted separately.
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Item 13 – Review of Accounts
Client accounts are reviewed on at least a quarterly basis by the Representative or their assignees.
However, clients may request more frequent reviews. There are many factors that might bring about a
review of accounts, including regular review dates, supervision reviews, economic changes, political
disruptions or other market activity.
We encourage clients to carefully review any reports we provide with the statements provided by the
Custodian. Also, we encourage clients to contact their Custodian immediately if they do not receive
their statement directly from the Custodian on at least a quarterly basis.
Client supervision reviews are also conducted on a regular basis and may be completed by the Chief
Compliance Officer, assignees, third-party consultants or administrative associates. The review
includes the performance of the accounts and positions. It is critical that clients report any changes in
their financial situation so we can ensure they are invested properly.
Item 14 – Client Referrals and Other Compensation
While we do receive occasional referrals from clients and other professional service providers, we do
not have any formal arrangements in place for referrals. Nor do we compensate any person or entity
for referrals.
We receive an economic benefit from Schwab in the form of the support products and services it makes
available to us and other independent investment advisors whose clients maintain their accounts at
Schwab. These products and services, how they benefit us, and the related conflicts of interest are
described above, See Item 12. The availability to us of Schwab’s products and services is not based
on us giving particular investment advice, such as buying particulars securities for our clients.
Item 15 – Custody
As noted in the Advisory Agreement signed by the client for Investment Management Services, we have
the ability to deduct our advisory fee directly from client accounts. Additionally, we are reporting custody
on certain accounts where the client has requested the ability to electronically transfer assets to a third-
party (through a standing limited power of attorney) when written authorization is provided by the client.
Although, we do not have any relationship, affiliation or share an address with any of the third-parties,
we are following SEC guidelines to report having custody of these assets. Other than these situations,
we do not have custody of any client Assets.
Item 16 – Investment Discretion
Clients grant us discretion through a limited power of attorney to select, purchase, or sell securities
without obtaining client specific consent within client accounts. Our Advisory Agreement will provide us
discretion authority to trade accounts.
Item 17 – Voting Client Securities
We will not vote proxies for securities held in client accounts. Clients will receive information from the
custodian on how to vote proxies or organizational matters.
Item 18 – Financial Information
We are not aware of any circumstance that is reasonably likely to impair our ability to meet contractual
commitments to clients. We do not require pre-payment of Advisory Fees in excess of $1,200 and more
than six months in advance.
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Form ADV Part 2B
Form ADV Part 2B
March 20, 2026
Wayne von Borstel, CFP®, CLU®, ChFC®, CKA®, MSFS
von Borstel & Associates, Inc.
308 East 3rd Street
The Dalles, Oregon 97058
(541) 296-6669
vonborstel.com
Pa
This Brochure supplement provides information about Wayne von Borstel (CRD #1419351) that supplements the von
Borstel & Associates, Inc. brochure. Client should have received a copy of that Brochure. Please contact us at (541) 296-
6669 or staff@vonborstel.com to receive the Advisor’s Brochure or for any questions about the contents of this supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov.
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Item 2 – Educational Background and Business Experience
Wayne von Borstel was born 1955. He has been in the financial services industry since 1985. From 1985
through 2001 he was with Mony Securities Corporation. From 1992 through 2014 he provided investment
services through von Borstel & Associates, Inc (formally Oregon Trail Financial Services, Inc.). From 2001 he
was a registered representative (“RR”) with LPL Financial and an investment advisor representative (“IAR”) with
Financial Advocates Investment Management in 2017. In 2020, he registered von Borstel & Associates where
he is owner and an IAR. In 2000 he earned the Master of Science in Financial Planning from the American
College. He has also earned his Certified Financial Planner® (“CFP®”), his Chartered Life Underwriter® (“CLU®
”) and his Chartered Financial Consultant® (“ChFC® ”). Mr. von Borstel also has his Certified Kingdom Advisor
(“CKA”) designation. In 2000, he obtained his Master of Science in Financial Services (MSFS), which he
obtained from the American College of Financial Services.
The CFP® designation identifies individuals who have completed the mandatory examination, education,
experience, and ethics requirements mandated by the CFP® Board. Candidates must have at least three years
of qualifying work experience that relates to financial planning. CFP® candidates must pass an examination that
covers over 100 financial planning topics, which broadly include: general principles of financial planning,
insurance planning and risk management, employee benefits planning, investment planning, income tax
planning, retirement planning, and estate planning. Finally, candidates have ongoing ethics requirements and
oversight by the CFP® Board and 30 hours every two-years of continuing education.
The CLU® designation requires three years of full-time business experience within the five years preceding the
awarding of the designation. Designees must complete five core and three elective courses, equivalent of 24
semester credit hours and meet ethics standards and agree to comply with the American College Code of Ethics
and Procedures. There is a requirement for 30 hours of continuing education every two years.
The ChFC® designation requires three years of full-time business experience within the five years preceding the
awarding of the designation. Designees must complete seven core and two elective courses, equivalent to 27
semester credit hours and meet ethics standards and agree to comply with the American College Code of Ethics
and Procedures. There is a requirement for 30 hours of continuing education every two years.
To obtain the MSFS designation an individual must successfully complete 10 courses, four core residency and
six concentration courses. Continuing education requirements for the MSFS is 30 credit hourse of CE every two
years, including 1 hour of ethics.
To become a CKA®, applicants must have certain approved degrees or certifications, such as JD, CPA, CFP,
ChFC, and CPA, or 10 years of experience in their designated field. They must also complete the CKA
educational program, which includes coursework on faith-based financial planning, and pass the CKA exam.
Item 3 – Disciplinary Information
In 2022, Mr. von Borstel entered into an agreement with FINRA, a former regulator, agreeing to the imposition of
a suspension and fine (deferred) based upon recordkeeping issues related to his time at LPL Financial. Mr. von
Borstel was permitted to resign from LPL Financial and has worked to create robust recordkeeping and
compliance systems at his new advisory firm. Mr. von Borstel is always happy to discuss any questions related
to this matter.
Item 4 – Other Business Activities
There are no other business activities.
Item 5 – Additional Compensation
Mr. von Borstel receives commissions from previously sold insurance commissions and income from von Borstel
& Associates, Inc.
Item 6 – Supervision
Sandy Aguirre is the Chief Compliance Officer of von Borstel & Associates, Inc. and is solely responsible for the
supervision and oversight of all supervised persons. She can be reached at (541) 296-6669.
12
Form ADV Part 2B
March 20, 2026
Craig Smith, CFA®, CFP®, CKA®, ChFC®, CLU®
von Borstel & Associates, Inc.
308 East 3rd Street
The Dalles, Oregon 97058
(541) 296-6669
vonborstel.com
Pa
This Brochure supplement provides information about Craig Smith (CRD #5324542) that supplements the von Borstel &
Associates, Inc. brochure. Client should have received a copy of that Brochure. Please contact us at (541) 296-6669 or
staff@vonborstel.com to receive the Advisor’s Brochure or for any questions about the contents of this supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov.
Item 2 – Educational Background and Business Experience
Craig Smith was born in 1980. He graduated from the University of Portland with a Bachelor of Science in Civil
Engineering in 2002. He began working in the financial services industry in 2007 as a Registered Representative
13
(“RR”) for Mass Mutual. He was an Investment Advisor Representative (“IAR”) with Oregon Trail Financial
Services (later renamed von Borstel & Associates, Inc.) from 2009 to 2014. From 2009 to 2020 he was a RR
with LPL Financial and in 2017 was an IAR with Financial Advocates Investment Management. He affiliated with
von Borstel & Associates, Inc. in 2020 as an IAR. In 2018 he earned his Chartered Financial Analyst (“CFA®”)
designation. He has also earned his Certified Financial Planner® (“CFP®”), Chartered Financial Consultant®
(“ChFC® ”) and his Chartered Life Underwriter® (“CLU® ”).
To qualify for a Chartered Financial Analyst (“CFA®”), candidates must meet standards for examination,
education, experience, and ethics. Candidates must possess a bachelor’s degree from an accredited school, or
its equivalent. Candidates must have completed 48 months of qualified work experience. Third, candidates must
pass a series of three six-hour exams that covers ethics, quantitative methods, economics, corporate finance,
financial reporting and analysis, security analysis, and portfolio management. Finally, candidates must meet and
continue to adhere to a strict Code of Ethics and Standards governing their professional conduct, as reviewed
by the CFA Institute.
The CFP® designation identifies individuals who have completed the mandatory examination, education,
experience, and ethics requirements mandated by the CFP® Board. Candidates must have at least three years
of qualifying work experience. CFP® candidates must pass an examination that covers over 100 financial
planning topics, which broadly include: investment, financial, retirement, estate and insurance planning, risk
management, employee benefits planning, income tax planning. The designation has ongoing ethics
requirements and oversight by the CFP® Board and 30 hours every two-years of continuing education.
The CLU® designation requires three years of full-time business experience within the five years preceding the
awarding of the designation. Designees must complete five core and three elective courses, equivalent of 24
semester credit hours and meet ethics standards and agree to comply with the American College Code of Ethics
and Procedures. There is a requirement for 30 hours of continuing education every two years.
The ChFC® designation requires three years of full-time business experience within the five years preceding the
awarding of the designation. Designees must complete seven core and two elective courses, equivalent to 27
semester credit hours and meet ethics standards and agree to comply with the American College Code of Ethics
and Procedures. There is a requirement for 30 hours of continuing education every two years.
To become a CKA®, applicants must have certain approved degrees or certifications, such as JD, CPA, CFP,
ChFC, and CPA, or 10 years of experience in their designated field. They must also complete the CKA
educational program, which includes coursework on faith-based financial planning, and pass the CKA exam.
Item 3 – Disciplinary Information
There are no disciplinary events.
Item 4 – Other Business Activities
As an Insurance Agent licensed with various insurance companies, Mr. Smith is licensed to receive typical and
customary commission compensation for the purchase or sale of insurance products and services. This
compensation is in addition to and not credited against advisory fees earned by von Borstel & Associates, Inc.
There is a potential conflict of interest from these commission that are fully disclosed in Item 5 and Item 10 of
the attached Form ADV Part 2A.
Item 5 – Additional Compensation
Mr. Smith receives commissions from insurance sales and income from von Borstel & Associates, Inc.
Item 6 – Supervision
Sandy Aguirre is the Chief Compliance Officer of von Borstel & Associates, Inc. and is solely responsible for the
supervision and oversight of all supervised persons. She can be reached at (541) 296-6669.
14
Form ADV Part 2B
March 20, 2026
Anson Lilienthal
von Borstel & Associates, Inc.
308 East 3rd Street
The Dalles, Oregon 97058
(541) 296-6669
vonborstel.com
Cover Pa
This Brochure supplement provides information about Anson Lilienthal (CRD #7189315) that supplements the von Borstel
& Associates, Inc. brochure. Client should have received a copy of that Brochure. Please contact us at (541) 296-6669 or
staff@vonborstel.com to receive the Advisor’s Brochure or for any questions about the contents of this supplement.
Additional information is available on the SEC’s website at www.adviserinfo.sec.gov.
15
Item 2 – Educational Background and Business Experience
Anson Lilienthal was born in 1990. He earned an Associates of Applied Science from Portland
Community College in 2014. Anson began working with von Borstel and Associates in 2019 and
became an investment advisor representative in 2023. Previously, he was self-employed in Sales for
Events from 2015 to 2019. He worked in Banking at the Oregonians Credit Union from 2013-2015.
From 2012 to 2014 he was a student at Portland Community College.
Item 3 – Disciplinary Information
There are no disciplinary events.
Item 4 – Other Business Activities
There are no other business activities.
Item 5 – Additional Compensation
There is no additional compensation outside of the employment at von Borstel & Associates, Inc.
Item 6 – Supervision
Sandy Aguirre is the Chief Compliance Officer of von Borstel & Associates, Inc. and is solely responsible
for the supervision and oversight of all supervised persons. She can be reached at (541) 296-6669.
16