ALIGN IMPACT, LLC

Align Impact, LLC Form ADV Part 2A March 31, 2025 Address: 1001 Bannock St, 3Rd Floor Denver, CO 80204 Phone: (805) 243-8055 Website: https://alignimpact.com Email: info@alignimpact.com This brochure provides information about the qualifications and business practices of Align Impact, LLC. If you have any questions about the contents of this brochure, please contact us at the phone number or email address listed above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Align Impact, LLC is an investment adviser with the SEC. Registration as an investment adviser does not imply a certain level of skill or training. Additional information about Align Impact, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Align Impact, LLC’s CRD number is: 176516.  Item 2: Material Changes In this Item, Align Impact, LLC is required to identify and discuss material changes since filing its last annual amendment on March 26, 2024. The following material changes have occurred since its last filing: The address listed in Item 1 has been amended. The amount of regulatory assets under management listed in Item 4.E. has been updated. Additional risk factors were disclosed in Item 8. An additional affiliation has been disclosed in Item 10. Custody practices have been updated in Item 15. 2  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ............................................................................................................................ 2 Item 3: Table of Contents ............................................................................................................................. 3 Item 4: Advisory Business ............................................................................................................................ 4 Item 5: Fees and Compensation ................................................................................................................... 6 Item 6: Performance-Based Fees and Side-by-Side Management ................................................................. 9 Item 7: Types of Clients ................................................................................................................................ 9 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss .......................................................... 9 Item 9: Disciplinary Information ................................................................................................................ 16 Item 10: Other Financial Industry Activities and Affiliations ....................................................................... 16 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................... 17 Item 12: Brokerage Practices ..................................................................................................................... 18 Item 13: Review of Accounts ...................................................................................................................... 19 Item 14: Client Referrals and Other Compensation .................................................................................... 20 Item 15: Custody ....................................................................................................................................... 21 Item 16: Investment Discretion .................................................................................................................. 21 Item 17: Voting Client Securities ................................................................................................................ 21 Item 18: Financial Information .................................................................................................................. 22 3  Item 4: Advisory Business A. Description of the Advisory Firm Align Impact, LLC (hereinafter “Align,” “we,” “us,” and “our”) is a Limited Liability Company organized in the State of Delaware. Align was formed in 2015 and is principally owned by our CEO, Jennifer Kenning. Align is an independent, impact- focused advisory firm that aims to increase the effectiveness and alignment of philanthropic grants, impact investments, and mission-related investments. Align works with families, foundations, individuals, institutions, and private funds and provides portfolio management and financial planning services. B. Types of Advisory Services Impact Investing: Financial Planning Align offers impact investing strategy, wealth advisory, and financial planning services (“Impact Strategy services”) to high-net worth individuals and institutions (“Impact Strategy Clients”). Impact Strategy services may include, but is not limited to: values identification, investment risk tolerance, philanthropy strategy including selection and due diligence of donation recipients, tax strategy and estate planning. Impact Investing: Portfolio Management Align offers ongoing portfolio management services to separately managed accounts based on the individual values, goals, objectives, time horizon, and risk tolerance of each client (referred to as “Impact Retainer Clients”). As a first step, Align creates an Impact Investment Policy Statement for each Impact Retainer Client, which outlines the Impact Retainer Client’s current values and financial situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each Impact Retainer Client’s specific situation. Portfolio management services include, but are not limited to, the following: Investment strategy • • Asset selection • Asset allocation • Customized values screening • Risk tolerance • Regular portfolio monitoring Align evaluates the current investments of each Impact Retainer Client with respect to their risk tolerance levels and time horizon. Impact Retainer Clients can decide whether Align will have discretionary authority of their assets under management, which allows Align to select securities and execute transactions without obtaining permission from the Impact Retainer Client prior to each transaction. Based on an Impact Retainer Client’s investment objectives and strategy, Align may outsource the management of all or some of the assets in an Impact Retainer Client’s 4  portfolio to another SEC-registered investment adviser. In such an instance, the Impact Retainer Client will sign a written sub-advisory agreement, which sets forth the specific terms governing the sub-advisory relationship, with the sub-adviser. Align conducts initial and ongoing due diligence on all sub-advisers used by its clients. In addition to separately managed accounts, Align also provides portfolio management services to pooled investment vehicles (“Fund Clients”). Fund Clients include Align Impact Fund, LP; Align Impact Fund II, LP; and Align Impact Fund III, LP. Impact Investing: Institutional Services Align helps advisory firms (“Institutional Clients”) clarify their value proposition, mission statement, and services related to impact investing. Align provides Institutional Clients access to, and ongoing reporting on, its Aspire Platform (“Platform”) of best-in-class, third party managers and investment products that have undergone due diligence by its investment research team and reviewed by its investment committee. The Platform is limited to a subset of the investment opportunities that the investment committee approves for client use. The criteria for consideration for inclusion on the Platform are driven by the demand for and appropriateness of investment opportunities for our Institutional Clients, including size, asset class, and thematic exposure. Align can work with Institutional Clients to provide custom white labeled due diligence services for client-mandates. This service typically requires an initial engagement to clarify the criteria and is usually designed around a pre-determined plan for sourcing and decision-making as well. Align provides training and educational support through a regular cadence of calls with Institutional Clients. Select examples of topics covered in the past include shareholder engagement, green bond issuance, faith-based investing, ESG rating methodologies, navigating Opportunity Zone, and investing in Pay for Success contracts. Services Limited to Specific Types of Investments Align specializes in impact investing and generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds and private placements. Align may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions As part of its portfolio management services, Align will create a customized portfolio for each Impact Retainer Client based on their social values and preferences to divest from or invest more heavily in particular stocks or industries. This will include multiple interview sessions to get to know the Impact Retainer Client’s specific needs and requirements as well as a plan that will be executed by Align on behalf of the client. Align may use model portfolios together with a specific set of recommendations for each Impact Retainer Client based on their personal restrictions, needs, and targets. Impact Retainer Clients may impose restrictions in investing in certain securities or types of 5  securities in accordance with their values or beliefs. However, if the restrictions prevent Align from properly servicing the account, or if the restrictions would require Align to deviate from its standard suite of services, Align reserves the right to end the relationship. For Fund Clients, Align tailors its advisory services to meet the investment strategy, risk tolerance, and goals set forth in Fund Clients’ governing documents. Align does not tailor its advisory services to the individual needs of investors in Fund Clients and does not accept investor-imposed investment restrictions. Align tailors its Impact Strategy services to meet the individual needs of its Impact Strategy Clients, who may impose restrictions on the type of securities and plans recommended. D. Wrap Fee Programs Align does not participate in any wrap fee programs. E. Assets under Management As of March 14, 2025, Align had the following amounts of assets under management: $435,384,439 Discretionary: Non-Discretionary: $346,881,601 $782,266,040 Total: Item 5: Fees and Compensation A. Fee Schedule and Payment Impact Investing: Financial Planning Impact Strategy Clients pay impact strategy fees. The amount and frequency of payment is outlined in each Impact Strategy Client’s engagement agreement. Typically, 50% of fees are due in advance upon engagement, but never more than six months in advance, 25% is due three months after the effective engagement agreement date, and the remaining 25% of the financial planning fee is due upon completion of the impact strategy. If the engagement is terminated prematurely, impact strategy fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. Fees are negotiated and generally range from $50,000 to $200,000, depending on complexity and the amount of assets under consideration among other factors. Fees are billed to the Impact Strategy Client and may be paid electronically or by check. Impact Investing: Portfolio Management Impact Retainer Clients are charged portfolio management fees (“Investing Fees”) on a 6  quarterly basis. Investing Fees are due in advance and are payable electronically or by check. When authorized by the client in writing, we will withdraw our fees directly from the client’s account(s). The Firm allows each Impact Retainer Client to select an asset- based fee structure, a flat fee structure, or a combination of both. The selection will be encapsulated in the Impact Retainer Client’s written engagement agreement. Investing Fees are negotiable. Flat fees typically range from $100,000-$800,000 and are negotiable in certain circumstances. Impact Retainer Clients whose assets (whether a portion or in its entirety) are managed by a sub-advisor will sign a written sub-advisory agreement with the sub-advisor. Align works to negotiate favorable sub-advisory fees for Impact Retainer Clients but is not involved in collecting them. Any fees owed to the sub- advisor are separate and distinct from the advisory fees owed to Align. We treat cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed in writing, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under management for purposes of calculating our advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), we may maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss market advances and, depending upon current yields, at any point in time, our advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions. Upon termination of the Impact Retainer advisory relationship, Investing Fees paid in advance will be refunded equal to the amount of fees allocated to the number of days left in the quarter. This can be calculated by multiplying the daily rate (equal to the annual fee rate divided by 365) by the number of days left in the quarter (not including the date of termination). The Firm provides portfolio management and investment advisory services to its Funds Clients and is compensated by asset-based management fees (“Fund Management Fees”), which are calculated based upon a percentage of either the committed capital to or the net asset value of the Fund Client. Fund Management Fees are non-negotiable and typically range from 0.5%-1.5%, depending on the Fund Client. Additionally, Align receives performance-based fees (“Performance Fees”) for the management of Align Impact Fund II, LP and Align Impact Fund III, LP. Performance Fees are based upon a percentage of the net profits of the account being managed, specifically 5% carried interest above a 10% preferred return. Fund Management Fees are typically calculated and paid either quarterly in advance or quarterly in arrears. Performance Fees are typically calculated and paid in anticipation of distributions made to investors, on either a fund-as-a-whole or deal-by-deal basis. Fund Management Fees and Performance Fees for each Fund Client are outlined in the respective private placement memoranda. The Fund Client’s fund administrator will include any fund-related fees in investor capital call notices. As the capital calls are collected, the fund administrator will remit the appropriate fees to Align for its services as outlined in each Fund Client’s private placement memoranda. 7  Impact Investing: Institutional Services Align charges Institutional Clients a flat annual fee that ranges from $100,000-$400,000 for access to its Platform of best-in-class, third party managers and investment products that have undergone due diligence by its investment research team and reviewed by its investment committee. These fees are negotiable in certain circumstances. The Platform is limited to a subset of the investment opportunities that the investment committee approves for client use. The criteria for consideration for inclusion on the Platform are driven by the demand for and appropriateness of investment opportunities for our Institutional Clients, including size, asset class, and thematic exposure. This flat annual fee is paid in advance in quarterly installments. Our add-in services, including our training and education support service and custom white labeled due diligence services, are available for additional fees, based on the complexity of such services. The additional fees are typically flat fees, with 50% of the fee due up-front, 25% three months after the effective date of the engagement, and the remainder due upon completion. Institutional Clients receiving these services will receive an invoice from Align and may submit payment via ACH, check, or wire. Upon termination of service, Align will issue a refund for any pre-paid fees for services not yet provided. B. Client Responsibility for Third Party Fees In addition to the fees charged by Align, clients should expect to incur other fees and costs payable to third parties, including (but not limited to) custodian fees, brokerage fees, mutual fund fees, ETF fees, fund administration fees, sub-advisory fees, and transaction fees. Those fees are separate and distinct from the fees and expenses charged by Align. Please see Item 12 of this brochure regarding broker-dealer/custodian services and fees. C. Prepayment of Fees Refunds for fees paid in advance will be returned within fourteen days to the client via check or return deposit back into the client’s account. The amount refunded will be equal to the amount of fees allocated to the number of days left in the quarter. This can be calculated by multiplying the daily rate (equal to the annual fee rate divided by 365) by the number of days left in the quarter (not including the date of termination). For Impact Strategy Clients, fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. D. Outside Compensation for the Sale of Securities to Clients Neither Align 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. 8  Item 6: Performance-Based Fees and Side-by-Side Management As outlined above, Align receives Performance Fees for the management of Align Impact Fund II, LP and Align Impact Fund III, LP. Performance Fees are based upon a percentage of the net profits of the account being managed, specifically 5% carried interest above a 10% preferred return. No other clients are charged a performance-based fee. Align’s receipt of Performance Fees with respect to Align Impact Fund II, LP and Align Impact Fund III, LP may create an incentive to favor these clients. However, these accounts’ managed assets represent less than 2.2% of Align’s total assets under management, thereby limiting this incentive. Item 7: Types of Clients Align generally provides advisory services to the following types of clients and investors: Institutions • High Net Worth Individuals • Charitable Organizations • Corporations or Business Entities • • Pooled Investment Vehicles There is currently no minimum account size; however, Align does have a minimum annual fee of $50,000. These fees are negotiable in certain circumstances. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis Align’s methods of analysis include quantitative analysis and modern portfolio theory. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. 9  Modern portfolio theory is a theory of investment which attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, by carefully choosing the proportions of various assets. Impact and ESG (environmental, social, and governance) analysis is evaluated across three categories: • • • Theory of Change is, in the case of a fund, the fund’s overall philosophy of how its capital will produce a positive social and/or environmental impact and a description of the expected impact return, or impact outcomes, that will be produced. Impact Execution evaluates if the fund has the people, plans, and processes to set it up for impact success, and how market factors contribute to or detract from achieving its impact goals. Impact Monitoring is a combination of current practices and future plans that the fund has in place to measure impact, share learnings, and make better impact decisions as a result of the measurement. Impact monitoring is a combination of impact measurement and impact reporting. Investment Strategies Align uses long term trading and short term trading. 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 Quantitative Model Risk: Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Modern Portfolio Theory assumes that investors are risk adverse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off is the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk/expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Impact and ESG Risk: Align leverages Impact Management Project’s (IMP) impact risks framework across private market investments to identify if and how the impact return will be different than expected. These risks include Evidence Risk, Stakeholder Participation Risk, Fallacy Risk, Additionality Risk, Efficiency Risk, Execution Risk, Alignment Risk, 10  Endurance Risk, Drop-off Risk, External Risk, and Unintended Impact Risk. It should be noted that it is not possible to mitigate or foresee all risk. Investment 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. 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 a 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. Selection of Sub-advisers: Although Align will seek to select only money managers who will invest clients' assets with the highest level of integrity, Align's selection process cannot ensure that money managers will perform as desired and Align will have no control over the day-to-day operations of any of its selected money managers. Align would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulator breach or fraud. Investing in securities involves a risk that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (excluding some fixed income investments) 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. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry market conditions and general economic environments. Investments can be made in privately-held companies or publicly-held companies listed on 11  exchanges. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can 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, and individual bonds. In general, the fixed income market can be volatile and heavily impacted by interest rates. As interest rates rise, bond prices usually (though not always) 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. While the risk of default on fixed income products issued by the U.S. Treasury exists, it tends to be extremely low. However, this risk depends on numerous factors that are susceptible to change, such as government policy. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value, or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds costs to your portfolio, thus counteracting the low fees that is one of the typical benefits of ETFs. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. Losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. An ETF may trade at a premium or discount to its net asset value. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. 12  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. Private equity and venture capital funds carry many risks. Capital calls can be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Investments in these funds are speculative in nature, and they are designed for sophisticated investors who are capable of bearing the risk of the loss of their investment. There is no guarantee that the fund will achieve its investment objective. Investments in these funds carry high liquidity risk, and it may be difficult for the investor to exit the investment and for the fund to exit out of existing positions. Exit strategies can be adversely impacted by numerous factors, many of which may be unforeseen or unexpected at the time the investments are made. Generally, shares in these funds are restricted and cannot be sold in a public market. Transfer options are limited, if available. A fund may encounter difficulty finding attractive investment opportunities. While Align typically conducts a level of due diligence that it deems reasonable and appropriate based on the facts and circumstances applicable to an investment, limited availability of information may hinder its ability to conduct a comprehensive analysis of an investment. Additionally, any financial projections presented are inherently uncertain, and it is impossible to predict future results. For venture capital funds in particular, most investments are made in start-up companies at early stages of development; the risk of start-up companies’ failure is high. Returns, if any, are typically generated only through realization events. Private debt direct investments carry certain risks. Considerations include potential default, limited liquidity and the infrequent availability of independent credit ratings for private companies. Opportunities to dispose of positions may be extremely limited, if available. Private placements in general carry substantial risks as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, and liquidation (if available) may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Private placements are not available in public markets, which further restricts their liquidity. Catalytic investments, as defined by Mission Investors Exchange, are investments that accept disproportionate risk and/or lower returns relative to a conventional investment in order to generate positive impact and/or enable third-party investment that otherwise would not be possible. Catalytic investments can be made in the form of private debt 13  investments, private equity investments, private placements, venture capital funds and carry risks outlined for those investment strategies. Additional considerations include concessionary return and limited marketability. 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. Inflation Risk, also known as Purchasing Power Risk, arises from the decline in value of securities cash flow due to inflation, which is measured in terms of purchasing power. Inflation can be heavily impacted by various macroeconomic factors, including interest rates and tariffs. Interest Rate Risk is the risk that an investment's value will change due to a change in the absolute level of interest rates, spread between two rates, shape of the yield curve, or in any other interest rate relationship. Interest rate risk is especially prevalent in fixed income securities but can also impact other asset classes. Market Risk, also called systematic risk, is the possibility of an investor experiencing losses due to factors that affect the overall performance of the financial markets in which they are involved. This type of risk can be hedged against but cannot be eliminated through diversification. Sources of market risk include recessions, political turmoil, changes in interest rates, natural disasters, pandemics, terrorist attacks, and black swan events. Regulatory Risk is the risk that a change in laws and/or regulations will materially impact a security, business, sector or market. These changes can increase the costs of operating a business, reduce the attractiveness of an investment, or change the competitive landscape, and are made by either the government or a regulatory body. Liquidity Risk stems from the lack of marketability of an investment that cannot be bought or sold quickly enough to prevent or minimize a loss. It is typically reflected in unusually wide bid-ask spreads or large price movements. Typically, the smaller the size of the security or its issuer, the larger the liquidity risk. Investments in private placements also present their own unique set of liquidity risk due to the restrictive terms of the investment and the fact that they cannot be sold on the public market. Credit Risk traditionally refers to the risk that a lender may not receive owed principal and interest, which results in an interruption of cash flows and increased costs for collection. Credit risk is the probable risk of loss resulting from a borrower's failure to repay a loan or meet contractual obligations. It is impossible to know exactly who will default on obligations, but proper assessments and credit risk management can help mitigate the risk of loss. Cybersecurity Risks: Our firm and our service providers are subject to risks associated with a breach in cybersecurity. Cybersecurity is a generic term used to describe the technology, processes, and practices designed to protect networks, systems, computers, programs, and data from cyber-attacks and hacking by other computer 14  users, and to avoid the resulting damage and disruption of hardware and software systems, loss or corruption of data, and/or misappropriation of confidential information. In general, cyber-attacks are deliberate; however, unintentional events may have similar effects. Cyber-attacks may cause losses to clients by interfering with the processing of transactions, affecting the ability to calculate net asset value or impeding or sabotaging trading. Clients may also incur substantial costs as the result of a cybersecurity breach, including those associated with forensic analysis of the origin and scope of the breach, increased and upgraded cybersecurity, identity theft, unauthorized use of proprietary information, litigation, and the dissemination of confidential and proprietary information. Any such breach could expose our firm to civil liability as well as regulatory inquiry and/or action. In addition, clients could be exposed to additional losses as a result of unauthorized use of their personal information. While our firm has established a business continuity plan and systems designed to prevent cyber-attacks, there are inherent limitations in such plans and systems, including the possibility that certain risks have not been identified. Similar types of cyber security risks are also present for issuers of securities, investment companies and other investment advisers in which we invest, which could result in material adverse consequences for such entities and may cause a client's investment in such entities to lose value. Government Policy Risk: Each governmental regime presents its own set of policy risks that could impact investors. Domestically, the Trump administration has signaled that it will use tariffs, or the threats thereof, as a material policy tool. The scope, implementation, and duration of tariffs imposed by the US government remain uncertain. Industries that rely on imported raw material or that have heavily integrated cross-border manufacturing practices may be most impacted. However, it is challenging to predict the impact of actual and/or threatened tariffs and impossible to predict the administration’s future policy decisions. When tariffs are imposed, there is also a higher probability that retaliatory tariffs could be imposed, which could negatively impact domestic industries and products. Tariffs in general can also permanently alter global supply chains and have far-reaching indirect impacts. Tariffs tend to hurt growth in the long term and add to inflation, which can also lead to pressure on interest rates, impacting various areas of the economy and particularly the fixed income market. Many publicly traded companies are global in nature, generating significant portions of their income abroad and are subject to the risk of protectionist policies. The Trump administration has also embraced drastic cuts to the government workforce and spending, domestically and abroad. A meaningful reduction in the federal workforce and loss of expertise could have destabilizing effects on industries as regulatory and oversight capabilities of the federal government shrink. 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. 15  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-Regulatory Organization (SRO) Proceedings There are no SRO proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker-Dealer or Broker-Dealer Representative Neither Align nor its representatives are registered as, or having 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 Align nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interest Conscious Endeavors LP, an investment manager exempt from registration, is majority owned and managed by Align’s President. It currently serves as the investment manager to a pooled investment vehicle. Align has approved this as a separate outside business activity and reviews this relationship from time to time to ensure that possible conflicts of interest are appropriately managed. D. Selection of Other Advisers or Managers Based on a client’s investment objectives and strategy, Align may outsource the management of all or some of the assets in a client’s portfolio to another SEC-registered investment adviser. In such an instance, the client will sign a written sub-advisory agreement, which sets forth the specific terms governing the sub-advisory relationship, with the sub-adviser. Align conducts initial and ongoing due diligence on all sub-advisers used by its clients. Align works to negotiate favorable sub-advisory fees for clients but 16  is not involved in the collection of such fees. Any fees owed to the sub-adviser are separate and distinct from the advisory fees owed to Align. Align does not receive any compensation from sub-advisers in exchange for sub-advisory business or referrals. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Align has a written Code of Ethics that covers the following areas: Insider Trading, Illegal Activities, Personal Account Trading, Prohibited Transactions, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance with Laws and Regulations, Certification of Compliance, Reporting Violations, Recordkeeping, Sanctions, Whistleblower Protections, and Training. Align's Code of Ethics is available upon request to any actual or potential client or investor. Conflict of interest situations that arise in connection with the management of the assets of clients will be handled on a case-by-case basis. B. Recommendations Involving Material Financial Interests Align and its associated persons may have material financial interests in issuers of securities that Align may recommend for purchase or sale by clients. For example, Align may recommend investments in one or more of its Fund Clients. However, such recommendations only transpire when Align determines it is in the client’s best interest and full disclosure is made to the investor. C. Investing in the Same Securities as Clients Align recognizes that the personal investment transactions of our employees demand the application of a Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we also believe that if investment goals are similar for clients and for our employees, it is logical, and even desirable, that there be common ownership of some securities. From time to time, Align employees may buy or sell securities for themselves that they also recommend to clients. Therefore, to recognize and deal with conflicts of interest, we have established procedures for transactions effected by our employees for their personal accounts. In order to monitor compliance with our personal trading policy, we have pre-clearance requirements and a quarterly securities transaction reporting system for all of our employees. Additionally, no employee may directly or indirectly acquire or dispose of a security on a day in which a client portfolio has a pending “buy” or “sell” order for that security of the same type as the proposed personal trade until the client’s portfolio order is executed or withdrawn. 17  Item 12: Brokerage Practices A. Factors Used to Recommend Broker-Dealers Align acknowledges its obligation to its clients in seeking “best execution” with respect to the execution of client securities transactions. Align considers both quantitative and qualitative factors when evaluating the execution quality of a broker-dealer. For the most part, Align will seek to recommend to clients broker-dealers with the best combination of brokerage expenses and execution quality of transactions, taking into account the full range of services provided. Align is not required to recommend the broker-dealer that charges the lowest transaction cost, even if that broker-dealer provides execution quality comparable to other broker- dealers. In evaluating “execution quality,” factors such as clearance, settlement, error correction capabilities, reliability, responsiveness, liquidity, financial stability, access to support staff, quality of service, and availability of securities will be considered. Currently, Align recommends the use of Charles Schwab Institutional, Fidelity Institutional, and Inspira Financial. Align conducts a best execution review of brokers used on an annual basis. Research and Soft Dollars Align has no formal soft dollars agreement in place. However, the custodial broker- dealers recommended by Align does provide certain products and services that are intended to directly benefit Align, clients, or both. Such products and services include (a) an online platform through which Align can monitor and review client accounts, (b) access to proprietary technology that allows for order entry, (c) duplicate statements for client accounts and confirmations for client transactions, (d) invitations to the custodial broker-dealer’s educational conferences, (e) practice management consulting, and (f) occasional business meals and entertainment. The receipt of these products and services creates a conflict of interest to the extent it causes Align to recommend the provider as opposed to a comparable custodial broker-dealer. Align addresses this conflict of interest by fully disclosing it in this brochure, evaluating its custodial broker- dealers based on the value and quality of their services as realized by clients, and by periodically evaluating alternative broker-dealers to recommend. Brokerage for Client Referrals Align receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. Directed Brokerage While we recommend the use of Charles Schwab Institutional, Fidelity Institutional, and Inspira Financial, Align will consider the use of other broker-dealers upon client request on a case-by-case basis. Transactions through client-directed brokerage may not result in most favorable execution of client transactions; moreover, client-directed brokerage may cost clients more money. Client-directed brokerage may result in higher commissions, which may result in a price disparity between directed and non-directed accounts. Additionally, trades executed in directed accounts cannot be aggregated with non-directed accounts, which may lead to less favorable pricing, especially for illiquid securities or during volatile market conditions. Not all investment advisers allow their 18  clients to direct brokerage. B. Aggregation of Trades Align attempts to aggregate client orders whenever possible, as the aggregation of orders may result in a more favorable net price and/or more efficient execution than if each order were placed separately. However, there may be instances in which order aggregation results in a less favorable transaction than might have been obtained for a client by trading separately. Moreover, when orders are not aggregated, there may be circumstances when purchases or sales of portfolio securities for one or more clients will have an adverse effect on others. Align permits trade aggregation only if the securities order is: • in the best interests of each client participating in the order; • consistent with the Firm’s duty to obtain best execution; and • consistent with the terms of the investment management agreement of each participating client. Trades are allocated in a fair and equitable manner. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All portfolio management accounts are reviewed at least quarterly by the client’s Lead Advisor in light of the client’s unique investment profile and goals. All Lead Advisors are supervised by the President and the Chief Executive Officer. 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 a client's financial situation (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, Align’s services will generally conclude upon delivery of the financial plan, unless the client chooses to engage Align for portfolio management services under a separate investment advisory agreement. C. Content and Frequency of Regular Reports Provided to Clients Impact Retainer Clients will receive a monthly report from their custodian detailing their account, including assets held, asset value, and calculation of fees. From time to time, Impact Retainer Clients will also receive an impact report from Align regarding their investments. Investors in Fund Clients will receive quarterly reports from the fund administrator. Investors in Fund Clients will receive an impact report from Align on an annual basis. 19  Impact Strategy Clients will receive their financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Other than the benefits provided by custodial broker-dealers described in Item 12 and below, Align does not receive any economic benefit, directly or indirectly from any third party for advice rendered to Align's clients. With respect to custodial broker-dealers, Align receives access to certain institutional trading and custody services, which are typically not available to retail investors. These services generally are available to investment advisers at no charge to them so long as a minimum threshold of client assets are maintained in accounts at the custodial broker- dealer. Services include brokerage services that are related to the execution of securities transactions, custody, research, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Custodial broker-dealers also make available to Align other products and services that benefit Align but may not benefit its clients’ accounts. These benefits may include events organized and/or sponsored by the custodial broker-dealer. Other potential benefits may include occasional business entertainment of personnel of Align, including meals, invitations to events and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist Align in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of Align’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Other services include business consulting, publications and conferences on practice management, and information technology. Custodial broker-dealers may discount or waive fees it would otherwise charge for some of these services. B. Compensation for Client Referrals Align does not have any third-party solicitation arrangements at this time. 20  Item 15: Custody Align does not have custody of client accounts of their assets therein. All client accounts are custodied with a qualified custodian. For clients who have their fees deducted from their account(s), Align will generally be deemed to have limited custody over such clients’ funds pursuant to applicable custody rules and guidance thereto. For clients who have provided Align with discretion as to the amount and timing of disbursements pursuant to a standing letter of authorization to disburse funds from their account(s) to a third party, Align will typically be deemed to have limited custody over such clients’ funds or securities pursuant to the SEC’s custody rule and subsequent guidance thereto. At no time will Align accept custody of client funds or securities in the capacity of a custodial broker-dealer or other qualified custodian. Clients should receive account statements directly from their qualified custodian(s) and should review such statements for accuracy. Item 16: Investment Discretion Align provides discretionary and non-discretionary investment advisory services to clients. The governing documents established with each client sets forth whether Align has discretionary authority over the assets in a particular client account. Where investment discretion has been granted, Align generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, Align’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 Align). Item 17: Voting Client Securities Align will accept voting authority for securities in certain cases. When Align does accept voting authority for securities, it will always seek to vote in the best interests of the client. Align will generally vote proxies in accordance with ISS Sustainability Guidelines or the As You Sow Sustainability Guidelines, unless that guidance is not in the best interest of the client. When voting proxies, Align will always hold the interests of the clients above its own interests. The client may direct Align on how to vote securities by communicating their wishes in writing or electronically to Align. The client may obtain the voting record of Align on securities by contacting Align at the phone number or e-mail address listed on the cover page of this brochure. The client may obtain a copy of Align’s proxy voting policies and procedures upon request. 21  Item 18: Financial Information A. Balance Sheet Align neither requires nor solicits 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 Align nor its management has any financial condition that is likely to reasonably impair Align’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in the Past Ten Years Align has not been the subject of a bankruptcy petition in the last ten years. 22