ALM FIRST FINANCIAL ADVISORS LLC

ALM FIRST FINANCIAL ADVISORS, LLC FIRM BROCHURE March 2025  ITEM 1. COVER PAGE ALM First Financial Advisors, LLC 3800 Maple Avenue, Ste. 600 Dallas, TX 75219 https://www.almfirst.com Form ADV Part 2A Brochure March 31, 2025 This brochure provides information about the qualifications and business practices of ALM First Financial Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at: 1-800-752-4628 or info@almfirst.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission, or by any state securities authority. Registration with the United States Securities and Exchange Commission does not imply a certain level of skill or training. Additional information about ALM First Financial Advisors, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 2. SUMMARY OF MATERIAL CHANGES This brochure is the annual update to the Form ADV Part 2A. The updates to this Form ADV Part 2A since the last annual update filed in March 2024 include the following: • Item 5 – Fees and Compensation Item 7 – Types of Clients Item 9 – Methods of Analysis, Investment Strategies, and Risk of Loss Item 15 – Custody Item 4 – Advisory Business: Expanded to include private fund management. Related updates include: o o o o • General Stylistic Updates: Language refined for clarity and consistency. 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 2  ITEM 3. TABLE OF CONTENTS ITEM 1. COVER PAGE .................................................................................................................................................. 2 ITEM 2. SUMMARY OF MATERIAL CHANGES ..................................................................................................... 2 ITEM 3. TABLE OF CONTENTS ................................................................................................................................. 3 ITEM 4. ADVISORY BUSINESS .................................................................................................................................. 5 Firm Description ........................................................................................................................................................ 5 Principal Owners ....................................................................................................................................................... 5 Types of Services ...................................................................................................................................................... 5 Tailored Relationships ............................................................................................................................................. 7 Assets Under Management .................................................................................................................................... 7 Advisory Service Agreement .................................................................................................................................. 7 ITEM 5. FEES AND COMPENSATION ...................................................................................................................... 7 Dual Fees .................................................................................................................................................................... 8 Billing ........................................................................................................................................................................... 8 Past Due Accounts & Termination of Agreement ............................................................................................. 8 ITEM 6. PERFORMANCE BASED FEES ................................................................................................................... 8 ITEM 7. TYPES OF CLIENTS ....................................................................................................................................... 9 Account Minimums ................................................................................................................................................... 9 ITEM 8. METHOD OF ANALYSIS, INVESTMENT STRATEGIES, & RISK OF LOSS ....................................... 9 Methods of Analysis ................................................................................................................................................. 9 Investment Strategies .............................................................................................................................................. 9 Risk of Loss ................................................................................................................................................................. 9 ITEM 9. DISCIPLINARY INFORMATION ................................................................................................................ 10 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS ..................................................... 10 ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING ............................................................................................................................................... 11 Code of Ethics .......................................................................................................................................................... 11 Participation or Interest in Client Transactions ................................................................................................ 11 Personal Trading ..................................................................................................................................................... 11 ITEM 12. BROKERAGE PRACTICES ....................................................................................................................... 12 Selecting Brokerage Firms .................................................................................................................................... 12 Best Execution ......................................................................................................................................................... 12 Soft Dollars............................................................................................................................................................... 12 Trade Aggregation and Allocation ..................................................................................................................... 12 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 3  ITEM 13. REVIEW OF ACCOUNTS ......................................................................................................................... 13 Periodic Reviews ..................................................................................................................................................... 13 Review Triggers ...................................................................................................................................................... 13 Regular Reports ...................................................................................................................................................... 13 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION ..................................................................... 14 Incoming Referrals .................................................................................................................................................. 14 Referrals Out ............................................................................................................................................................ 14 ITEM 15. CUSTODY .................................................................................................................................................... 14 ITEM 16. INVESTMENT DISCRETION .................................................................................................................... 14 Discretionary Authority for Trading .................................................................................................................... 14 Limited Power of Attorney ................................................................................................................................... 14 ITEM 17. VOTING CLIENT SECURITIES ................................................................................................................ 15 ITEM 18. FINANCIAL INFORMATION .................................................................................................................... 15 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 4  ITEM 4. ADVISORY BUSINESS Firm Description Founded in 1995, ALM First Financial Advisors, LLC, is a trusted partner in investment and financial management, specializing in serving financial institutions and institutional investors. As a fee-based advisory firm, we provide consulting, non-discretionary, and discretionary investment management services designed to align with institutional objectives and regulatory requirements. With a focus on delivering insight-driven strategies, we help institutions navigate complex investment landscapes. ALM First operates with a commitment to transparency—we do not sell financial products or securities, and do not accept commissions or finder’s fees. An affiliate, ALM First Executive Benefits, LLC, operates as a licensed insurance agency, offering financial products to support executive benefit and retention strategies. Principal Owners ALM First Financial Advisors, LLC is wholly held by its parent, ALM First Group LLC. ALM First Group, LLC is a Delaware limited liability company with a principal office in Dallas, Texas. ALM First Group, LLC is principally owned by CEO Emily Moré Hollis. Types of Services ALM First Financial Advisors, LLC provides a range of investment and capital markets-based risk management services tailored for institutional investors. These services are designed to support clients in managing investment portfolios, optimizing returns, and mitigating risk. Our advisory services include: Investment Advisory & Portfolio Management We offer both discretionary and non-discretionary investment advisory services focused primarily on fixed-income securities and select alternative investments. Our portfolio management approach is guided by client-specific investment objectives and regulatory considerations. Depending on the service level, we provide: Investment Policy Review & Development – Assessing client investment policies and • recommending adjustments to align with regulatory requirements, risk tolerance, and strategic objectives. • Portfolio Structuring & Strategy Development – Designing customized investment strategies that consider risk exposures, liquidity needs, and yield optimization. 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 5  • Execution & Trade Implementation – Managing investment transactions in accordance with agreed-upon guidelines, whether through direct client approvals (non- discretionary) or under our discretion within pre-established parameters (discretionary). • Ongoing Monitoring & Reporting – Delivering detailed reports on portfolio composition, performance, and risk analytics through regular updates. Hedging & Interest Rate Risk Management For clients exposed to interest rate risk, we provide hedging strategies designed to mitigate volatility while maintaining alignment with regulatory guidelines. Our hedging services include: Interest Rate Derivatives Advisory – Structuring and executing interest rate swaps, • caps, and floors to hedge against rate fluctuations. • Mortgage Pipeline Hedging – Managing interest rate risk associated with mortgage origination pipelines through TBA MBS and other hedging instruments. • MSR Hedging – Assessing and mitigating risks related to mortgage servicing rights (MSRs) through a combination of Treasury securities, interest rate derivatives, and mortgage-backed securities. We provide educational resources and work closely with clients to ensure a comprehensive understanding of these instruments and their application in risk management strategies. Private Fund & Insurance-Based Investment Management We provide investment advisory and management services for institutional investors through private funds and insurance-based investment vehicles. Our services include: • Private Fund Management – Advising and managing private investment funds designed for institutional investors, including financial institutions and nonprofit entities. Each fund operates in accordance with its governing documents, such as private placement memoranda and operating agreements, and is structured to align with institutional investment objectives. Insurance-Based Investment Management – Managing assets within structured • insurance investment vehicles, including stable value annuities separate account institution-owned life insurance. We work with institutions to develop investment strategies that balance stability, liquidity, and return objectives while adhering to regulatory requirements. This approach allows institutional investors to efficiently manage capital within specialized investment structures tailored to their strategic and regulatory needs. 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 6  Tailored Relationships Each client’s investment objectives and constraints are documented in their Investment Policy Statement or similar governing documents. Clients may impose restrictions on investments in certain asset classes, issuers, or transaction types based on their internal policies or regulatory requirements. These restrictions guide our portfolio management approach. However, clients should be aware that such limitations may impact investment flexibility and performance relative to portfolios without similar constraints. For fund accounts and insurance-based solutions, investment objectives and guidelines are detailed in the private placement memorandum and/or operating agreement. Assets Under Management As of December 31, 2024, ALM First Financial Advisors, LLC managed $1,820,110,868 in discretionary and $67,063,463,358 in non-discretionary regulatory assets under management for 160 clients. Advisory Service Agreement Clients engage our firm to receive in-depth, ongoing strategic guidance aligned with their objectives and regulatory requirements. The scope of services and fees are outlined in written agreements, which must be signed by both the client and an authorized representative of ALM First Financial Advisors, LLC before services commence. Agreements generally have a one-year term and automatically renew unless either party provides written notice of termination at least 30 days before renewal. Investment advisory services may be terminated with 30 days’ notice. ITEM 5. FEES AND COMPENSATION ALM First Financial Advisors, LLC structures its fees based on the level of service provided, with customized pricing to reflect the scope and complexity of each client’s investment strategy. Our advisory services include discretionary and non-discretionary investment management, private fund management, insurance-based investment management, and hedging services. Fees are determined through a tiered or fixed structure, negotiated based on the size and composition of assets under management, and may be revised periodically. For discretionary investment management, fees are typically asset-based, with rates declining as assets increase. Non-discretionary and advisory services are generally billed as fixed annual fees, structured according to the size and needs of the institution. Clients investing in private funds 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 7  managed by ALM First pay fund management fees in accordance with the fund’s private placement memorandum, with rates tiered based on fund assets. Hedging services, including mortgage pipeline hedging and MSR hedging, are subject to a one-time start-up fee and an ongoing annual fee, assessed monthly in arrears. The start-up fee is based on the complexity of the strategy and the scope of services required. The ongoing fees are structured based on the notional amount of derivatives utilized, with rates decreasing as the notional amount increases. Most fees are negotiable. Dual Fees In cases where clients engage ALM First for multiple services—such as investment advisory and private fund investments—dual fees may apply. For example, a client investing in a private fund managed by ALM First would pay fund management fees on that investment while separately compensating ALM First for advisory services related to their broader portfolio. Clients should refer to their investment management agreement and the applicable private placement memorandum for details on fees associated with specific services. Billing Fees are typically billed monthly or quarterly, either in advance or in arrears, depending on the service agreement. In certain cases, minimum fees may apply, but ALM First reserves the discretion to adjust fees based on the nature of the engagement. Past Due Accounts & Termination of Agreement Invoices are generally due within 10 days of issuance. If an account remains unpaid for more than 30 days, we reserve the right to suspend services until payment is received or, in certain cases, to terminate the advisory relationship. Additionally, we may terminate an agreement if a client fails to provide necessary information for the effective execution of services. In the event of termination, any prepaid fees will be prorated based on the portion of the billing period in which services were provided, and any unused portion will be refunded within 30 days. ITEM 6. PERFORMANCE BASED FEES Performance-based fees may be charged to certain accounts of qualified clients, ensuring alignment with client objectives without incentivizing excessive risk-taking. We have an incentive to favor accounts for which we receive a performance-based fee. We address these potential conflicts of interest by (i) recognizing our fiduciary duty owed to each client, and (ii) reviewing each client’s objective, strategy and investment guidelines alongside our recommendations. 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 8  ITEM 7. TYPES OF CLIENTS Our clients primarily include financial institutions such as credit unions, community banks, specialty lenders, and insurance companies, among others. We provide these institutions with consulting, non- discretionary and discretionary investment advisory services, as well as the ancillary services described earlier in this document. Client relationships vary in scope and duration, with some institutions maintaining engagements with us for decades. In addition to providing advisory services to individual financial institutions, ALM First Financial Advisors, LLC serves as an investment manager for private funds and institutional investment vehicles. Account Minimums While there is no strict minimum account size for our advisory services, certain service tiers and offerings have minimum fees based on the size and complexity of the client’s investment portfolio and overall assets. Minimum fees and service requirements are determined based on the scope of engagement and are subject to negotiation. Most ongoing advisory services require a minimum contractual commitment. ITEM 8. METHOD OF ANALYSIS, INVESTMENT STRATEGIES, & RISK OF LOSS Methods of Analysis Our investment process uses both top-down and bottom-up assessments of risk and return. A multi- dimensional risk analysis observes macro factor risks in evaluating ex-ante and ex-post returns. Portfolio managers utilize a multitude of internal and external tools and resources, and all investment decisions are reviewed in a risk-adjusted framework. Investment Strategies Our investment strategy for each client is tailored to their goals and objectives, outlined during consultations and in ongoing meetings. Each client signs an Investment Policy Statement that reflects their desired strategy, which is kept on file for easy access by our advisors before making recommendations. Risk of Loss While we focus on fixed income securities, all investments carry risks that could result in a loss of principal or reduced earnings. Clients may face the following risks: 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 9  • Credit Risk: A default by the issuer of a non-collateralized fixed income security or a loss beyond the credit support of a structured security could lead to a loss of principal. • • Financial Risk: Excessive borrowing can increase the risk of business profitability, and failure to meet obligations during financial stress could lead to default, bankruptcy, or a drop in market value. Interest-Rate Risk: Changes in interest rates can cause investment prices to fluctuate. For example, rising interest rates can reduce the market value of existing fixed income securities. • Liquidity Risk: The ease of converting an investment to cash can vary. Generally, larger securities are more liquid. • Market Risk: Fixed income security prices may drop due to external factors such as political, economic, or social conditions. • Reinvestment Risk: Future proceeds may need to be reinvested at lower returns if interest rates decrease. • Natural and Human Disruptions: Events like natural disasters, climate change, war, or public health crises can negatively affect asset values. • Private Fund Risks: Investing in private funds carries risk, including interest rate risk, risks from hedging and derivatives, lack of liquidity, and tax risks. Please see the “Risk Factors” section of the private placement memorandum. • Operational/Cybersecurity Risk: System failures, cyberattacks, or breaches can disrupt business operations and cause financial losses. While we have risk management plans in place, there are inherent limitations. We manage portfolios with clients' risk tolerances in mind, but we cannot guarantee success. Clients should be prepared to bear the risk of loss. ITEM 9. DISCIPLINARY INFORMATION Neither ALM First Financial Advisors, LLC nor its management personnel have been subject to any legal or regulatory disciplinary actions related to investment advisory services. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES & AFFILIATIONS ALM First Financial Advisors, LLC has a related business under common control, ALM First Executive Benefits LLC, that share employees and resources. ALM First Executive Benefits and Michael Ensweiler, a Principal with both entities serving as ALM First Executive Benefits' licensed agent and principal, are licensed insurance producers (ALM Producers) under contract and appointed with various life insurance companies. ALM Producer licenses are maintained in resident Texas (General Lines Agency #3106973 and Agent #3097048, respectively) as well as various non-resident licenses (including California - Agency License #6013070, Agent #4361107) wherever business is conducted. ALM Producers receive compensation for serving customers in connection with the sale of insurance 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 10  and insurance-related products. A material conflict of interest may arise regarding recommendations to our clients (and investors) of either the insurance products of ALM First Executive Benefits, or private fund products managed by ALM First Financial Advisors, LLC. To address this conflict, strict protocols are in place to ensure transparency, disclosure, and adherence to fiduciary duties, thereby safeguarding the interests of our clients. ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING Code of Ethics ALM First Financial Advisors, LLC has adopted a written Code of Ethics that applies to all employees. As fiduciaries, we uphold a duty of undivided loyalty to our clients. Our Code establishes standards of conduct aligned with these fiduciary responsibilities and compliance with all applicable federal securities laws. Employees are prohibited from trading, either personally or on behalf of others (including accounts managed by the firm), on material nonpublic information or from improperly communicating such information. All employees must comply with ALM First Financial Advisors, LLC’s Policy for the Prevention of Insider Trading and adhere to personal trading policy requirements. The Code also addresses policies regarding the acceptance of gifts, favors, entertainment, and other items of material value; the duty of confidentiality as outlined in our Privacy Policy; marketing and communications standards; and guidelines for service on boards or other outside activities. A copy of our Code of Ethics is available to any client or prospective client upon request. Participation or Interest in Client Transactions Employees of ALM First Financial Advisors, LLC are subject to strict trading policies. Personal holdings of reportable securities held by clients are restricted, with exceptions requiring pre-clearance, such as Exchange-Traded Funds (ETFs). Certain securities, such as U.S. Treasury obligations, are exempt from these requirements. Personal Trading The Chief Compliance Officer is responsible for reviewing all employee transactions in reportable securities. Trades executed by the Chief Compliance Officer are reviewed by the Chief Executive Officer. Employees must obtain pre-clearance before trading in any reportable security held by client accounts, as well as before participating in initial public offerings or private placements. These measures help ensure that employee trading activities do not impact markets or create conflicts with fiduciary obligations to clients. 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 11  ITEM 12. BROKERAGE PRACTICES Selecting Brokerage Firms For non-discretionary accounts, ALM First Financial Advisors, LLC does not generally determine the securities to be traded, the broker-dealer to be used, or the transaction pricing without prior client approval. Advisors review portfolio positions, evaluate pricing through multiple broker-dealers, and seek client authorization before executing trades. Broker-dealer selection is based on best obtainable pricing. All broker-dealers must be approved by participating clients before being utilized for transactions. ALM First Financial Advisors, LLC does not receive compensation from broker-dealers, nor does it maintain affiliations with brokerage firms. Clients are free to designate a custodian of their choice, with the exception of Pershing, LLC, which serves as the default custodian for certain discretionary advisory services. Clients utilizing Pershing retain the option to opt out of this arrangement. Best Execution ALM First Financial Advisors, LLC seeks to obtain the most favorable pricing and execution terms available. Trade execution practices include obtaining multiple market comparables, when possible, and documenting best execution standards. In non-discretionary arrangements, trade aggregation is utilized only when it results in demonstrable pricing benefits, with allocations distributed equitably among eligible clients. ALM First Financial Advisors, LLC conducts an annual review of broker-dealers. Clients directing brokerage arrangements must provide written authorization and acknowledge potential limitations, including an inability to negotiate commissions and obtain volume discounts. Employees are prohibited from accepting cash, gifts, entertainment, or other inducements of material value that could impair their objectivity in brokerage selection. Soft Dollars ALM First Financial Advisors, LLC does not engage in soft dollar arrangements. Research reports and other data received from brokerage firms are used to support investment analysis and trading decisions, benefiting all clients. Trade Aggregation and Allocation Trades are generally allocated pro-rata among eligible accounts. However, in the case of scarce assets or limited investment opportunities, ALM First Financial Advisors, LLC follows a rotational allocation methodology, subject to the following guidelines: 1. Limited investment opportunities are available only to discretionary management clients. 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 12  2. Among discretionary clients, those structured as investment companies under the Investment Company Act of 1940 (“’40 Act”) receive priority consideration. 3. Remaining eligible clients are offered allocations on a rotational basis, starting with the largest managed investment portfolio. 4. Clients unable to participate due to suitability, liquidity, or other constraints remain in the rotation for future opportunities. 5. Clients receiving an allocation are not necessarily precluded from subsequent allocations if no other eligible clients are available. 6. The portfolio manager retains discretion to decline an allocation if it is deemed not to be in a client’s best interest. This allocation methodology is designed to ensure fair and equitable access to investment opportunities while maintaining alignment with client objectives. ITEM 13. REVIEW OF ACCOUNTS Periodic Reviews Each client portfolio is assigned a primary Director. The Director oversees daily supervision and client relationship management. Supporting the Director is a team of analysts who assist with daily analytics. Directors conduct continuous reviews of client portfolios to ensure appropriate asset allocation, investment suitability, and alignment with client objectives. In cases of absence due to illness or vacation, other Directors are available to provide account coverage. Review Triggers Portfolio reviews are prompted by factors such as changes in financial markets, interest rates, and credit ratings of approved institutions or obligations. Additionally, reviews occur in response to shifts in a client’s liquidity position, overall financial standing, or change in investment strategy or objectives. Regular Reports Regular reporting may include a detailed inventory of holdings, a performance summary, strategy recommendations, and portfolio analytics, provided at least quarterly. Monthly accounting reports are available upon request and provide portfolio activity details, along with relevant accrual and payment information for accounting and reporting purposes. For private funds managed by ALM First Financial Advisors, LLC, investor reporting is conducted by a retained Fund Administrator, with audited financial statements provided annually. 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 13  ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION Incoming Referrals We maintain agreements with three (3) third parties for client referrals. Compensation structures vary but generally involve the promoter receiving a percentage of advisory fees paid by the referred client. Each referral arrangement is disclosed in compliance with SEC Rule 206(4)-1(b)(1). Referrals Out We do not accept referral fees or any form of remuneration when referring prospects or clients to other professionals. ITEM 15. CUSTODY We do not have custody of client funds or securities, except in cases involving private fund clients. When acting as the manager of a private fund, ALM First Financial Advisors, LLC is considered to have custody due to its control relationship with the fund client. For clients where we have custody, a qualified custodian or Fund Administrator sends account statements directly to clients (or fund investors) at least quarterly. Pershing serves as the prime broker and custodian for private funds. Private fund clients are subject to an annual audit, as well as a liquidation audit when applicable, conducted by an independent public accountant registered with and subject to regular inspection by the PCAOB (Public Company Accounting Oversight Board). We make every effort to distribute audit reports to investors within 120 days of the fund’s fiscal year-end. ITEM 16. INVESTMENT DISCRETION Discretionary Authority for Trading Discretionary authority for certain clients, including private fund clients, insurance-based investment portfolio, and separate accounts are managed in accordance with client-approved sector allocations and targeted effective durations. Before assuming discretionary authority, we assess risk tolerance, review asset-liability management reports where applicable, and set mutually agreed-upon risk controls. Security types and policy limits are reviewed and approved as part of this process. Limited Power of Attorney Clients granting discretionary authority sign a limited power of attorney, allowing us to execute approved trades on their behalf. 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 14  ITEM 17. VOTING CLIENT SECURITIES We generally do not accept authority to vote proxies. However, we may exercise discretion over corporate actions, such as tender offers, in discretionary accounts. In limited cases, we vote proxies for large clients or private fund clients. Our proxy voting policies prioritize clients' financial interests, typically aligning with management recommendations rather than engaging in shareholder activism. Clients may request details on proxy votes or direct voting preferences. Proxy voting policies are available upon request. Most trades involve fixed-income securities, including government agency or government-sponsored entity debt, where proxy voting is not required. Non-discretionary clients are expected to vote their own proxies. ITEM 18. FINANCIAL INFORMATION We have no financial impairment affecting our ability to meet contractual obligations. We do not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. 3800 Maple Avenue Suite 600 | Dallas, TX 75219 | www.almfirst.com | 800.752.4628 15