ASB CONSULTORES, LLC

Brochure ASB Consultores, LLC. 21005 NE 31st Avenue Aventura, FL, 33180 (305) 318 – 7172 March 31, 2025 This brochure provides information about the qualifications and business practices of ASB Consultores, LLC (“ACL”, “Advisor,” “us,” “we,” or “our”). When we use the words “you,” “your,” and “client,” we are referring to you as our client or our prospective client. We use the term “supervised person” when referring to our officers, employees, and all individuals providing investment advice on behalf of ACL. If you have any questions about the contents of this brochure, please contact us at (305) 318-7172 or by email at: alex.silberwasser@asb-consultores.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. ASB is a registered investment advisor. The registration of an advisor does not imply any level of skill or training. The oral and written communications made to you by ASB, including the information contained in this Brochure, should provide you with the information to determine whether to hire or retain ASB as your advisor. is also available on the SEC’s website at information about ASB Consultores, LLC Additional www.adviserinfo.sec.gov. ASB Consultores, LLC’s CRD number is: 189514. i  Item 2: Material Changes Please note that there were no “material changes” made to this Brochure since our last delivery or posting of the Brochure on the SEC’s public disclosure website (‘IAPD’) which is located at www.advisorinfo.sec.gov. However, this Brochure does include a number of minor editorial changes, and updated information on our attests under management. The material changes in this brochure will be updated annually or when material changes occur since the previous release of the firm’s brochure. Material changes relate to ASB Consultores, LLC’s policies, practices or conflicts of interests only. ii  Item 3: Table of Contents Item 1: Cover Page…………………………………………………………………………………………………………………………………………………………………………………………………….i Item 2: Material Changes .........................................................................................................................................................................................................ii Item 3: Table of Contents ...................................................................................................................................................................................................... iiii .................................................................................................................................................................................................................................................. iii Item 4: Advisory Business ...................................................................................................................................................................................................... 2 A. Description of the Advisory Firm ................................................................................................................................................................................ 2 B. Types of Advisory Services ........................................................................................................................................................................................... 2 C. Client Tailored Services and Client Imposed Restrictions ........................................................................................................................................ 3 D. Wrap Fee Programs ....................................................................................................................................................................................................... 3 E. Assets Under Management ........................................................................................................................................................................................... 3 Item 5: Fees and Compensation ............................................................................................................................................................................................. 4 A. Fee Schedule ................................................................................................................................................................................................................... 4 B. Payment of Fees.............................................................................................................................................................................................................. 5 C. Client Responsibility For Third Party Fees ................................................................................................................................................................. 5 D. Prepayment of Fees ....................................................................................................................................................................................................... 6 E. Outside Compensation For the Sale of Securities to Clients ..................................................................................................................................... 6 Item 6: Performance-Based Fees and Side-By-Side Management ...................................................................................................................................... 6 Item 7: Types of Clients ........................................................................................................................................................................................................... 6 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ............................................................................................................................. 6 A. Methods of Analysis and Investment Strategies........................................................................................................................................................ 6 B. Material Risks Involved ................................................................................................................................................................................................. 7 C. Risks of Specific Securities Utilized ............................................................................................................................................................................. 8 Item 9: Disciplinary Information .......................................................................................................................................................................................... 10 A. Criminal or Civil Actions ............................................................................................................................................................................................ 10 B. Administrative Proceedings ....................................................................................................................................................................................... 10 C. Self-regulatory Organization (SRO) Proceedings .................................................................................................................................................... 10 Item 10: Other Financial Industry Activities and Affiliations .......................................................................................................................................... 10 A. Registration as a Broker/Dealer or Broker/Dealer Representative ...................................................................................................................... 11 B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor........................................ 11 C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests .................................................................. 11 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ........................................................ 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................................................................................. 11 A. Code of Ethics .............................................................................................................................................................................................................. 11 B. Recommendations Involving Material Financial Interests ...................................................................................................................................... 12 C. Investing Personal Money in the Same Securities as Clients .................................................................................................................................. 12 D. Trading Securities At/Around the Same Time as Clients’ Securities ................................................................................................................... 12 Item 12: Brokerage Practices ................................................................................................................................................................................................. 12 iii  A. Factors Used to Select Custodians and/or Broker/Dealers ................................................................................................................................... 12 1. Research and Other Soft-Dollar Benefits .............................................................................................................................................................. 12 2. Brokerage for Client Referrals ................................................................................................................................................................................ 13 3. Clients Directing Which Broker/Dealer/Custodian to Use ............................................................................................................................... 13 B. Aggregating (Block) Trading for Multiple Client Accounts ................................................................................................................................... 13 Item 13: Reviews of Accounts ............................................................................................................................................................................................... 13 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews..................................................................................................... 13 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts .................................................................................................................. 14 C. Content and Frequency of Regular Reports Provided to Clients ........................................................................................................................... 14 Item 14: Client Referrals and Other Compensation ........................................................................................................................................................... 14 A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ............................. 14 B. Compensation to Non – Advisory Personnel for Client Referrals ......................................................................................................................... 14 Item 15: Custody .................................................................................................................................................................................................................... 14 Item 16: Investment Discretion............................................................................................................................................................................................. 15 Item 17: Voting Client Securities (Proxy Voting) ............................................................................................................................................................... 15 Item 18: Financial Information ............................................................................................................................................................................................. 15 A. Balance Sheet ................................................................................................................................................................................................................ 15 B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients ...................................................... 15 C. Bankruptcy Petitions in Previous Ten Years ............................................................................................................................................................ 15 iv  Item 4: Advisory Business A. Description of the Advisory Firm ASB Consultores, LLC (hereinafter “ACL”) is a Corporation organized in the State of Florida. The firm was formed in June 2014, and the principal owner is Alex Silberwasser. B. Types of Advisory Services Portfolio Management Services ACL offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. ACL creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: Investment strategy Asset allocation Risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring • • • ACL evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. ACL will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. is to seek fair and equitable allocation of ACL seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of ACL’s economic, investment or other financial interests. To meet its fiduciary obligations, ACL attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and investment accordingly, ACL’s policy opportunities/transactions among its clients to avoid favoring one client over another over time. It is ACL’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. Financial Planning and Consulting Services Financial planning may include, but is not limited to: - Investment planning; life insurance; tax concerns; retirement planning; college planning; and debit/credit planning. 2  - Work with current insurance, tax advice and legal advice providers as appropriate in order to generate coordinated plans Consulting Services may include, but are not limited to: - Supervise current advisor/bank relationships, focusing on: o Cost control o Product due diligence o New advisor/bank due diligence o Periodic evaluations and feedback: level of service, investment performance Investment policy creation and maintenance Industry research (asset managers, endowments, SWF, Portfolio theory, other topics) - Setup and ongoing management of investment committee, as needed - Design of internal investment process - - - Read advisor/bank research and provide written opinion - Analyze various investment projects and provide written opinion, as requested Services Limited to Specific Types of Investments ACL generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, 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, although ACL primarily recommends mutual funds and ETFs to a majority of its clients. ACL may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions ACL offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent ACL from properly servicing the client account, or if the restrictions would require ACL to deviate from its standard suite of services, ACL reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and other administrative fees. ACL does not participate in any wrap fee programs. E. Assets Under Management ACL has the following assets under management: 3  Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 900,591,450 $ 0.00 December 31, 2024 Item 5: Fees and Compensation A. Fee Schedule Asset-Based Fees for Portfolio Management Total Assets Under Management Annual Fee $5,000,000 – And Up 1.00% These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of ACL's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. ACL uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Performance-Based Fees for Portfolio Management Qualified clients will pay an annual fee of 1.00% of assets under management along with a 15.00% performance fee based on capital appreciation. If the client's portfolio rises in value, the client will pay 15.00% on that increase in value, but if the portfolio drops in value, the client will not incur a new performance fee until the portfolio reaches the last highest value, adjusted for withdrawals and deposits, which is generally known as a “high water mark.” Accredited clients will pay an annual fee of 1.00% of assets under management along with a 15.00% performance fee based on capital appreciation. If the client's portfolio rises in value, the client will pay 15.00% on that increase in value, but if the portfolio drops in value, the client will not incur a new performance fee until the portfolio reaches the last highest value, adjusted for withdrawals and deposits, which is generally known as a “high water mark.” The high water mark will be the highest value of the client’s account on the last day of any previous year, after accounting for the client’s deposits or withdrawals for each billing period. 4  These fees are generally negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. This service may be canceled with 30 days’ notice. Clients must pay the prorated performance-based fees for the billing period in which they terminate the Investment Advisory Contract up to and including the day of termination. Financial Planning and Consulting services Fees Clients may terminate the agreement without penalty for a full refund of ACL's fees within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Fixed Fees The negotiated fixed rate (retainer) for financial planning and consulting is between $36,000 and $48,000 per year. Fees are charged quarterly in arrears. B. Payment of Fees Payment of Asset-Based Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis, or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in arrears. Payment of Performance-Based Portfolio Management Fees Performance-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a annual basis, or may be invoiced and billed directly to the client on a annual basis. Clients may select the method in which they are billed. Fees are paid in arrears. Payment of Financial Planning Fees Financial planning fees are paid via wire. Fixed financial planning fees are paid in arrears upon completion. C. Client Responsibility For Third Party Fees 5  Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by ACL. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees ACL collects its fees in arrears. It does not collect fees in advance. E. Outside Compensation For the Sale of Securities to Clients Neither ACL nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management ACL manages accounts that are billed on performance-based fees (a share of capital gains on or capital appreciation of the assets of a client) and may as well manage accounts that are not billed on performance- based fees. Managing both kinds of accounts at the same time presents a conflict of interest because ACL and/or its supervised persons have an incentive to favor accounts for which ACL receives a performance- based fee. ACL addresses the conflicts by ensuring that clients are not systematically advantaged or disadvantaged due to the presence or absence of performance-based fees. ACL seeks best execution and upholds its fiduciary duty for all clients. Clients paying a performance-based fee should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes. Item 7: Types of Clients ACL generally provides advisory services to High-Net-Worth Individuals. Minimum Account Size for Portfolio Management ACL does not have an account minimum. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis and Investment Strategies 6  Methods of Analysis ACL’s methods of analysis include fundamental analysis and modern portfolio theory. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Investment Strategies ACL uses long term trading, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. 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 will be 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. Investment Strategies ACL's use of margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically 7  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. 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. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized ACL's use of margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. 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 conditions and the general economic environments. 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, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. 8  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. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real Estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Hedge Funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will 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. Private placements carry a substantial risk 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, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. 9  Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations 10  A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither ACL nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither ACL nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Alex Silberwasser is a financial consultant. He helps manage client assets, both financial and nonfinancial and is a member and secretary of an investment committee, with (optional) authorization to instruct trades on behalf of the client's legal structure. This could include conducting macro, asset allocation analysis and due diligence on specific investment vehicles, as well as managing risk procedures, compliance and possible legal responsibilities. The research is primarily conducted on ideas and products presented by Private Banks, Brokerages, Advisers and other third parties. Alex Silberwasser spends 1 hour a month on these activities during business hours and 3 hours a month during outside trading hours. 25 percent of yearly compensation is derived from these activities. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ACL does not utilize nor select third-party investment advisers. All assets are managed by ACL management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics ACL has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, 11  Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. ACL's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests ACL does not recommend that clients buy or sell any security in which a related person to ACL or ACL has a material financial interest. C. Investing Personal Money in the Same Securities as Clients As part of its Code of Ethics, ACL has implemented a restricted list to ensure that neither the adviser nor its representatives will trade in securities that ACL also recommends to clients. D. Trading Securities At/Around the Same Time as Clients’ Securities Please see Item 11.C above. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on ACL’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and ACL may also consider the market expertise and research access provided by the broker-dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in ACL's research efforts. ACL will never charge a premium or commission on transactions, beyond the actual cost imposed by the brokerdealer/custodian. ACL recommends Pershing Advisor Solutions LLC, Schwab Institutional, a division of Charles Schwab & Co., Inc., Morgan Stanley, USB Financial Services Inc. and Citi Private Bank. 1. Research and Other Soft-Dollar Benefits While ACL has no formal soft dollars program in which soft dollars are used to pay for third party services, ACL may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). ACL may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor 12  contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and ACL does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. ACL benefits by not having to produce or pay for the research, products or services, and ACL will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that ACL’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals ACL receives no referrals from a broker-dealer or third party in exchange for using that brokerdealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use ACL may permit clients to direct it to execute transactions through a specified broker-dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to ACL to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts ACL does not aggregate or bunch the securities to be purchased or sold for multiple clients. This may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Reviews of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for ACL's advisory services provided on an ongoing basis are reviewed at least quarterly by Alex Silberwasser, Consultant with regard to clients’ respective investment policies and risk tolerance levels. All accounts at ACL are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Alex Silberwasser, Consultant. There is only one level of review for financial planning, and that is the total review conducted to create the financial plan. 13  B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, ACL’s services will generally conclude upon delivery of the financial plan. C. Content and Frequency of Regular Reports Provided to Clients Each client of ACL's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) ACL does not receive any economic benefit, directly or indirectly from any third party for advice rendered to ACL's clients. B. Compensation to Non – Advisory Personnel for Client Referrals ACL may enter into written arrangements with third parties to act as solicitors for ACL's investment management services. Solicitor relationships will be fully disclosed to each Client to the extent required by applicable law. ACL will ensure each solicitor is exempt, notice filed, or properly registered in all appropriate jurisdictions. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, ACL will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. 14  Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Item 16: Investment Discretion ACL provides discretionary and non-discretionary investment advisory services to clients. The Investment Advisory Contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, ACL 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. Item 17: Voting Client Securities (Proxy Voting) ACL will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet ACL neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither ACL nor its management has any financial condition that is likely to reasonably impair ACL’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years ACL has not been the subject of a bankruptcy petition in the last ten years. 15