ASSET ADVISORS INVESTMENT MANAGEMENT, LLC

Item 1 – Cover Page Form ADV Part 2A Investment Advisor Brochure Asset Advisors Investment Management, LLC Name of Registered Investment Advisor Address Phone Number Website Address E-mail Address Date 2814-A Hillcreek Dr Augusta, GA 30909 706-650-9900 www.assetadvisors.com nkuehl@assetadvisors.com March 27, 2025 This Form ADV Part 2A (Investment Advisor Brochure) gives information about the qualifications and business practices of Asset Advisors Investment Management, LLC (“Asset Advisors” or the “Firm”) and its business for the use of clients and prospective clients. Registration is mandatory for all non-exempt persons meeting the definition of investment adviser and does not imply a certain level of skill or training. 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. If you have any questions about the contents of this Brochure, please contact us. Additional information about our firm is available on the SEC’s website at: www.adviserinfo.sec.gov 1  Item 2 - Material Changes Pursuant to SEC rules, we are required to update this Brochure at least annually and provide you with a summary of material changes since the previous annual amendment. Since we filed our annual update to this Brochure in March 2024, we have made the following material changes: On 09/01/2024 Nichole Kuehl was named the Chief Compliance Officer. Item 4 has been revised to reflect this change. We offer clients the option of obtaining certain financial solutions from unaffiliated third- party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). UPTIQ is compensated by sharing in the revenue earned by such third-party institutions for serving our clients. When legally permissible, UPTIQ shares a portion of this earned revenue with an affiliate of our firm. Further information on this conflict of interest is available in Items 4, 5, and 10 of this Brochure. We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”). If FRS places an insurance product for our client or refers our client to an insurance broker and there is a subsequent purchase of insurance through the broker, then FRS will receive a portion of the upfront and/or ongoing commissions associated with the sale by the insurance carrier with which the policy was placed. Additionally, certain of these brokers pay FRS periodic fees to participate in the FRS platform and, thereby, to offer their services to our clients and certain of our affiliates’ clients. Further information on this conflict of interest is available in Items 4, 5 and 10 of this Brochure. Disclosure on Trade Errors has been added to Item 12. 2  Item 3 - Table of Contents Material Changes ...........................................................................................................................2 Table of Contents ...........................................................................................................................3 Advisory Business ..........................................................................................................................4 Fees and Compensation .................................................................................................................6 Performance-Based Fees And Side-By-Side Management ........................................................8 Types of Clients ..............................................................................................................................8 Methods of Analysis, Investment Strategies, and Risk of Loss..................................................8 Disciplinary Information .............................................................................................................11 Other Financial Industry Activities and Affiliations ................................................................11 Code of Ethics, Participation or Interest In Client Transactions, and Personal Trading…15 Brokerage Practices .....................................................................................................................15 Review of Accounts ......................................................................................................................18 Client Referrals & Other Compensation ...................................................................................18 Custody .........................................................................................................................................20 Investment Discretion ..................................................................................................................20 Voting Client Securities ...............................................................................................................20 Financial Information ..................................................................................................................20 3  Item 4.A – Description of Advisory Business Focus Financial Partners Asset Advisors Investment Management, LLC (“Asset Advisors”) is part of the Focus Financial Partners, LLC (“Focus LLC”) partnership. Specifically, Asset Advisors is a wholly-owned indirect subsidiary of Focus LLC. Focus Financial Partners, Inc. is the sole managing member of Focus LLC. Ultimate governance of Focus LLC is conducted through the board of directors at Ferdinand FFP Ultimate Holdings, LP. Focus LLC is majority-owned, indirectly and collectively, by investment vehicles affiliated with Clayton, Dubilier & Rice, LLC (“CD&R”). Investment vehicles affiliated with Stone Point Capital LLC (“Stone Point”) are indirect owners of Focus LLC. Because Asset Advisors is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Asset Advisors. Focus LLC also owns other registered investment advisers, broker-dealers, pension consultants, insurance firms, business managers and other firms (the “Focus Partners”), most of which provide wealth management, benefit consulting and investment consulting services to individuals, families, employers, and institutions. Some Focus Partners also manage or advise limited partnerships, private funds, or investment companies as disclosed on their respective Form ADVs. Asset Advisors offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Please see Items 5 and 10 for a fuller discussion of these services and other important information. We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. Please see Items 5 and 10 for a fuller discussion of these services and other important information. Asset Advisors Investment Management, LLC is managed by Will Rice, Ben Braxton, Hamp Manning, Will Evans, and Rusty Woodward (“Asset Advisors Principals”), pursuant to a management agreement between AAC Capital, LLC and Asset Advisors. The Asset Advisors Principals serve as leaders and officers of Asset Advisors and are responsible for the management, supervision, and oversight of Asset Advisors. George Rush serves as President of Asset Advisors. Nichole Kuehl serves as the Chief Compliance Officer (“CCO”) of Asset Advisors. AAC Capital, LLC is wholly owned by its Principals. Item 4.B - Types of Advisory Services Asset Advisors provides personalized wealth management and discretionary investment management services to high-net-worth individuals and other individuals, charitable 4  organizations, pension and profit-sharing plans, and corporations. As needed, Asset Advisors provides clients with financial planning services. Investment Management Services In designing and implementing customized models and portfolio strategies, Asset Advisors manages, on a discretionary basis, a range of investment strategies designed to align with the client’s investment objectives. Asset Advisors primarily allocates client assets among exchange- traded funds (“ETFs”), equity securities of individual companies, municipal bonds, corporate bonds, government bonds and certificates of deposit (“CDs”). We render advisory services based on the individual needs of our clients. Clients may impose reasonable restrictions on the management of their portfolio subject to Asset Advisors acceptance of those restrictions. Asset Advisors is a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”) with respect to investment management services and investment advice provided to ERISA plans and ERISA plan participants. Asset Advisors is also a fiduciary under section 4975 of the Internal Revenue Code of 1986, as amended (the “IRC”) with respect to investment management services and investment advice provided to individual retirement accounts (“IRAs”), ERISA plans, and ERISA plan participants. As such, Asset Advisors is subject to specific duties and obligations under ERISA and the IRC, as applicable, that include, among other things, prohibited transaction rules which are intended to prohibit fiduciaries from acting on conflicts of interest. When a fiduciary gives advice, the fiduciary must either avoid certain conflicts of interest or rely upon an applicable prohibited transaction exemption (a “PTE”). Asset Advisors acts as your investment adviser responsible for the investment and reinvestment of those assets that you designate to be subject to our management in accordance with your investment needs, goals and objectives. You hereby appoint us as your attorney-in-fact and grant us limited power-of-attorney with discretionary trading authority over your account. Advice rendered on a client’s ERISA plan not managed by us is given as non-discretionary advice, meaning the client retains and exercises the final decision-making authority for implementing or rejecting Asset Advisors’ recommendations. As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any non-waivable rights you possess. Item 4.E - Client Assets As of December 31, 2024, Asset Advisors had $1,300,476,408 in discretionary assets under management. 5  Item 5 - Fees and Compensation Our investment advisory and financial planning fees are set forth in a written agreement with our clients. Our investment advisory fee is 1% of a client’s assets under management. A few clients pay fixed fees rather than fees that are a percentage of the client’s assets under management. Our minimum annual fee is $3,000. Fees are potentially negotiable. Fees are waived for a few founding principals’ family accounts. For clients with no assets under management, financial planning services are provided for a fixed fee that is subject to negotiation, takes into account the complexity and scope of services to be provided, and is memorialized in the client agreement. Financial planning fees will be billed annually or quarterly, based on the client’s agreement, in arrears, through direct invoice. If the advisory fee is based on a percentage of the value of assets under management, the advisory fee is payable quarterly in arrears, based on the period ending net asset value of the client’s account on the last day of the previous quarter. Cash, cash equivalents, and accrued interest are included in the market value on which our fee is assessed. For the initial quarter, the advisory fee is payable on a pro rata basis, in arrears, based on the period ending net assets under management at the end of such initial quarter. The advisory fee charged by the Firm will apply to all the client’s assets under management, unless specifically excluded in the client agreement. For both the initial and subsequent quarters, we make an adjustment for contributions and withdrawals made during the quarter of $10,000 or larger. Clients have five (5) business days from the date of execution of the client agreement to terminate the services without any fee. The investment advisory or financial planning agreement terminates at will by either Asset Advisors or the client upon written notice. Asset Advisors does not impose termination fees when the investment advisory relationship ends. Any management fee earned through the time of termination will be payable upon invoice. Our fees are for investment management or financial planning only and do not include any transaction fees, brokerage commissions or other costs associated with the purchase and sale of securities, custodian fees, wire-transfer fees, interest, taxes, or other account expenses. All fees paid to Asset Advisors for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or in conjunction with internal expenses associated with ETFs. Asset Advisors does not receive any portion of these fees. See section on Brokerage Practices for additional information. Most Clients with assets under management authorize the custodian holding their securities to deduct our management fee directly from their account upon our instruction. The custodian will not determine whether the fee is properly calculated. Clients are sent invoices at the same time we request payment from the custodian. The custodian provides monthly or quarterly account statements to the clients, which reflect all fee payments to Asset Advisors. A limited number of clients pay our fee directly by check. Clients are urged to review the information in their custodial statement and compare it to any reports received from Asset Advisors. 6  We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). Focus Financial Partners, LLC (“Focus”) is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients. The revenue paid to UPTIQ also benefits UPTIQ, Inc.’s investors, including Focus, our parent company. When legally permissible, UPTIQ also shares a portion of this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives from such third-party financial institutions. For other loans (except residential mortgage loans) made to our clients, UPTIQ will share with FSH up to 25% of all revenue it receives from such third-party financial institutions. For cash management products and services provided to our clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial institutions and other intermediaries that provide administrative and settlement services in connection with this program. Although the amount of these revenue-sharing payments to FSH is not charged directly in the calculation of the interest rate paid by clients on credit solutions facilitated by UPTIQ or the yield earned by clients on cash management solutions facilitated by UPTIQ, the compensation earned by UPTIQ is an expense of the third-party financial institutions that informs the interest rate paid by clients on credit solutions and the yield earned by clients on cash management solutions. Further information on this conflict of interest is available in Item 10 of this Brochure. We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC. FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters and placing insurance products for them and/or referring our clients to certain third-party insurance brokers (the “Brokers”), with whom FRS has agreements, which either separately or together with FRS place insurance products for them. If FRS places an insurance product or refers one of our clients to a Broker and there is a subsequent purchase of insurance through the Broker, then FRS will receive a portion of the upfront and/or ongoing commissions associated with the sale by the insurance carrier with which the policy was placed. The amount of revenue earned by FRS for the sale of these insurance products will vary over time in response to market conditions and will also differ based on the type of insurance product sold and which Broker placed the policy. Additionally, in exchange for allowing certain of the Brokers to participate in the FRS platform and, thereby, to offer their services to our clients and certain of our affiliates’ clients, FRS receives periodic fees (the “Platform Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share in such revenue. FRS also indirectly benefits from our clients’ use of the services insofar as such use incentivizes the Brokers to maintain their relationship with FRS and to continue paying Platform Fees to FRS, which could also support increases in the overall amount of the Platform Fee rates in the future. Further information on this conflict of interest is available in Item 10 of this Brochure. Asset Advisors does not have any arrangements, oral or in writing, where it is paid in cash by or receives some economic benefit (including commissions, equipment, or non-research services) 7  from a non-client in connection with giving advice to clients. Asset Advisors is not directly or indirectly compensated by any person for client referrals. Item 6 - Performance-Based Fees and Side-By-Side Management Some money managers charge performance-based fees. Performance-based fees are charged on a percentage of the profits in a client account. Asset Advisors does not charge performance- based fees; we prefer our simplified percentage of assets under management fee. Therefore, we do not face a conflict of interest from managing accounts that pay an asset-based fee alongside accounts that pay performance-based fees. Item 7 - Types of Clients Asset Advisors provides advisory services to high-net-worth individuals and other individuals, charitable organizations, pension and profit-sharing plans, and corporations. Generally, our relationships involve managing $1 million or more for a client or their family. We are not short-term oriented in performance return or client relationships. We invest with a long-term orientation. We are blessed with clients that share the objective of preserving wealth and growing assets over the long-term. We strive to always merit client trust in caring for their investment assets. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss Asset Advisors primarily allocates client assets among ETFs, equity securities of individual companies, municipal bonds, corporate bonds, government bonds and certificates of deposit (“CDs”). We look for investments which have the potential for a multiyear holding period. Asset Advisors is a personalized firm with a limited number of clients. We strive to carefully manage accounts in a manner consistent with each client’s investment objectives and risk tolerance. Our investment committee meets on a regular basis to review our investment ideas. Our selection of stocks and bonds relies heavily on the investment experience of our professionals. We utilize fundamental and technical analysis. More importantly, extensive reading and careful study of various financial and economic news sources generates many of our investment ideas. Investing in securities involves a risk of loss, including the risk of losing all or a substantial portion of the client’s investment, that clients should be prepared to bear. 8  Material Risks Involved Investing in equity securities generally involves becoming an owner in the issuer company and participating fully in its economic risks. The value of equity securities generally varies with the performance of that company and movements in the equity markets. As a result, clients may suffer losses if they own companies whose performance diverges from the Firm’s expectations or if equity markets generally move in a single direction. An issuer of bonds has agreed to return the face value of the security to the holder at maturity. Most bonds pay investors a fixed rate of interest income. While bonds are generally considered more conservative than equity investments, they carry risks that include the risk that the issuer will default on payment of principal, fluctuation in interest rates, inflation, and counterparties’ inability to meet contractual obligations. An ETF’s risks include declining value of the securities held by the ETF, adverse developments in the industry or sector that the ETF tracks, capital loss in geographically focused funds because of unfavorable fluctuation in currency exchange rates, differences in generally accepted accounting principles, or economic or political instability, tracking error, which is the difference between the return of the ETF and the return of its benchmark and trading at a premium or discount, meaning the difference between the ETF’s market price and NAV. While ETFs may provide diversification, risks can be significantly increased for funds concentrated in a particular sector of the market, or that primarily invest in small cap or speculative companies, use leverage (i.e., borrow money), or concentrate in a particular type of security rather than balancing the fund with different types of securities. ETFs can be bought and sold throughout the day and their price can fluctuate throughout the day. During times of extreme market volatility, ETF pricing may lag versus the actual underlying asset values and there is no guarantee this relationship will resolve itself. ETFs also are subject to the individual risks described in their prospectus. Although the goal of diversification is to combine investments with different characteristics so that the risks inherent in any one investment can be balanced by assets that move in different cycles or respond to different market factors, diversification is not always successful in reducing correlation among asset classes and does not eliminate the risk of loss. In some circumstances, price movements may be highly correlated across securities and funds. A specific fund may not be diversified, and a client portfolio may not be diversified. Additionally, when diversification is a client objective, there is risk that the strategies that the Firm uses may not be successful in achieving the desired level of diversification. There is also risk that the strategies, resources, and analytical methods that the Firm uses will not be successful in identifying investment opportunities. The following events also could cause ETFs, equities and fixed income securities and other investments managed for clients to decrease in value: • Market Risk: The price of an equity security, bond, or ETF may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, changes in political, economic, and social conditions may trigger adverse market events. 9  • Interest Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive compared to newly issued bonds, causing the market values of existing bonds to decline. • Event Risk: An adverse event affecting a particular company or that company’s industry could depress the price of a client’s investments in that company’s stocks or bonds. The company, government or other entity that issued bonds in a client’s portfolio could become less able to, or fail to, repay, service or refinance its debts, or the issuer’s credit rating could be downgraded by a rating agency. Adverse events affecting a particular country, including political and economic instability, could depress the value of investments in issuers headquartered or doing business in that country. • Liquidity Risk: Securities that are normally liquid may become difficult or impossible to sell at an acceptable price during periods of economic instability or other emergency conditions. Some securities may be infrequently or thinly traded even under normal market conditions. • Inflation Risk: Countries around the globe may be more, or less, prone to inflation than the U.S. economy at any given time. Companies operating in countries with higher inflation rates may find it more difficult to post profits reflecting its underlying health. • Reinvestment Risk: Future proceeds from investments may have to be reinvested at a lower rate of return when such proceeds become available for investment. This primarily relates to fixed income securities, especially in a period of declining interest rates. • Operational Risk: ETF service providers may experience disruptions or operating errors such as processing errors or human errors, inadequate or failed internal or external processes, or systems or technology failures, that could negatively impact the ETF. • Regulatory/Legislative Developments Risk: Regulators and/or legislators may promulgate rules or pass legislation that places restrictions on, adds procedural hurdles to, affects the liquidity of, and/or alters the risks associated with certain investment transactions or the securities underlying such investment transactions. Such rules/legislation could affect the value associated with such investment transactions or underlying securities. Cybersecurity Risk The computer systems, networks and devices used by Asset Advisors and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. 10  Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future. Item 9 - Disciplinary Information An investment advisor must disclose material facts about any legal or disciplinary event that is material to your evaluation of our advisory business or of the integrity of our personnel. Asset Advisors and our employees have not been the subject of any legal or disciplinary events. We are required to notify you promptly in the event any material disciplinary event occurs. Item 10 - Other Financial Industry Activities and Affiliations Asset Advisors and its employees do not have any relationships or arrangements with other financial services companies that pose material conflicts of interest. Principals of Asset Advisors are not actively engaged in another business. Asset Advisors is not registered, nor are any employees licensed, as securities salespersons (“Registered Representatives”) or insurance agents. We are not in the business of selling securities and insurance products. Our business is managing portfolios for a select number of clients. Asset Advisors recommends to certain 401(k) clients or prospects the record keeping and third-party administrative services of Sentinel Benefits Group, LLC (“Sentinel”), which is an affiliate, as it is also owned by Focus Operating, LLC. However, 401(k) advisory clients receive a proposal directly from, and contract separately with, Sentinel on an arm’s-length basis for those services if they so choose. No compensation or financial incentives of any kind are exchanged between Asset Advisors and Sentinel with regard to mutual clients. As noted above in response to Item 4, certain funds affiliated with CD&R collectively are indirect majority owners of Focus LLC, and certain investment vehicles affiliated with Stone Point are indirect owners of Focus LLC. Because Asset Advisors Investment Management is an indirect, wholly-owned subsidiary of Focus LLC, CD&R and Stone Point investment vehicles are indirect owners of Asset Advisors. 11  UPTIQ Credit and Cash Management Solutions We offer clients the option of obtaining certain financial solutions from unaffiliated third-party financial institutions through UPTIQ Treasury & Credit Solutions, LLC (together with UPTIQ, Inc. and its affiliates, “UPTIQ”). These third-party financial institutions are banks and non- banks that offer credit and cash management solutions to our clients, as well as certain other unaffiliated third parties that provide administrative and settlement services to facilitate UPTIQ’s cash management solutions. UPTIQ acts as an intermediary to facilitate our clients’ access to these credit and cash management solutions. We are a wholly owned subsidiary of Focus Financial Partners, LLC (“Focus”). Focus is a minority investor in UPTIQ, Inc. UPTIQ is compensated by sharing in the revenue earned by such third-party financial institutions for serving our clients. The revenue paid to UPTIQ also benefits UPTIQ, Inc.’s investors, including Focus. When legally permissible, UPTIQ also shares a portion of this earned revenue with our affiliate, Focus Solutions Holdings, LLC (“FSH”). For securities-backed lines of credit (“SBLOCs”) made to our clients, UPTIQ will share with FSH up to 75% of all revenue it receives from such third-party financial institutions. For other loans (except residential mortgage loans) made to our clients, UPTIQ will share with FSH up to 25% of all revenue it receives from such third-party financial institutions. For cash management products and services provided to our clients, UPTIQ will share with FSH up to 33% of all revenue it receives from the third-party financial institutions and other intermediaries that provide administrative and settlement services in connection with this program. Although the amount of these revenue-sharing payments to FSH is not charged directly in the calculation of the interest rate paid by clients on credit solutions facilitated by UPTIQ or the yield earned by clients on cash management solutions facilitated by UPTIQ, the compensation earned by UPTIQ is an expense of the third-party financial institutions that informs the interest rate paid by clients on credit solutions and the yield earned by clients on cash management solutions. This revenue is also revenue for FSH’s and our common parent company, Focus. Additionally, the volume generated by our clients’ transactions allows Focus to negotiate better terms with UPTIQ, which benefits Focus and us. Accordingly, we have a conflict of interest when recommending UPTIQ’s services to clients because of the compensation to our affiliates, FSH and Focus, and the transaction volume to UPTIQ. We mitigate this conflict by: (1) fully and fairly disclosing the material facts concerning the above arrangements to our clients, including in this Brochure; and (2) offering UPTIQ’s solutions to clients on a strictly nondiscretionary and fully disclosed basis, and not as part of any discretionary investment services. Additionally, we note that clients who use UPTIQ’s services will receive product-specific disclosures from the third-party financial institutions and other unaffiliated third-party intermediaries that provide services to our clients. We have an additional conflict of interest when we recommend credit solutions to our clients because our interest in continuing to receive investment advisory fees from client accounts gives us a financial incentive to recommend that clients borrow money rather than liquidate some or all of the assets we manage. Credit Solutions Clients retain the right to pledge assets in accounts generally, subject to any restrictions imposed by clients’ custodians. While credit solution programs that we offer facilitate secured loans 12  through third-party financial institutions, clients are free instead to work directly with institutions outside such programs. Because of the limited number of participating third-party financial institutions, clients may be limited in their ability to obtain as favorable loan terms as if the client were to work directly with other banks to negotiate loan terms or obtain other financial arrangements. Clients should also understand that pledging assets in an account to secure a loan involves additional risk and restrictions. A third-party financial institution has the authority to liquidate all or part of the pledged securities at any time, without prior notice to clients and without their consent, to maintain required collateral levels. The third-party financial institution also has the right to call client loans and require repayment within a short period of time; if the client cannot repay the loan within the specified time period, the third-party financial institution will have the right to force the sale of pledged assets to repay those loans. Selling assets to maintain collateral levels or calling loans may result in asset sales and realized losses in a declining market, leading to the permanent loss of capital. These sales also may have adverse tax consequences. Interest payments and any other loan-related fees are borne by clients and are in addition to the advisory fees that clients pay us for managing assets, including assets that are pledged as collateral. The returns on pledged assets may be less than the account fees and interest paid by the account. Clients should consider carefully and skeptically any recommendation to pursue a more aggressive investment strategy in order to support the cost of borrowing, particularly the risks and costs of any such strategy. More generally, before borrowing funds, a client should carefully review the loan agreement, loan application, and other forms and determine that the loan is consistent with the client’s long-term financial goals and presents risks consistent with the client’s financial circumstances and risk tolerance. We use UPTIQ to facilitate credit solutions for our clients. Cash Management Solutions For cash management programs, certain third-party intermediaries provide administrative and settlement services to our clients. Engaging the third-party financial institutions and other intermediaries to provide cash management solutions does not alter the manner in which we treat cash for billing purposes. Clients should understand that in rare circumstances, depending on interest rates and other economic and market factors, the yields on cash management solutions could be lower than the aggregate fees and expenses charged by the third-party financial institutions, the intermediaries referenced above, and us. Consequently, in these rare circumstances, a client could experience a negative overall investment return with respect to those cash investments. Nonetheless, it might still be reasonable for a client to participate in a cash management program if the client prefers to hold cash at the third-party financial institutions rather than at other financial institutions (e.g., to take advantage of FDIC insurance). We use UPTIQ to facilitate cash management solutions for our clients. 13  Focus Risk Solutions We help our clients obtain certain insurance solutions by introducing clients to our affiliate, Focus Risk Solutions, LLC (“FRS”), a wholly owned subsidiary of our parent company, Focus Financial Partners, LLC (“Focus”). FRS assists our clients with regulated insurance sales activity by advising our clients on insurance matters and placing insurance products for them and/or referring our clients to certain third-party insurance brokers (the “Brokers”), with whom FRS has agreements, which either separately or together with FRS place insurance products for them. If FRS places an insurance product or refers one of our clients to a Broker and there is a subsequent purchase of insurance through the Broker, then FRS will receive a portion of the upfront and/or ongoing commissions associated with the sale by the insurance carrier with which the policy was placed. The amount of revenue earned by FRS for the sale of these insurance products will vary over time in response to market conditions and will also differ based on the type of insurance product sold and which Broker placed the policy. This revenue is also revenue for our and FRS’s common parent company, Focus. Additionally, in exchange for allowing certain of the Brokers to participate in the FRS platform and, thereby, to offer their services to our clients and certain of our affiliates’ clients, FRS receives periodic fees (the “Platform Fees”) from such Brokers. The Platform Fees are expected to change over time. Such Platform Fees are revenue for FRS and, ultimately, for our common parent company, Focus, but we do not share in such revenue. FRS also indirectly benefits from our clients’ use of the services insofar as such use incentivizes the Brokers to maintain their relationship with FRS and to continue paying Platform Fees to FRS, which could also support increases in the overall amount of the Platform Fee rates in the future. Accordingly, we have a conflict of interest when recommending FRS’s services to clients because of the compensation to our affiliates, FRS and Focus. We address this conflict by: (1) fully and fairly disclosing the material facts concerning the above arrangements to our clients, including in this Brochure; (2) offering FRS solutions to clients on a strictly nondiscretionary and fully disclosed basis, and not as part of any discretionary investment services; and (3) not sharing in any portion of the Platform Fees. Additionally, we note that clients who use FRS’s services will receive product-specific disclosure from the Brokers and insurance carriers and other unaffiliated third-party intermediaries that provide services to our clients. The insurance premium is ultimately dictated by the insurance carrier, although in some circumstances the Brokers or FRS may have the ability to influence an insurance carrier to lower the premium of the policy. The final rate may be higher or lower than the prevailing market rate, and may be higher than if the policy was purchased directly through the Broker without the assistance of FRS. We can offer no assurances that the rates offered to you by the insurance carrier are the lowest possible rates available in the marketplace. 14  Item 11 - Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading Asset Advisors has adopted a Code of Ethics (the “Code”) in accordance with SEC Rule 204A-1 which requires the Firm’s employees (“supervised persons”) to comply with their legal obligations and fulfill the fiduciary duties owed to the Firm’s clients. Among other things, the Code of Ethics sets forth policies and procedures related to conflicts of interest and procedures governing personal securities trading by supervised persons. Personal securities transactions of supervised persons present potential conflicts of interest with the price obtained in client securities transactions or the investment opportunity available to clients. The Code addresses these potential conflicts by prohibiting securities trades that would breach a fiduciary duty to a client and requiring, with certain exceptions, supervised persons to report their personal securities holdings and transactions to the Firm for review. The Code also requires supervised persons to obtain pre-approval of certain investments, including initial public offerings and limited offerings. Asset Advisors will provide a copy of the Firm’s Code of Ethics to any client or prospective client upon request. Item 12 - Brokerage Practices Selection or recommendation of broker/dealers We custody client accounts at firms considered to be reputable and fiscally sound. Our employees are not registered representatives of any outside firm and do not receive any commissions or fees from broker dealers. When a new client does not have a strong preference where their account is held, we typically recommend that clients establish brokerage accounts with Schwab Advisor Services, a division of Charles Schwab & Co., Inc. (“Schwab”). We may, in the future, establish relationships with other institutional custodians. Clients always have the final say on the Custodian selected. In deciding to recommend Schwab, some of the factors that Asset Advisors considers include: • Trade order execution and the ability to provide accurate and timely execution of trades; • The reasonableness and competitiveness of commissions and other transaction costs; • Access to a broad range of investment products; • Access to trading desks; • Technology that integrates within Asset Advisors’ environment, including interfacing with Asset Advisors’ portfolio management system; • A dedicated service or back-office team and its ability to process requests from Asset Advisors on behalf of its clients; • Ability to provide Asset Advisors with access to client account information through an institutional website; and 15  • Ability to provide clients with electronic access to account information and investment and research tools. Schwab provides Asset Advisors with access to their institutional trading and custody services which are typically not available to retail investors. Schwab does not charge separately for custody services. Schwab makes available products and services that may benefit our firm but may not directly benefit client accounts or may be used to service all or some of our clients including clients with accounts maintained at other custodians and/or brokers. These products and services include technologies that: • provide access to client data and account information, documents and forms, and trade confirmations and account statements; facilitate trade execution and allocate aggregated trade orders for multiple accounts; • provide research, pricing, and other market data; and • facilitate investment management fee payment concurrent with Asset Advisors providing our client an invoice. Schwab may offer or provide through third party vendors: compliance, legal, and business consulting; publications, conferences, and educational events, and business entertainment of Asset Advisors personnel. Schwab may incur the cost or may discount or waive the fees it would otherwise charge for these services. These benefits are based on the total client assets custodied at Schwab and do not depend on the number of trades executed on behalf of clients. In evaluating whether to recommend Schwab to hold client assets, Asset Advisors may consider the availability of some of the foregoing products and services as part of the total mix of factors we consider and not solely the nature, cost or quality of custody and brokerage services. These factors may create a potential conflict of interest when recommending Schwab. Disclosure of the above factors makes them less likely to create a conflict for our clients. Trades are usually executed with the broker that also serves as the custodian for the client account. Asset Advisors sometimes “trades away” from the custodian to access better inventory or more favorable prices. In such instances, the account will incur a trade-away fee from a BD/Custodian for each transaction that is executed on a trade-away basis. The fee is separate from the commission/transaction fee or mark-up/mark-down imposed by the broker-dealer through which the trade was executed. Trading away may be advantageous for the client because: • • • • the broker-dealer may have expertise in a particular security or market. the broker-dealer makes a market in a particular security. a particular security is thinly traded; or the broker-dealer can identify a counterparty for a trade. 16  Soft Dollar Practices Some investment managers receive compensation from a brokerage firm in the form of research, products or services (“soft dollars”). When a firm uses client brokerage commissions to obtain soft dollars, the firm receives a benefit by not having to pay for such items. A firm may have an incentive to select or recommend a broker/dealer based on soft dollars received, rather than best execution for the client. Asset Advisors does not receive any soft dollar compensation from any firms. Asset Advisors may receive unsolicited proprietary research from brokers regarding general market commentary, industry-specific analysis, economic data or other information that may be useful in making investment decisions. This research is not provided to Asset Advisors as a result of any commissions or transaction volume directed to any particular broker. Trade Errors Asset Advisors has implemented policies and procedures to ensure that the utmost care is taken in making and implementing investment decisions of behalf of client accounts. To the extent that any errors occur, they are to be (a) corrected as soon as practicable and in such a manner that the client incurs no loss, (b) reported to the CCO, and (c) scrutinized carefully with a view toward implementing procedures to prevent or reduce future errors, if necessary. In the event of a trade error loss on Schwab: • If the gain or loss is less than $100, Schwab absorbs the gain or loss; • If the loss is greater than $100, Asset Advisors reimburses Schwab and will book the charge against its operating expenses; If the gain is greater than $100, Schwab donates the gain to charity. • Client Referrals from Brokers Clients have the final say on where to custody their account. In maintaining an existing broker/dealer relationship, a conflict of interest may exist in obtaining best execution on behalf of the client as their account may not receive the lowest commission obtainable from other brokers. We might not receive future referrals from a broker/dealer if we did not maintain these existing relationships. Directed Brokerage In rare cases, a client may direct brokerage to a specified broker/dealer other than a firm used routinely by us. It is up to that client to negotiate the commission rate as Asset Advisors will not. That client may not be able to negotiate the most competitive rate. As a result, that client may pay more than the rate available through a broker/dealer chosen by us. In addition, the trades of clients who have a directed brokerage arrangement will not be aggregated with the trades of other clients and likely will be placed after the trades placed for other clients. Asset Advisors cannot make any assurances that best execution will be achieved for a client-directed transaction. Trade Aggregation While individual portfolio management is provided each account, certain client trades are executed together as a block trade to obtain volume discounts on execution costs. No account 17  within the block trade will be favored over any other account, and thus, each account will participate in an aggregated order at the average share price. The aggregation may slightly reduce the costs of execution. We will not aggregate a client's order if in a particular instance we believe that aggregation would cause the client's cost of execution to be increased. Cross Trades From time to time, when we deem it advantageous for both the selling and the purchasing client, we direct a broker to cross trades of fixed income securities between client accounts. Recommending cross trades presents a conflict of interest in that it is in the selling client’s interest to receive the highest possible price, while it is in the purchasing client’s interest to receive the lowest possible price. We address this conflict by disclosing it to you and by seeking execution at prices that are advantageous for both the selling and purchasing client. Item 13 - Review of Accounts Markets are monitored continuously, and accounts are reviewed regularly by Investment Committee Members for consistency with the client’s investment objectives and risk tolerance. Clients are requested to notify us any time there are changes to their financial situation that might warrant a change to their investment strategy. Clients may contact us any time to discuss their account, financial situation, or investment needs. All clients receive trade confirmations and monthly account statements (quarterly when there is no activity in the account) from brokerage firms where their account is held. By their own choice, some clients receive their statements and trade confirmations electronically. The monthly statements show all transactions, including amounts deposited and disbursed from accounts, as well as the cash and securities in the account. This brokerage statement is the official record of your account for tax purposes. Item 14 – Client Referrals & Other Compensation Asset Advisors is fortunate to have gained clients over many years from referrals from existing clients and professionals, for example, accountants and lawyers. However, we do not compensate anyone for client referrals. Asset Advisors’ parent company is Focus Financial Partners, LLC (“Focus”). From time to time, Focus holds partnership meetings and other industry and best-practices conferences, which typically include Asset Advisors, other Focus firms and external attendees. These meetings are first and foremost intended to provide training or education to personnel of Focus firms, including Asset Advisors. However, the meetings do provide sponsorship opportunities for asset managers, asset custodians, vendors, and other third-party service providers. Sponsorship fees allow these companies to advertise their products and services to Focus firms, including Asset Advisors. Although the participation of Focus firm personnel in these meetings is not preconditioned on the achievement of a sales target for any conference sponsor, this practice could nonetheless be deemed a conflict as the marketing and education activities conducted, and 18  the access granted, at such meetings and conferences could cause Asset Advisors to focus on those conference sponsors in the course of its duties. Focus attempts to mitigate any such conflict by allocating the sponsorship fees only to defraying the cost of the meeting or future meetings and not as revenue for itself or any affiliate, including Asset Advisors. Conference sponsorship fees are not dependent on assets placed with any specific provider or revenue generated by such asset placement. The following entities have provided conference sponsorship to Focus from January 1, 2024 to February 1, 2025: • Advent Software, Inc. (includes SS&C) • BlackRock, Inc. • Blackstone Administrative Services Partnership L.P. • Capital Integration Systems LLC (CAIS) • Charles Schwab & Co., Inc. • Confluence Technologies Inc. • Eaton Vance Distributors, Inc. (includes Parametric Portfolio Associates) • Fidelity Brokerage Services LLC and Fidelity Distributors Company LLC (includes Fidelity Institutional Asset Management and FIAM) • Flourish Financial LLC • Franklin Distributors, LLC (includes O’Shaughnessy Asset Management, L.L.C. (OSAM) and CANVAS) • K&L Gates LLP • Nuveen Securities, LLC • Orion Advisor Technology, LLC • Pinegrove Capital Partners LLC (includes Brookfield Oaktree Wealth Solutions) • Practifi, Inc. • Salus GRC, LLC • Stone Ridge Asset Management LLC • The Vanguard Group, Inc. • TriState Capital Bank • UPTIQ, Inc. You can access updates to the list of conference sponsors on Focus’ website through the following link: https://www.focusfinancialpartners.com/conference-sponsors Other products or companies giving sponsorship to supervised persons of Asset Advisors in the last fiscal year include: • Nuveen, LLC 19  Item 15 - Custody Our Firm is deemed to have custody over accounts of certain clients where an officer of Asset Advisors serves as executor, trustee or general power of attorney of the account. We obtain an annual surprise audit to verify the assets in such accounts, as required by the SEC. We are also deemed to have custody of client funds if Asset Advisors directly debits investment advisory fees from client accounts. Debiting of fees is done pursuant to authorization provided by each client and we are not required to obtain a custody audit for having this form of custody. We are also deemed to have custody when clients give us the authority, through Standing Letters of Authorization, to direct the client account custodian to transfer assets to third parties. We rely on SEC no-action relief from the custody audit requirement for this form of custody. Usually monthly, but no less than quarterly, clients receive account statements directly from the custodian of their account. Custodial statements show account holdings, market values and any activity that occurred during the period, including the deduction of our investment advisory fee. Asset Advisors urges clients to compare information contained in reports provided by Asset Advisors with the account statements received directly from the account custodian. Clients may notice differences in portfolio values reflected on the statements due to one or more of the following: (1) unsettled trades; (2) the timing of accrued income and dividends; and (3) pricing of securities. Item 16 - Investment Discretion Asset Advisors maintains full discretionary trading authority over the securities in client portfolios pursuant to a limited power of attorney granted in our client agreements. Item 17 - Voting Client Securities Our Firm does not accept proxy voting authority over client accounts (though we will process corporate actions such as mergers). Clients receive proxy materials for stocks owned in their accounts directly from their custodian. Item 18 - Financial Information Under certain conditions, an investment advisor must provide financial information about the firm to clients. These conditions are: • more than $1,200 of fees from one client required six months or more in advance; • a financial condition likely to impair the ability to meet contractual commitments; or • a bankruptcy occurred within the past ten years. Asset Advisors does not have anything to disclose pursuant to this item. 20