Overview
Assets Under Management: $317 million
Headquarters: WOBURN, MA
High-Net-Worth Clients: 68
Average Client Assets: $3 million
Services Offered
Services: Portfolio Management for Individuals
Fee Structure
Primary Fee Schedule (AUOUR PART 2A BROCHURE)
Min | Max | Marginal Fee Rate |
---|---|---|
$0 | $1,000,000 | 1.00% |
$1,000,001 | $5,000,000 | 0.75% |
$5,000,001 | and above | 0.50% |
Illustrative Fee Rates
Total Assets | Annual Fees | Average Fee Rate |
---|---|---|
$1 million | $10,000 | 1.00% |
$5 million | $40,000 | 0.80% |
$10 million | $65,000 | 0.65% |
$50 million | $265,000 | 0.53% |
$100 million | $515,000 | 0.52% |
Clients
Number of High-Net-Worth Clients: 68
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 65.65
Average High-Net-Worth Client Assets: $3 million
Total Client Accounts: 775
Discretionary Accounts: 739
Non-Discretionary Accounts: 36
Regulatory Filings
CRD Number: 173392
Last Filing Date: 2024-09-30 00:00:00
Website: HTTPS://WWW.AUOUR.COM
Form ADV Documents
Primary Brochure: AUOUR PART 2A BROCHURE (2025-03-25)
View Document Text
Form ADV Part 2A: Firm Brochure
Firm Brochure
Part 2A of Form ADV
(Item 1)
Auour Investments
400 Tradecenter Suite 3990 Woburn, MA 01801
978-338-4830
www.auour.com
March 25, 2025
This brochure provides information about the qualifications and business practices of Auour
Investments. If you have any questions about the contents of this brochure, please contact the
Compliance Department at 978-338-4830. The information in this brochure has not been
approved or verified by the United States Securities and Exchange Commission or by any state
securities authority.
Additional information about the Adviser is available on the SEC’s website at www.adviserinfo.sec.gov
Auour Investments Brochure
ITEM: 2 MATERIAL CHANGES
ANNUAL UPDATE
The purpose of Item 2 is to discuss specific, material changes that have been made relative to the prior
Disclosure Brochure and to provide Clients with a summary of such changes.
MATERIAL CHANGES SINCE THE LAST UPDATE
Since the last distribution of this Disclosure Brochure, the firm has had the following changes:
1. (At Item 4 – Advisory Business) Auour has updated its assets under management .
FULL BROCHURE AVAILABLE
If you would like to receive a complete copy of our Firm Brochure, please call (978) 338-4830 or email
info@auour.com.
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TABLE OF CONTENTS
ITEM: 2 MATERIAL CHANGES .................................................................................... 2
ANNUAL UPDATE ...................................................................................................... 2
MATERIAL CHANGES SINCE THE LAST UPDATE ........................................................................ 2
FULL BROCHURE AVAILABLE ......................................................................................... 2
ITEM 4: ADVISORY BUSINESS .................................................................................... 4
ASSETS UNDER MANAGEMENT ....................................................................................... 4
PRINCIPAL OWNERS ................................................................................................... 4
FIRM DESCRIPTION .................................................................................................... 4
TYPES OF SERVICES ................................................................................................... 4
ITEM 5: FEES AND COMPENSATION ............................................................................ 5
FEE SCHEDULE .......................................................................................................... 6
WRITTEN AGREEMENT ................................................................................................ 7
ITEM 6: PERFORMANCE FEES AND SIDE-BY-SIDE MANAGEMENT ...................................... 7
ITEM 7: TYPES OF CLIENTS ....................................................................................... 8
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ................. 8
ITEM 9: DISCIPLINARY DISCLOSURES ....................................................................... 10
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS .......................... 10
ITEM 11: CODE OF ETHICS, RECOMMENDATIONS, PARTICIPATION OR INTEREST IN CLIENT
TRANSACTIONS AND PERSONAL TRADING ................................................................. 10
IRA ROLLOVER RECOMMENDATION ................................................................................. 11
PARTICIPATION OR OTHER INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ........................ 12
ITEM 12: BROKERAGE PRACTICES ........................................................................... 12
SOFT DOLLARS OR ECONOMIC BENEFITS ............................................................................ 13
BROKERAGE FOR CLIENT REFERRALS ............................................................................... 13
TRADE AGGREGATION ............................................................................................... 13
TRADE ROTATION POLICY ........................................................................................... 14
ITEM 13: REVIEW OF ACCOUNTS AND REPORTS .......................................................... 14
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION (SOLICITOR ARRANGEMENTS) 14
ITEM 15 CUSTODY ................................................................................................. 15
ITEM 16 INVESTMENT DISCRETION .......................................................................... 15
ITEM 17 VOTING CLIENT SECURITIES ....................................................................... 16
ITEM 18 FINANCIAL INFORMATION .......................................................................... 16
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ITEM 4: ADVISORY BUSINESS
Being registered does not mean any regulatory authority endorses Auour or implies any level of skill or
training. The Adviser is headquartered in Woburn, MA. Auour’s services involve portfolio management
and investment advisory services.
ASSETS UNDER MANAGEMENT
Total assets under management (“AUM”) as of December 31, 2024:
Non-Discretionary
$33,615,123
Discretionary
$307,321,034
Total
$340,936,157
PRINCIPAL OWNERS
Auour Investments, a Massachusetts limited liability company founded in 2013, is owned by its managing
principals, Joseph Hosler, Robert Kuftinec, and Kenneth Doerr, through direct ownership. The managing
principals hold 100% of the firm.
FIRM DESCRIPTION
Auour Investments uses proprietary asset allocation investment processes and models to help guide
investment decisions aiming to manage portfolio risk to best protect and grow clients’ future purchasing
power. Client assets are generally invested using a passive exchange-traded fund (“ETF”) strategy but
may also hold stocks, bonds, mutual funds, and other types of securities.
The firm’s investment strategies are offered as described below.
TYPES OF SERVICES
Directly Managed Separate Accounts
investment management services on a discretionary basis
Auour provides customized
to
individuals, family offices, family & charitable trusts, and high net-worth clients through our
investment advisor representatives (“IAR”). After discussions around risk tolerance, investment time
horizon, asset allocation, and income requirements, among other things, Auour, through our IARs, will
discuss options appropriate and suitable to the client based on the client’s investment needs.
Account supervision is guided by the client’s stated objectives (i.e., capital appreciation, growth,
income, etc.), and all managed accounts will be maintained with an independent, qualified custodian.
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Auour accounts are managed on a discretionary or non-discretionary basis as indicated in the Auour
Investment Advisory Agreement.
Sub-Advisor or Co-Advisor to Managed Separate Accounts
The Firm also provides discretionary investment advisory services to separate account clients as a
subadvisor or co-advisor to other registered investment advisers (outside RIAs). The RIA's investment
adviser representative (IAR) selects an investment strategy for their client after consulting with them and
providing the risk profile to Auour to substantiate the selection.
The RIA is responsible for providing updates to Auour as and when applicable.
Clients utilizing Auour as a subadvisor or co-advisor will pay higher fees than clients in Directly
Managed Separate Accounts.
Strategy Signal Service
Auour offers a strategy signal service whereby it enters into a non-discretionary advisory agreement with
unaffiliated third parties. This offers a broader distribution of the Auour strategies to non-clients
unrelated to service providers. Through this service, Auour uploads holdings and trade instructions to the
various third parties’ platforms which may then utilize the information as a component of the allocation
process for their clients that subscribe to the Auour strategies. The third parties and their clients may
choose to follow (or not) the signals Auour provided. Auour does not manage any accounts under the
strategy signal service and is not responsible for the trade execution or reconciliation of these accounts.
Any assets that rely on the signals are not included in AUM and will be identified as Assets Under
Advisement (“AUA”).
ITEM 5: FEES AND COMPENSATION
Auour receives fees for its advisory services based on assets under management. For directly managed
separate accounts, some assets in a managed account may not be included in the client’s advisory fee
calculation if those assets are deemed non-discretionary investments. The fee Auour charges is generally
established in the client’s written agreement with Auour. Auour may bill its fees monthly or quarterly.
Clients pay fees in arrears as specified in the advisory agreement.
For subadvisor and co-advisor relationships, Auour charges its portion of the advisory fee and, in
addition, charges a fee that is paid to the outside RIA. As such, the costs associated with a program are
more than those of Auour’s Direct Managed Separate Accounts. The client generally pays for ongoing
investment and planning advice and portfolio management from the outside RIA and Auour. The fee paid
to the outside RIA may be more than what the outside RIA would receive if the client participated in
another program. As a result, the outside RIA may be financially incentivized to recommend Auour’s
program or service over other programs or services.
For directly managed separate accounts, co-advisor, and subadvisor relationships, the Qualified Custodian
generally deducts advisory fees from the client account upon instruction from Auour. The Custodian will
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send statements directly to the client reflecting the deduction of these fees. Clients are encouraged to
contact Auour or the Custodian with any questions or concerns related to the fees.
In addition to the investment advisory fees and transaction charges, accounts may also incur certain
charges imposed by third parties in connection with investments made through the program. These may
include, but are not limited to, the following: mutual fund or money market 12b-1 fees, mutual fund,
money market or ETF management fees and administrative expenses, mutual fund transaction fees, other
transaction charges and service fees, IRA and qualified plan fees, processing and handling fees or other
charges on a fully disclosed basis. Further information regarding charges and fees assessed by a mutual
fund is available in the appropriate prospectus, which is delivered to the client by the Custodian under a
contractual arrangement with Auour.
Mutual funds and exchange-traded funds also charge internal management fees, which are disclosed in a
fund’s prospectus. Such charges, fees, and commissions are exclusive of and in addition to Auour’s fee.
Auour shall not receive any portion of these commissions, fees, and costs. Clients may avoid additional
fees by purchasing funds directly from a fund family and not receiving investment advice.
Compensation for the Sale of Securities or Other Investment Products
Persons providing investment advice on behalf of our firm are licensed as independent insurance agents.
These persons will earn commission-based compensation for selling insurance products, including those
they sell to you. Insurance commissions earned by these persons are separate and in addition to our
advisory fees. This practice presents a conflict of interest because persons providing investment advice on
behalf of our firm, who are insurance agents, have the incentive to recommend insurance products to you
to generate commissions rather than solely based on your needs. You are under no obligation,
contractually or otherwise, to purchase insurance products through any person affiliated with our firm.
FEE SCHEDULE
Auour Investments
For Directly Managed Separate Accounts, Auour charges a fee (the “Fee”) for investment supervision and
management of the Account(s) based on the current market value assets in the Account(s) (including cash
and equivalent items) according to the following schedule:
Assets Under Management
Annual Fee
On the first $1 Million
1.00%
On the next $4 Million
0.75%
Above $5 Million
0.50%
Fees are payable in arrears in either 1) quarterly installments or 2) monthly installments, based on the
account’s average daily market value (s). The custodian will typically deduct payment at the end of the
period.
For sub-advisory and co-advisory clients, fees charged by outside RIAs are in addition to those charged
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by Auour, resulting in higher total fees. All fees are negotiable and agreed upon among the outside RIA,
Auour, and Client and are disclosed in the Investment Advisory Agreement and, when applicable, a
separate Tri-Party Addendum. Fees are payable in arrears in monthly installments based on the account’s
average daily market value (s). The custodian will typically deduct payment at the end of the period.
For the strategy signal service, Auour negotiates fees directly with third parties.
For all relationships, if the Agreement starts at a date other than the beginning of a calendar quarter (or
month for clients paying monthly), the Fee for that partial quarter/month shall be prorated accordingly. In
the event of any termination of this Agreement, the Adviser’s Fees will be calculated pro-rata through the
termination date.
The firm relies on third-party resources such as the custodian for valuations of publicly traded securities
based on our assessment of their reliability.
The Client will be responsible for all other expenses, such as broker commissions, fund loads, fund
management fees, and custody fees. Those fees are separate, apart, and in addition to the fees to Auour.
Auour does not earn any portion of the fees described in this paragraph.
All advisory fees are subject to negotiation.
WRITTEN AGREEMENT
All clients are required to sign an advisory agreement with Auour. The client or Auour may terminate or
assign the advisory relationship in accordance with the provisions of those agreements. It is noted that
Auour will not assign the advisory agreement without the client’s consent. Additionally, a client may
terminate its advisory relationship with Auour at any time without penalty. Auour encourages clients to
carefully review the terms outlined in the agreement before signing the agreement.
ITEM 6: PERFORMANCE FEES AND SIDE -BY-SIDE MANAGEMENT
Auour does not charge performance-based fees (based on a share of capital gains on or appreciation of a
client’s assets).
Auour offers separately managed accounts and sub-advisory services to third-party advisors. Some of
these offerings include portfolios of investments that may be substantially identical and could create
certain conflicts of interest. As the investment funds will be managed concurrently, all transactions will
be implemented according to Auour's trade allocation procedures. These procedures, among other things,
ensure that all trades allocated to advisory clients fulfill Auour's fiduciary duty to each client and
otherwise allocate securities on a fair and non-discriminatory basis. In determining a fair allocation,
Auour considers several factors, including, among other things, the Adviser’s fiduciary duty to each
client, any potential conflicts of interest, the size of the transaction, the relative value of a client’s
portfolio, cash available for investment, suitability as well as each client’s investment objectives. Auour
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has in place several controls to manage this risk, including independent monitoring of portfolio risk,
performance, and exposure and periodic compliance monitoring reviews.
ITEM 7: TYPES OF CLIENTS
Auour Investments primarily provides investment advisory services to individuals, high-net-worth
individuals, trusts, estates, and charitable organizations. Auour does impose a minimum relationship size
of $5,000,000 for Directly Managed Separate Account clients. This is negotiable depending on the client
relationship.
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK
OF LOSS
Auour’s investment strategy combines global strategic asset allocations with disciplined tactical
adjustments driven through our proprietary multi-factor model that assesses the risk appetite of the global
markets. Auour offers investors five globally diversified portfolios constructed using proprietary asset
allocation strategies.
Shifts, both strategic and tactical, to the strategies, will be based on our quantitative model (“Auour
Regime Model,” or “ARM”), which analyzes macroeconomic factors such as geographically-based return
diffusions, style-based return diffusions, credit market conditions, pricing momentum, market valuations,
and market volatility. We will also consider political events and country-specific dynamics in our
investment decision-making process.
Auour believes in and employs several investment biases in portfolio construction. These include:
(a) passive management generally outperforms active management.
(b) investment returns are primarily driven by asset allocation versus stock selection,
(c) avoiding major market corrections drives investment returns, and
(d) asset class returns revert to the mean over time.
These beliefs influence the design of the Auour investment processes.
The Auour Investment Committee regularly (but no less frequently than weekly) monitors each strategy's
strategic and tactical allocations. The monitoring includes reviewing each strategy's asset class, sector,
and geographical exposures while evaluating the liquidity and construction of the underlying securities.
We rebalance when market conditions dictate to our asset class exposure while also adjusting this
exposure based on our model’s risk regime calculation.
Auour believes that the best investment vehicles to implement our globally diversified asset allocation
model are exchange-traded funds (“ETFs”). ETFs provide liquidity, transparency, tax efficiency, and
diversification in a low-cost investment vehicle. The Auour Investment Committee routinely evaluates
each ETF investment based on liquidity, capitalization, transparency, relative cost, investment objective,
tax implications, tracking error and premium/discount. The strategy may include the limited use of
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Exchange Traded Notes (“ETNs”) and other investment vehicles that assist in producing the desired
outcome. Our investment process does not anticipate using margin, leverage, or derivatives but uses
levered ETFs within our most aggressive strategy. The strategy does not include direct shorting of
securities but may employ selective use of inverse ETFs.
Auour manages seven distinct investment strategies. Each strategy aims to reduce risk through
diversification and mitigate losses in the financial markets.
Ultra Low Duration Fixed Income strategy provides exposure to global income and liquid alternative
investments. The primary investment objective is maintaining the principal with current dividend and
interest income.
Municipal Fixed Income strategy provides exposure to tax-advantaged income and liquid alternative
investments. The primary investment objective is national tax-advantaged current dividend and interest
income, although income and capital growth is considered.
Instinct Global Fixed Income strategy provides exposure to global income and liquid alternative
investments. The primary investment objective is current dividend and interest income, although capital
growth is considered.
Instinct Multi-Asset Income strategy provides exposure to global equities, global income, and liquid
alternative investments. The primary investment objective is current dividend and interest income,
although the growth of income and capital is considered.
Instinct Global Balanced strategy provides exposure to global equities, global income, and liquid
alternative investments. The primary investment objective is a combination of capital growth with current
income.
Instinct Global Equity strategy provides broad exposure to domestic/international, value/growth,
small/large, sectors/country, and liquid alternative investments. The primary investment objective is long-
term capital growth, with current income a secondary consideration.
strategy provides broad exposure
to a combination of
Instinct Global Equity Levered
domestic/international, value/growth, small/large, sectors/country, and liquid alternative investments and
“ultra” ETFs to provide leverage to market returns. The primary investment objective is long-term capital
growth. Current income is not considered.
Each Auour portfolio typically owns between 5 and 20 separate securities, and no individual security will
represent >50% of total portfolio assets except within extreme market conditions.
Investing in Auour portfolios involves risks, including the potential for capital loss. Auour’s investment
strategies focus on investments in exchange-traded funds (ETFs) that hold domestic and international
equities, fixed income, real estate, commodities, precious metals, currencies, derivatives, cash, and other
instruments. The returns generated by these ETFs are subject to numerous risks, including economic,
social, and political uncertainty, market volatility, foreign currency exchange rate volatility, and tracking
error versus an underlying index. ETFs holding fixed-income securities are also subject to default and
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interest rate risks. There can be no assurance that the investment objectives of any portfolio managed by
Auour will be achieved.
ITEM 9: DISCIPLINARY DISCLOSURES
Auour must disclose all material facts regarding any legal or disciplinary events that would be material to
your evaluation of Auour or the integrity of Auour’s management. Auour has no information applicable
to this item. Although Auour must and will make separate disclosure if disciplinary disclosure
information changes, clients are encouraged to review publicly available information about the entity and
the individuals and www.adviserinfo.sec.gov.
ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND
AFFILIATIONS
Arrangements with Affiliated Investment Adviser
We are affiliated with Integrity Financial Advisors, LLC, through common control and ownership.
Integrity is distinct from Auour in that its advisers focus on risk protection and financial planning. In most
situations, Integrity will utilize Auour for investment management and account servicing. Those clients
enter into a tri-party agreement with both Auour and Integrity and pay fees that include the fees
associated with their financial adviser services and Auour's investment management services. Auour
relies on Integrity advisers to direct Auour on the risk tolerance of the client and the positioning within
the Auour strategies that best fit the client’s needs. Conflicts may present themselves as Auour is a 50%
owner in Integrity.
Receipt of Insurance Commission
Certain persons associated with our firm are also licensed insurance agents with various insurance
companies and, in such a capacity, may recommend purchasing certain insurance products. Please refer to
Item 5, Fees and Compensation, for more information.
11:
CODE
OF
ETHICS,
ITEM
RECOMMENDATIONS,
PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
Auour places significant value on ethical conduct for all advisory business. As such, Auour has adopted a
Code of Ethics (“Code”) to establish and implement ethical obligations and provide rules for reviewing
the personal securities transactions of its supervised persons. Auour owes a duty of loyalty, fairness, and
good faith towards its clients, and it is obligated to adhere not only to the specific provisions of the Code
but to the general principles that guide the Code.
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The Code covers a range of topics that may include general ethical principles, reporting personal
securities trading, exceptions to reporting securities trading, reportable securities, initial public offerings
and private placements, reporting ethical violations, distribution of the Code, review and enforcement
processes, amendments to Form ADV and supervisory procedures. The Code also includes Auour’s
policy that prohibits the use of material non-public information. Any principal or associate who does not
observe the provisions of the Code may be subject to discipline.
As a fiduciary to their clients, an Adviser is responsible for providing professional, continuous, and
unbiased investment advice. Fiduciaries owe their clients a duty of honesty, good faith, and fair dealing.
To ensure that our employees strictly adhere to the highest standards of conduct and integrity in
conducting business on behalf of our clients, we require that each year, every Auour associate certify that
he or she: (1) has read and understood the Code, (2) recognizes that the Code applies to him or her, and
(3) has complied with all of the rules and requirements of the Code.
Auour will provide a copy of its Code of Ethics at no charge to any client or prospective client upon
request.
IRA ROLLOVER RECOMMENDATION
When we provide investment advice to you regarding your retirement plan account or individual
retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income
Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement
accounts. How we make money creates conflicts with your interests, so we operate under a special rule
that requires us to act in your best interest and not put our interests ahead of yours. Under this special
rule’s provisions, we must:
a. Meet a professional standard of care when making investment recommendations (give prudent
advice).
b. Never put our financial interests ahead of yours when making recommendations (give loyal
advice).
c. Avoid misleading statements about conflicts of interest, fees, and investments.
d. Follow policies and procedures designed to ensure that we give advice that is in your best
interest.
e. Charge no more than is reasonable for our services; and
f. Give you basic information about conflicts of interest.
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PARTICIPATION OR OTHER INTEREST IN CLIENT TRANSACTIONS AND
PERSONAL TRADING
Occasionally, Auour may employ a security within its strategies in which the firm or an employee owns
shares or has other financial interests. Although rare, when this occurs, Auour’s procedures require the
firm to determine that the investment suits the client’s needs and risk profile and that any corresponding
transactions in the security in the Auour employee’s account are conducted equally or more favorably to
the client. If an employee of the firm wishes to buy or sell for himself/herself a model portfolio security
that has also been recommended to a client, the Auour employee transaction is placed at the same time
and terms as the client transaction.
No agency cross transactions or principal trades will be affected in an advisory account.
ITEM 12: BROKERAGE PRACTICES
Auour will recommend that clients establish brokerage accounts with Fidelity Brokerage Services LLC
Member NYSE/SIPC, Charles Schwab & Co., Inc. Member FINRA/SIPC, or Interactive Brokers LLC
Member NYSE/FINRA/SIPC to maintain custody of clients’ assets and to effect trades for our accounts.
However, Auour does not require clients to use Interactive Brokers, Fidelity, or Schwab. Auour is
independently owned and operated and is not affiliated with Interactive Brokers, Fidelity, or Schwab.
Interactive Brokers Fidelity and Schwab provide us access to their institutional trading and custody
services, which are typically unavailable to retail investors. These services generally are available to
independent investment advisors on an unsolicited basis, at no charge to them so long as a total of at least
$20 million of the advisor’s clients’ assets are maintained in accounts at each custodian and are not
otherwise contingent upon Auour committing to Interactive Brokers, Fidelity, or Schwab any specific
amount of business (assets in custody or trading). Interactive Brokers’, Fidelity’s, and Schwab’s services
include brokerage, custody, research, and access to mutual funds and other investments that are otherwise
generally available only to institutional investors or would require a significantly higher minimum initial
investment.
For clients in custodial relationships with Interactive Brokers, Fidelity, or Schwab, Auour employs block-
trading principles. (See “Trade Aggregation” below) This process is designed to result in all clients
receiving approximately the same price for the purchase or sale of securities. Clients opting for custody
outside Interactive Brokers, Fidelity, or Schwab may not get the same price. To best ensure fairness
across all custodian and execution venues, Auour utilizes a trade rotation policy to notify custodians of
desired trades (See “Trade Rotation Policy” below).
For our client accounts maintained in its custody, Fidelity, Schwab, and Interactive Brokers generally do
not charge separately for custody but are compensated by account holders through commissions or other
transaction-related fees for securities trades executed through them that settle into their accounts.
A client may direct us in writing to use a particular broker/dealer to execute all transactions for the client's
account. When a client selects the broker to be used for his account, the commission rates are decided
upon between the client and his broker. In addition, Auour does not have any responsibility for
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obtaining for the client from any such broker the best prices or particular commission rates, and the client
may not obtain rates as low as it might otherwise obtain if the client utilized a broker recommended by
Auour. Therefore, directing brokerage to a particular broker/dealer may cost clients more or less money.
Clients that restrict us from using a particular broker/dealer (or direct us to use a particular broker/dealer)
for executing their transactions generally will be unable to participate in aggregated orders and will be
precluded from receiving the benefits, if any, of an aggregation which other clients may receive. (See
also: Trade Aggregation, below)
SOFT DOLLARS OR ECONOMIC BENEFITS
Fidelity, Schwab, and Interactive Brokers also make available to us other products and services that
benefit Auour but may not directly benefit our clients’ accounts. Some of these other products and
services assist us with managing and administering clients’ accounts. These include software and other
technology that provide access to client account data (such as trade confirmations and account
statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client
accounts), provide research, pricing information, and other market data, facilitate payment of our fees
from client accounts, and assist with back-office functions, recordkeeping, and client reporting. Many of
these services are used to service all or a substantial number of Auour’s accounts. In addition, Fidelity,
Schwab, and Interactive Brokers make available, arrange and/or pay for these services rendered to us by
independent third parties. Fidelity, Schwab, and Interactive Brokers discount or waive fees they would
otherwise charge for some of these services or pay all or a part of the fees of a third party providing these
services to Auour. While as a fiduciary, Auour endeavors to act in its client’s best interests, our
recommendation that clients maintain their assets in accounts at Interactive Brokers, Fidelity, or Schwab
may be based in part on the benefit to Auour of the availability of some of the foregoing products and
services and not solely on the nature, cost or quality of custody and brokerage services provided by them,
which may create a potential conflict of interest.
Auour may receive services from other broker-dealers that enhance its ability to service its clients. For
instance, recommended broker-dealers may provide Auour with automated or electronic access to client
account information, duplicate statements, or consolidated reports.
BROKERAGE FOR CLIENT REFERRALS
Auour does not refer clients to brokers in exchange for referrals.
TRADE AGGREGATION
Auour may combine orders into block trades at either custodian when more than one account held at that
custodian is participating in the trade. This blocking or bunching technique must be equitable and
potentially advantageous for each account (e.g., reducing brokerage commissions or obtaining a more
favorable execution price). Block trading is performed when it is consistent with the duty to seek the best
execution with the terms of Auour’s investment advisory agreements. Equity trades are blocked based
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upon fairness to the client, both in the participation of their account and in allocating orders for the
accounts of more than one client. Allocations of all orders are performed in a timely and efficient
manner. All managed accounts participating in a block execution receive the same execution price
(average share price) for the securities purchased or sold on a trading day. Due to the low liquidity of
certain securities, broker availability may be limited. Open orders are worked until they are filled, which
may span several days. If an order is filled in its entirety, securities purchased in the aggregated
transaction will be allocated among the accounts participating in the trade in accordance with the
allocation statement. If an order is partially filled, the securities will be allocated pro rata based on the
allocation statement.
TRADE ROTATION POLICY
As a fiduciary, the firm looks to institute best practices and treat all discretionary and non-discretionary
clients (model delivery platforms) fairly and similarly. Auour has instituted a random trading rotation
process for the dissemination of strategy holdings designed to ensure that, over time, all participants are
treated equally.
Auour maintains a list of trading groups, including direct clients segmented by custodian and all model
delivery platforms. This list will be randomized quarterly, and the notification order will be set for that
quarter. It is expected that Auour will rebalance all strategies monthly unless outside factors require
immediate action. Auour will initiate the trading process when trades must be effected by notifying each
group as set in the randomized list. Notification will constitute an e-mail with confirmation of receipt or
uploading to a firm’s portal.
For assets under advisement, the third party, not Auour, takes responsibility for ensuring the trading of
model portfolios.
ITEM 13: REVIEW OF ACCOUNTS AND REPORTS
The Investment Committee is responsible for the day-to-day supervision of each account. The
performance of each account is reviewed on a regular basis and compared to strategy composites.
Auour furnishes its client with a written quarterly portfolio review, including the following for each
security: cost basis, market value, annual income, current yield, and asset class. The Investment
Committee members meet with clients when and if necessary. Clients also receive account statements
directly from their chosen custodian monthly. Clients are encouraged to review the custodial account
statements carefully.
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION (SOLICITOR
ARRANGEMENTS)
Outside RIAs, for example, unaffiliated broker/dealers and investment advisers who are directly
responsible for bringing a client to Auour Investments receive separate compensation from us for client
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referrals. Such arrangements comply with the requirements under the Investment Advisers Act of 1940
and/or applicable law, including an agreement between the Firm and the outside RIA. Outside RIAs must
provide a copy of Auour’s Brochure and a separate outside RIA’s Disclosure Statement regarding the
relationship between the outside RIA and Auour to the prospective client at the time of engagement. The
prospective client must acknowledge this arrangement before accepting the account for advisory services.
A conflict of interest exists due to the nature of the arrangements. As such, third-party clients are advised
to pay attention to and carefully consider the separate fees earned by the outside RIA in connection with
the referral to Auour.
ITEM 15 CUSTODY
Clients will receive written transaction confirmation notices and monthly or quarterly statements from the
Custodian that holds and maintains the Client’s Account. Auour urges all Clients to carefully review such
statements and compare such official custodial records to the Account statements Auour may provide.
Auour’s report may vary from custodial statements based on accounting procedures, reporting dates, or
valuation methodologies of certain securities. The account custodian does not verify the accuracy of the
Adviser’s advisory fee calculations.
In addition, certain Clients have established asset transfer authorizations that permit the qualified
custodian to rely upon instructions from Auour to transfer Client funds or securities to third parties. These
arrangements are disclosed in Item 9 of Part 1 of Form ADV. However, in accordance with the guidance
provided in the SEC’s February 21, 2017, Investment Adviser Association No-Action Letter, the affected
accounts are not subject to an annual surprise CPA examination.
ITEM 16 INVESTMENT DISCRETION
Auour has investment discretion over most clients’ accounts. Auour’s authority includes the discretion to
determine the securities and amount to be bought and sold for a client’s account. Auour does not have
the authority to disburse funds from client accounts. Clients grant us trading discretion by executing a
limited power of attorney included in Auour’s advisory contract and custodian account opening
documentation.
Clients can place reasonable restrictions on Auour’s investment discretion if the restrictions fit within
our investment strategies. For example, some clients have asked us not to sell certain securities where
the client has a particularly low tax basis.
Other clients, such as clients invested in self-directed 401ks, can manage their investments directly by
selecting investment options that include the Auour model portfolios, among other selections.
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ITEM 17 VOTING CLIENT SECURITIES
Auour’s policy on proxy voting with respect to client accounts is to vote proxies when requested in a
manner consistent with its fiduciary duty to clients. Auour shall be responsible for voting proxies on
behalf of client accounts. H o w e v e r , certain clients may retain full proxy voting authority. Proxy
voting authority is assigned in the Custodian’s account opening application. In cases where Auour
retains full responsibility over the proxy voting activities of an account, Auour shall vote client
proxies in a way that it believes will cause securities to increase the most or decline the least in value
to maximize shareholder value. Consideration will be given to both the short- and
long-term
implications of the proposal to be voted on when considering the optimal vote. Conflicts of interest will
be identified and addressed in such a manner as to benefit most clients and shareholders.
Notwithstanding Auour’s discretionary authority to make investment decisions on behalf of its clients,
Auour will not exercise proxy voting authority over certain clients’ accounts. Clients shall not be
precluded from contacting Auour for advice or information about a particular proxy vote.
ITEM 18 FINANCIAL INFORMATION
The firm’s principals are not aware of any financial condition that would prevent Auour from delivering
contractual services to clients.
Auour and its principals have neither claimed protection from creditors nor filed bankruptcy.
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