Description of Asset Allocation Strategies
Asset Allocation Strategies, LLC (or “AAS “the firm” or “the adviser” or “we”) is a Michigan limited
liability company that is an SEC registered investment advisory firm under the Investment Advisers Act
of 1940, as amended (the “Advisers Act”).
AAS, established in April 2010, provides investment advisory services to clients on either their
employer sponsored retirement program accounts or their personal investment accounts. We may
also offer advice to sponsors of 401(k) and 403(b) plans. With respect to our 401(k) and 403(b)
business, we have always been a fee based advisor. Our compensation is not commission based but is
a fee that is calculated as a percentage of assets under management.
Principal Owners and Officers
Mr. Alexander Kocoves, Managing Member Owner; Mr. Kocoves is a non-registered manager only
( 7 0 % owner). Mr. Kocoves does not perform supervisory duties for Asset Allocations Strategies, LLC.
Mr. Michael P. McEvilly, Member/Owner and does not perform supervisory duties for Asset
Allocation Strategies, LLC. [Series 7; Series 24 ; Series 63 ; licensed for life insurance sales] (30%
owner).
Mr. Justin Rolnitzky is the Director of Internal Operations of Asset Allocation Strategies, LLC and a
Principal with the firm’s affiliated broker-dealer, GLP Investment Services, LLC. Mr. Rolnitzky is able
to approve new business, sign agreements for the firm with businesses and advisory clients and
conduct portfolio management. [Series 7; Series 66; Series 24].
AAS does require its advisory representatives to qualify by passing either the series 65 or the
combination of the series 7 and 66.
Advisory Services
AAS offers discretionary and non-discretionary account management with a variety of investment strategies that
range from conservative to aggressive and take an active approach to investing for our clients. AAS also offers
Financial Planning and consulting services to clients and plan sponsors on their defined benefit, defined
contribution and deferred compensation plans for a flat fee or basis points arrangement. While a majority of our
client’s assets are held on the SCHWAB ADVISOR SERVICES platform, on occasion we may refer clients to a third
party asset manager.
Our asset management services are provided on a discretionary basis. With discretionary authority, we make all
decisions to buy, sell or hold securities, cash or other investments in the managed account in our sole discretion
without consulting you before implementing any transactions. You must provide us with written authorization to
exercise this discretionary authority. Discretionary authority is limited. We do not have access to your funds
and/or securities with the exception of having advisory fees deducted from your account and paid to us by the
account custodian. You may revoke this authority at any time, in writing, to us.
We also offer non-discretionary portfolio management services. If you enter into non-discretionary arrangements
with our firm, we must maintain your approval prior to executing any transactions on behalf of your account. You
have an unrestricted right to decline to implement any advice provided by our firm on a non-discretionary basis.
Custodians are also broker- dealers, and they may have different account fees, execution charges and capacities.
This may occur because custodial services are based on several factors. Factors may include, but are not limited to
cost, expected level of asset safety, client confidentiality, communication, reporting and execution quality of client
trades. We base all decisions on the individual investment circumstances of each client.
• Portfolio Management using AAS model portfolios
AAS is a Michigan-based, SEC registered investment adviser (801-106707) that offers discretionary and non-
discretionary advice on constructing, implementing and re-balancing investment portfolios. Additionally, based on
Capital Market Assumptions developed by the Portfolio Manager, advice is rendered as to optimal asset classes and
asset allocation with respect to the clients overall Strategic Asset Allocation The firm is prepared to provide advice
on many types of securities (see Item 8), Non-discretionary advice will require clients to approve, in writing, each
trade execution a client may request the adviser to place on the client's behalf.
• Portfolio Management using Schwab Advisor Services portfolios
As part of our portfolio management services, in addition to other types of investments (see disclosures below
in this section), we may invest your assets according to one or more model portfolios developed by Schwab.
These models are designed for investors with varying degrees of risk tolerance ranging from a more aggressive
investment strategy to a more conservative investment approach.
Financial Planning Services
We offer financial planning services which typically involve providing a variety of advisory services to clients
regarding the management of their financial resources based upon an analysis of their individual needs. These
services can range from broad-based financial planning to consultative or single subject planning. AAS’ clients may
be interviewed using a fact finder whose purpose is to establish what investments are suitable for each client. Some
of these interviews will uncover other financial needs in which instances representatives of AAS can provide financial
planning services to those clients who desire them. Further fact finding will aim at assessing a client's insurance
needs, financial situation, estate, tax planning needs and other topics such as risk-management that a client may
request. The adviser utilizes a financial planning software program to assist in the evaluation. We will deliver a
written plan to you, designed to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial
information you provide to us. You must promptly notify our firm if your financial situation, goals, objectives, or
needs change.
You are under no obligation to act on our financial planning recommendations. Should you choose to act on any of
our recommendations, you are not obligated to implement the financial plan through any of our other investment
advisory services. Moreover, you may act on our recommendations by placing securities transactions with any
brokerage firm.
Services to Plan Sponsors
We may provide investment advice to plan sponsors for which we have a formal agreement to do so. Every plan
should have a clear investment policy that sets out how the plan is to be run and how its performance and the
performance of its investments are analyzed and reviewed. We assist plan sponsors with development and review
of their Investment Policy Statement. We begin with a general meeting to obtain background information
and determine the scope of services required. Once the Investment Policy Statement is finalized, we can also assist
in the selection of investment
categories as well as specific investment choices.
We offer an independent view of the funds and investment vehicles available. We also assist plan sponsors with
periodic reviews of investment choices. The specific services we provide to a plan sponsor may vary depending on
our relationship. Thus, our agreement with the plan sponsor will describe the specific services we agree to provide
the plan sponsor. In any of our services, our clients may place reasonable restrictions on their accounts making it
possible for a client to exclude a certain market sector, issuer or particular security type.
Retirement Plan Rollovers and DOL Fiduciary Status
When we provide investment advice about your retirement plan account or individual retirement account (“IRA”)
including whether to maintain investments and/or proceeds in the retirement plan account or roll over such
investments from the retirement plan account to an IRA or make a distribution from the retirement plan account,
we acknowledge that the firm is a “fiduciary” within the meaning of Title I of the Employee Retirement Income
Security Act (“ERISA”) and/or the Internal Revenue Code as applicable. The way that the firm makes money creates
conflicts with your interests, so the firm operates under a special rule that requires that firm to act in your best
interest and not put our interests ahead of yours.
Under this special rule’s provisions, the firm must as a fiduciary to a retirement plan account or IRA under
ERISA/the Internal Revenue Code by:
• Meeting a professional standard of care when making investment recommendations (i.e., give prudent
advice);
• Never putting the interests of the firm ahead of you when making recommendations (i.e., give loyal
advice);
• Avoiding misleading statements about conflicts of interest, fees, and investments;
• Following policies and procedures designed to ensure that the firm gives advice that is in your best interest;
• Charging no more than is reasonable for the services of the firm; and
• Giving you basic information about any conflicts of interest.
To the extent that we recommend that you roll over your account to an account managed by the firm, please know
that the firm, its investment advisor representatives have an inherent conflict of interest. Increased investment
advisory fees may be earned by recommending that you roll over your account to an account managed by the firm.
We will earn fewer investment advisory fees if you do not roll over the funds to an account managed by the firm.
Thus, our investment advisor representatives have an economic incentive to recommend a rollover of funds to an
account managed by the firm which is a conflict of interest because our recommendation that you open the
account to be managed by the firm can be based on our economic incentive and not based exclusively on whether
or not moving the funds is in your overall best interest.
We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby
our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding
a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not
recommend investments which result in the firm receiving unreasonable compensation related to the rollover of
funds, and (iii) fully disclose compensation received by the firm and our supervised persons and any material
conflicts of interest related to recommending the rollover of funds and refrain from making any materially
misleading statements regarding such rollover.
When providing advice to you regarding a rollover, our investment adviser representatives and registered
representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing
that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an
enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial
circumstances, and a client’s needs, without regard to the financial or other interests of the firm or our affiliated
personnel.
Tailoring of Advisory Services
Effective portfolio allocation recommendations must be based on each client’s individual needs. As noted in
our Services to Individuals section, AAS’ clients will be interviewed to establish a client’s risk tolerance, goals
and objectives, tax and distribution needs. Based upon that information, suitable investments are
recommended to each client based upon their individualized situation and needs. Further fact finding will aim
at assessing a client's need for other financial services. From time to time, the adviser will utilize a financial
planning software program to assist in the evaluation. After the initial consultation, we will sign an agreement
to work together and gather additional information to open your account. Our discretionary management of
your account begins once assets are received at Schwab Advisor Services where the assets will be invested in
the selected securities. In many cases, the Firm uses ETFs to provide cost efficient broad market diversification
with improved tax efficiency that we believe is necessary for you, depending on your risk tolerance and financial
circumstances.
AAS may refer its advisory client to the advisory services of a third-party money manager or recommend its
own goals-based and risk-based based strategies. The selected third-party money managers and the portfolios
that are used are regularly vetted by the Compliance Department and/or Due Diligence Committee.
As a fiduciary, an investment adviser is to make only those recommendations that demonstrably are in the
client’s best interest, which means that they, too, must be based on an individual’s stated and/ or established,
individual needs, goals, risk tolerance and investment time horizon. These Plans should be re-evaluated on
annual basis or more frequently with substantive changes in the client’s financial situation.
Restrictions and Constraints
Clients may impose restrictions on the adviser’s ability to invest in certain securities or types of securities
including within discretionary accounts; clients must approve each recommended transaction they direct the
adviser to place as a transaction order for non-discretionary accounts.
Types of Investments
AAS uses some or all the following suitable investment options when providing advisory services: stocks,
bonds, mutual funds (stock funds, bond funds and other asset classes), options, exchange-traded funds
(“ETFs”), and the utilization of 3rd party money managers.
Wrap Fee Programs
AAS does not participate in a wrap fee program.
Client Assets Under Management by AAS
As of 12/31/2023 this firm had regulatory assets under management of $451,177,416 in a continuous and regular
manner, all of which are on a discretionary basis. Additionally, the firm managed $175,564,846 on a non-
discretionary basis.