Aquilant Advisors is an investment adviser registered with the SEC and is a limited liability company (LLC) formed under the laws of the State of Missouri.
• Steven Farris is the Managing Member and 100% owner of Aquilant Advisors.
• Aquilant Advisors received its initial approval as a registered investment adviser in April 2016. Introduction The investment advisory services of Aquilant Advisors are provided to you through an appropriately licensed and qualified individual who is an investment adviser representative of Aquilant Advisors (referred to as your investment adviser representative throughout this brochure). Description of Advisory Services The following are descriptions of the primary advisory services of Aquilant Advisors. Please understand that a written agreement, which details the exact terms of the service, must be signed by you and Aquilant Advisors before we can provide you the services described below. Asset Management Services Aquilant Advisors offers asset management services, which involves Aquilant Advisors providing you with continuous and ongoing supervision over your specified accounts. You must appoint our firm as your investment adviser of record on specified accounts (collectively, the “Account”). The Account consists only of separate account(s) held by qualified custodian(s) under your name. The qualified custodians maintain physical custody of all funds and securities of the Account, and you retain all rights of ownership (e.g., right to withdraw securities or cash, delegate proxy voting and receive transaction confirmations) of the Account. The Account is managed by us based on your financial situation, investment objectives and risk tolerance. We actively monitor the Account and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Account. We will need to obtain certain information from you to determine your financial situation and investment objectives. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. We are always reasonably available to consult with you relative to the status of your Account. You have the ability to impose reasonable restrictions on the management of your accounts, including the ability to instruct us not to purchase certain securities. Aquilant Advisors Page 5 Form ADV Part 2A Disclosure Brochure It is important that you understand that we manage investments for other clients and may give them advice or take actions for them or for our personal accounts that is different from the advice we provide to you or actions taken for you. We are not obligated to buy, sell or recommend to you any security or other investment that we may buy, sell or recommend for any other clients or for our own accounts. Conflicts may arise in the allocation of investment opportunities among accounts that we manage. We strive to allocate investment opportunities believed to be appropriate for your account(s) and other accounts advised by our firm among such accounts equitably and consistent with the best interests of all accounts involved. However, there can be no assurance that a particular investment opportunity that comes to our attention will be allocated in any particular manner. If we obtain material, non-public information about a security or its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the information to any client or use it for any client’s benefit. Participation in Wrap Fee Programs Aquilant Advisors offer services through both wrap fee programs and non-wrap fee programs. A wrap fee program is defined as any advisory program under which a specified fee or fees not based directly upon transactions in a client’s account is charged for investment advisory services (which may include portfolio management or advice concerning the selection of other investment advisers) and the execution of client transactions. Whenever a fee is charged to a client for services described in this brochure (whether wrap fee or non-wrap fee), we will receive all or a portion of the fee charged. Asset Mark Platform Aquilant Advisors may offer advisory services to Clients by selecting the AssetMark Platform. For more information regarding the AssetMark Platform, refer to AssetMark Platform Disclosure Brochure. The minimum investment required on the AssetMark Platform depends upon the Investment Solution chosen for a Client’s account and is generally for Mutual Fund and $100,000 for ETF Accounts, and from $50,000 to $500,000 for Privately Managed and Unified Managed Accounts, depending on the investment strategy selected for the account. These minimums are described in more detail in the AssetMark Platform Disclosure Brochure. Accounts below the stated minimums may be accepted on an individual basis at the discretion of AssetMark. WealthPort Wrap Program Aquilant Advisors participate in the WealthPort Wrap program sponsored by Cambridge Investment Research Advisors, Inc. (CIRA). WealthPort Wrap (“WealthPort”) is a CIRA sponsored program that is recommended to clients of Aquilant Advisors. Aquilant Advisors participates, under a co-advisory relationship with CIRA, in fee-based services sponsored through CIRA’s WealthPort Wrap Programs. The wrap fee programs charge an inclusive fee, covering custodial, brokerage, and investment advisory services. All clients placed in the WealthPort Wrap Program are provided with the WealthPort Wrap Brochure before or at the time they enter the program. WealthPort accounts will be established at CIRA, with [Custodians: NFS, Pershing, Schwab and Fidelity] serving as the clearing broker/dealer. Aquilant Advisors Page 6 Form ADV Part 2A Disclosure Brochure The following information provides a brief summary of WealthPort Program options available to Aquilant Advisors. Advisor-Directed Program: In the WealthPort Advisor-directed Program, Aquilant Advisors provides investment management services, defined as giving continuous investment advice to you and makes investments based on your individual needs. Through the Program, we are responsible for determining investment recommendations and implementing transactions. We actively manage your account(s) in accordance with your individual needs, objectives and risk tolerance. CAAP® (Cambridge Asset Allocation Platform): Within the WealthPort CAAP®, CIRA has made arrangements with various strategists to provide consulting services in connection with the creation of asset allocation models and the selection of portfolio funds, ETFs, and/or Equities. The client’s investment objectives, financial situation, and risk tolerance will be considered. Consultants and/or Portfolio Managers can select their own proprietary funds to be held in a client’s portfolio, which creates a conflict of interest in that they will receive a separate and duplicitous form of income from the client when their own proprietary funds have been chosen for the client. CAAP strategists are not affiliated with Aquilant Advisors or CIRA. Unified Managed Account (UMA): The UMA program offers clients the ability to select multiple CAAP® strategies in one account. The UMA holds the investments recommended by each selected strategist in a separate sleeve. Proposal generation tools allow the client’s investment advisory representative to customize the asset allocation models on an individualized or generalized basis. Wherein the former allows for a tailored program while the latter may suit larger groups of clients with similar financial needs. The investment advisory representative is then responsible for further tailoring the chosen sleeves to meet their client’s individual needs, ongoing due-diligence, e balancing, and suitability needs as the client’s own personal financial situation evolves over time. All clients are provided with the WealthPort Wrap Brochure before or at the time the client enters into this program. Advisory Representatives of Aquilant Advisors who direct clients to the WealthPort Wrap Program provide customized portfolio management solutions based on a client’s individual circumstances, risk tolerance, investment objectives, and time horizon on a discretionary basis. Aquilant Advisors investment advisory representative will meet with the client at least annually to review personal circumstances and investment objectives and adjust the portfolio’s asset allocation as needed. Financial Planning & Consulting Services Aquilant Advisors offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. Financial planning services are offered by Aquilant Advisors on an ‘a la carte’ basis depending on the client requests. However, if clients want Aquilant Advisors to prepare a comprehensive plan and/or assess their investment objectives and risk profile through a detailed questionnaire and/or interview process to determine the suitability of investment in a particular model(s) Aquilant Advisors will offer the financial planning service against a separate fee. Aquilant Advisors provides full written financial plans, which typically address the following topics: Investment Planning, Retirement Planning, Tax Planning, Portfolios Review, and Asset Allocation. Investment Planning – Aquilant Advisors prepares an Investment Policy Statement (IPS) with detailed review of client’s overall investment objective, return requirements, risk tolerance, time horizon, liquidity needs, tax preference and unique circumstances. The IPS outlines the investment philosophy, asset Aquilant Advisors Page 7 Form ADV Part 2A Disclosure Brochure allocation plan, investment selection criteria and monitoring procedures. The IPS is normally updated on a yearly basis unless there is a change in client’s personal circumstance which would require an interim update. Investment planning can take anywhere between six to forty hours depending upon the client’s profile and circumstances Retirement Planning – Aquilant Advisors determines retirement income goals and gathers information about potential sources of retirement. Aquilant Advisors creates a unified and comprehensive retirement plan covering assets, income, taxation, inheritance and risk management. A long-term asset management plan is structured considering economic environment and inflationary conditions, tax minimization strategy, uncertainty and market volatility. Retirement planning services include research, financial modeling and mathematical simulation to identify adequacy of client’s investment to attain retirement readiness, and to clarify strategic choices and actions. Retirement planning can take anywhere between twenty to fifty hours depending upon the client’s profile and circumstances. Tax Planning – Aquilant Advisors works with third party tax / accounting advisor(s) to align financial goals with tax efficiency planning. Tax planning would encompass many different aspects e.g. selection of investment options and types of retirement plans, timing of income and capital growth as well as tax lot selection for investment transactions within client’s portfolio. Tax planning services would include recommendations on tax reduction strategies based on income, expenses, individual needs and goals. Clients can also choose to use their existing tax / accounting advisor(s). The fee arrangement with an outside professional is described in the section ‘Other Fee Terms for Financial Planning, Institutional Advisory & Consulting Services’. Tax planning can take anywhere between fifteen to forty hours depending upon the client’s profile and circumstances. Portfolio Review and Asset Allocation – Aquilant Advisors researches clients’ existing portfolios and underlying investments to determine the asset class mix, return profile and risk characteristics. Aquilant Advisors also determines broad asset allocation objectives based on the Investment Policy Statement (IPS). An Efficient Frontier is constructed to develop an optimized portfolio based on the constraints indicated in the IPS, and underlying investments (e.g. stocks, bonds, ETFs, mutual funds) are selected using quantitative screens and qualitative review. Aquilant Advisors also analyzes return, risk and modern portfolio statistics and runs mathematical simulation, wherever necessary, to identify the adequacy of the portfolio against client’s investment objectives and risk tolerance. Portfolio Review and asset allocation can take anywhere between twenty to sixty hours depending upon the client’s profile and circumstances. When providing financial planning and consulting services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. Written financial plans prepared by us do not include specific recommendations of individual securities. We also offer consultations in order to discuss financial planning issues when you do not need a written financial plan. We offer a one-time consultation, which covers mutually agreed upon areas of concern related to investments or financial planning. We also offer “as-needed” consultations, which are limited to consultations in response to a particular investment or financial planning issue raised or request made by you. Under an “as-needed” consultation, it will be incumbent upon you to identify those particular issues for which you are seeking our advice or consultation on. Our financial planning and consulting services do not involve implementing any transaction on your behalf or the active and ongoing monitoring or management of your investments or accounts. You have the sole Aquilant Advisors Page 8 Form ADV Part 2A Disclosure Brochure responsibility for determining whether to implement our financial planning and consulting recommendations. To the extent that you would like to implement any of our investment recommendations through Aquilant Advisors or retain Aquilant Advisors to actively monitor and manage your investments, you must execute a separate written agreement with Aquilant Advisors for our asset management services. Retirement Plan Services - Aquilant Advisors offers retirement plan services to retirement plan sponsors and to individual participants in retirement plans. For a corporate sponsor of a retirement plan, our retirement plan services can include, but are not limited to, the following services: Fiduciary Consulting Services Aquilant Advisors provides the following Fiduciary Retirement Plan Consulting Services:
• Investment Policy Statement Preparation. Aquilant Advisors will help you develop an investment policy statement. The investment policy statement establishes the investment policies and objectives for the Plan. You will have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement.
• Non-Discretionary Investment Advice. Aquilant Advisors will provide you with general, non- discretionary investment advice regarding assets classes and investment options, consistent with your Plan’s investment policy statement.
• Investment Selection Services. Aquilant Advisors will provide you with recommendations of investment options consistent with ERISA section 404(c).
• Investment Due Diligence Review. Aquilant Advisors will provide you with periodic due diligence reviews of the Plan’s reports, investment options and recommendations.
• Investment Monitoring. Aquilant Advisors will assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformation to the guidelines set forth in the investment policy statement and Aquilant Advisors will make recommendations to maintain or remove and replace investment options.
• Default Investment Alternative Advice. Aquilant Advisors will provide you with non-discretionary investment advice to assist you with the development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. You will retain the sole responsibility to provide all notices to participants required

under ERISA section 404(c)(5).
• Individualized Participant Advice. Upon request, Aquilant Advisors will provide one-on-one advice to Plan participants regarding their individual situations. For Fiduciary Consulting Services, all recommendations of investment options and portfolios will be submitted to you for your ultimate approval or rejection. For retirement plan Fiduciary Consulting Services, the retirement plan sponsor client or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. Aquilant Advisors Page 9 Form ADV Part 2A Disclosure Brochure Fiduciary Consulting Services are not management services, and Aquilant Advisors does not serve as administrator or trustee of the plan. Aquilant Advisors does not act as custodian for any client account or have access to client funds or securities (with the exception of, some accounts, having written authorization from the client to deduct our fees). Aquilant Advisors acknowledges that in performing the Fiduciary Consulting Services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Aquilant Advisors will act in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Aquilant Advisors to be a fiduciary as a matter of law. However, in providing the Fiduciary Consulting Services, Aquilant Advisors (a) has no responsibility and will not (i) exercise any discretionary authority or discretionary control respecting management of Client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of Client’s retirement plan, or (iii) have any discretionary authority or discretionary responsibility in the administration of Client’s retirement plan or the interpretation of Client’s retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets, and (c) is not the “Administrator” of Client’s retirement plan as defined in ERISA. Fiduciary Management Services Aquilant Advisors provides clients with the following Fiduciary Retirement Plan Management Services:
• Discretionary Management Services. Aquilant Advisors will provide you with continuous and ongoing supervision over the designated retirement plan assets. Aquilant Advisors will actively monitor the designated retirement plan assets and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Plan. We have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with you. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets.
• Discretionary Investment Selection Services. Aquilant Advisors will monitor the investment options of the Plan and add or remove investment options for the Plan. Aquilant Advisors will have discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants. If you elect to utilize any of Aquilant Advisors’s Fiduciary Management Services, then Aquilant Advisors will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to our Fiduciary Management Services, and Aquilant Advisors hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. Non-Fiduciary Services Although an investment adviser is considered a fiduciary under the Investment Advisers Act of 1940 and required to meet the fiduciary duties as defined by the Advisers Act, the services listed here as non- Aquilant Advisors Page 10 Form ADV Part 2A Disclosure Brochure fiduciary should not be considered fiduciary services for the purposes of ERISA since Advisor is not acting as a fiduciary to the Plan as the term “fiduciary” is defined in Section 3(21)(A)(ii) of ERISA. The exact suite of services provided to a client will be listed and detailed in the Qualified Retirement Plan Agreement. Aquilant Advisors provides clients with the following Non-Fiduciary Retirement Plan Consulting Services:
• Participant Education. Aquilant Advisors will provide education services to Plan participants about general investment principles and the investment alternatives available under the Plan. Aquilant Advisors’s assistance in participant investment education will be consistent with and within the scope of DOL Interpretive Bulletin 96-1. Education presentations will not take into account the individual circumstances of each participant and individual recommendations will not be provided unless otherwise agreed upon. Plan participants are responsible for implementing transactions in their own accounts.
• Participant Enrollment. Aquilant Advisors will assist you with group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees.
• Qualified Plan Development. Aquilant Advisors will assist you with the establishment of a qualified plan by working with you and a selected Third Party Administrator. If you have not already selected a Third Party Administrator, we shall assist you with the review and selection of a Third Party Administrator for the Plan.
• Due Diligence Review. Aquilant Advisors will provide you with periodic due diligence reviews of your Plan’s fees and expenses and your Plan’s service providers.
• Fiduciary File Set-up. Aquilant Advisors will help you establish a “fiduciary file” for the Plan which contains trust documents, custodial/brokerage statements, investment performance reports, services agreements with investment management vendors, the investment policy statement, investment committee minutes, asset allocation/asset liability studies, due diligence fields on funds/money managers and monitoring procedures for funds and/or money managers.
• Benchmarking. Aquilant Advisors will provide you benchmarking services and will provide analysis concerning the operations of the Plan. Securities and other types of investments all bear different types and levels of risk. Those risks are typically discussed with clients in defining the investment policies and objectives that will guide investment decisions for their qualified plan accounts. Upon request, as part of our retirement plan services, we can discuss those investments and investment strategies that we believe may tend to reduce these risks for a particular client’s circumstances and plan participants. Clients and plan participants must realize that obtaining higher rates of return on investments entails accepting higher levels of risk. Based upon discussions with the client, we will attempt to identify the balance of risks and rewards that is appropriate and comfortable for the client and other employees. It is still the clients’ responsibility to ask questions if the client does not fully understand the risks associated with any investment. All plan participants are strongly encouraged to read prospectuses, when applicable, and ask questions prior to investing. Aquilant Advisors Page 11 Form ADV Part 2A Disclosure Brochure We strive to render our best judgment for clients. Still, Aquilant Advisors cannot assure that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. Aquilant Advisors will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learn of such error or omission. Retirement Plan Rollover Recommendations - To the extent we recommend you roll over your account from a current retirement plan to an individual retirement account (“Rollover IRA”), managed by Aquilant Advisors please know that Aquilant Advisors and our investment adviser representatives have a conflict of interest. We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to a Rollover IRA managed by Aquilant Advisors. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to a Rollover IRA managed by Aquilant Advisors. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to a Rollover IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program 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 Aquilant Advisors receiving unreasonable compensation related to the rollover of funds from the retirement plan to a Rollover IRA, and (iii) fully disclose compensation received by Aquilant Advisors and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to a Rollover IRA and refrain from making any materially misleading statements regarding such rollover. Aquilant Advisors Page 12 Form ADV Part 2A Disclosure Brochure To the extent we provide you investment advice as a participant in a retirement plan regarding whether to maintain investments and/or proceeds in the retirement plan, roll over such investment/proceeds from the retirement plan to a Rollover IRA or make a distribution from the retirement plan, Aquilant Advisors here by acknowledges our fiduciary obligations to you with regard to our investment advice about whether to maintain, roll over or distribute proceeds from the retirement plan, and as such a fiduciary with respect to its investment advice to you about whether to maintain, roll over or distribute proceeds from the retirement plan. Our investment advisor representatives shall 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 Aquilant Advisors or our affiliated personnel. Variable Sub-Account Management Services - Under our sub-account management services, Aquilant Advisors manages your variable annuity or variable life contract by selecting, monitoring and exchanging as necessary between sub-accounts available from the insurance company issuing the variable annuity or variable life contract. Under this program, we assist you in completing a questionnaire which details your financial goals, risk tolerance and time horizon. You will have the opportunity to list on your investment advisory agreement with our firm any reasonable restrictions on the sub-accounts that may be utilized by Aquilant Advisors. You will be responsible for notifying us of any updates regarding your financial situation, risk tolerance or investment objective and whether you wish to impose or modify existing investment restrictions; however, we will contact you at least annually to discuss any changes or updates regarding your financial situation, risk tolerance or investment objectives. Once you have provided us with the necessary information and made the appropriate authorizations, Aquilant Advisors utilizes limited discretionary authority to select or exchange among the sub-accounts available under your variable annuity or variable life contract in accordance with your disclosed investment objective and risk tolerance. Aquilant Advisors may utilize signal providers for guidance regarding investment strategies, asset allocations and timing of exchanges. Aquilant Advisors will monitor your sub-accounts and exchange sub-accounts as necessary and in accordance with your investment objective and risk tolerance. Educational Seminars/Workshops Aquilant Advisors may occasionally provide seminars/workshops in areas such as financial planning, retirement planning, estate planning, college planning and charitable planning. Seminars/ workshops are always offered on an impersonal basis and do not focus on the individual needs of participants. Limits Advice to Certain Types of Investments Aquilant Advisors provides investment advice on the following types of investments:
• Exchange Traded Funds (ETFs)
• Mutual Funds Aquilant Advisors Page 13 Form ADV Part 2A Disclosure Brochure
• Exchange-listed Securities
• Securities Traded Over-the-Counter
• Foreign Issues
• Warrants
• Corporate Debt Securities
• Certificates of Deposit
• Municipal Securities
• Variable Annuities
• Variable Life Insurance
• US Government Securities
• Options Contracts on Securities Although we generally provide advice only on the products previously listed, we reserve the right to offer advice on any investment product that may be suitable for each client’s specific circumstances, needs, goals and objectives. It is not our typical investment strategy to attempt to time the market, but we may increase cash holdings modestly as deemed appropriate based on your risk tolerance and our expectations of market behavior. We may modify our investment strategy to accommodate special situations such as low basis stock, stock options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations. (Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.) Tailor Advisory Services to Individual Needs of Clients Aquilant Advisors’ advisory services are always provided based on your individual needs. This means, for example, that when we provide asset management services, you are given the ability to impose restrictions on the accounts we manage for you, including specific investment selections and sectors. We work with you on a one-on-one basis through interviews and questionnaires to determine your investment objectives and suitability information. We will not enter into an investment adviser relationship with a prospective client whose investment objectives may be considered incompatible with our investment philosophy or strategies or where the prospective client seeks to impose unduly restrictive investment guidelines. Client Assets Managed by Aquilant Advisors As of March 5, 2024, Aquilant Advisors has $182,226,086 in assets under management. $182,226,086 is managed on a discretionary basis and $0 is managed on a non-discretionary basis.