Ameraudi Asset Management, Inc. (herein after referred to as "Ameraudi", the "Company", "we", "us"
and "our") is an investment adviser formed in January, 1999 as a Delaware corporation. Ameraudi is
wholly owned by Interaudi Bank, a New York State chartered FDIC bank. George J. Audi is Ameraudi's
President and Marlon Orantes is Ameraudi's Chief Compliance Officer.
Our firm assists clients with navigating global financial markets. We provide a macro-perspective on
the prevailing economic environment and assist our clients with identifying suitable investment
strategies that address their unique investment needs.
Ameraudi offers discretionary/managed and non-discretionary/trading portfolio management services
to high net worth individuals. We may also recommend independent third-party money manager(s) to
manage client portfolios.
Discretionary/Managed Portfolios - The minimum amount for a managed model portfolio is $1,000,000.
For the managed discretionary portfolio, the adviser will work with the client to determine the
investment objectives, risk tolerance, asset allocation goals and time horizon. Clients have the right to
place reasonable restrictions.
Non-Discretionary/Trading Portfolios - The minimum amount for a trading portfolio is $1,000,000.
Ameraudi offers a full range of investment options on a non-discretionary basis and our investment
team has the ability to provide trade ideas and execution. Clients can evaluate specific trade ideas with
their financial advisers and may trade individual stocks, bonds, and funds with the assistance of our
team.
Third Party Managers - Ameraudi may recommend independent third party managers, when
appropriate, to manage all or a portion of a client's assets. Clients are responsible for executing
separate investment management agreements with the third party manager. The third party manager
manages the client assets on a discretionary basis and is responsible for the implementation of the
investment strategy. Although Ameraudi does not oversee the third party manager, we will monitor the
activity and performance of our client's accounts and at our discretion may terminate the relationship.
When recommending an independent manager for a client, Ameraudi reviews information about the
third party manager, such as their disclosure brochure and/or other material supplied by the third party
manager.
Ameraudi tailors advisory services to meet the individual need of the client. In order to determine the
appropriate investment strategy, we engage prospects in a pre-advisory consultation in which our
advisers will communicate with prospective clients in order to determine the investment objectives, risk
tolerance, asset allocation goals and time horizon. In addition to the pre-advisory consultation, we
require that the client or prospect themselves or with the assistance of an adviser, complete a risk
questionnaire in order to obtain a better analysis of the client's specific needs and investment goals.
We utilize this information to generate an Investment Policy Statement for the client to keep for their
records.
Clients may impose reasonable investment restrictions, including restrictions on particular securities or
types of investments, subject to our agreement. Ameraudi requires that any requests for investment
limitations or restrictions be made in writing. Clients should be aware that performance of restricted
portfolios may differ from performance of portfolios without such restrictions, which may affect overall
returns.
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Ameraudi reviews our client portfolios though an ongoing process of assessing client objectives,
developing an appropriate asset allocation to best achieve those objectives and modifying that
allocation when risk/opportunities are presented. Clients should notify Ameraudi if there are changes in
their financial situation or investment objectives.
Selection of Other Advisers
We may recommend that you use the services of a third party money manager ("TPMM") to manage
all, or a portion of, your investment
portfolio. After gathering information about your financial situation
and objectives, we may recommend that you engage a specific TPMM or investment program. Factors
that we take into consideration when making our recommendation(s) include, but are not limited to, the
following: the TPMM's performance, methods of analysis, fees, your financial needs, investment goals,
risk tolerance, and investment objectives. We will monitor the TPMM(s)' performance to ensure its
management and investment style remains aligned with your investment goals and objectives.
The TPMM(s) will actively manage your portfolio and will assume discretionary investment authority
over your account. We will assume discretionary authority to hire and fire TPMM(s) and/or reallocate
your assets to other TPMM(s) where we deem such action appropriate.
Sub-Advisory Services to Registered Investment Advisers
We offer sub-advisory services to unaffiliated third party money managers (the "Primary Investment
Adviser"). As part of these services, we will provide model portfolios, which the Primary Investment
Adviser selects for their clients. We manage on both a discretionary and non-discretionary basis. We
will not directly manage the Primary Investment Adviser's individual client accounts. The Primary
Investment Adviser will be responsible for selecting the appropriate model or investments for its clients.
Types of Investments
We primarily offer advice on ETFs. Refer to the Methods of Analysis, Investment Strategies and Risk
of Loss below for additional disclosures on this topic.
Additionally, we may advise you on various types of investments based on your stated goals and
objectives. We may also provide advice on any type of investment held in your portfolio at the inception
of our advisory relationship.
Since our investment strategies and advice are based on each client's specific financial situation, the
investment advice we provide to you may be different or conflicting with the advice we give to other
clients regarding the same security or investment.
IRA Rollover Recommendations
Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field
Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's
Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the
following acknowledgment to you. 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. The way we make money creates some conflicts with
your interests, so we operate under a special rule that requires us to act in your best interest and not
put our interest ahead of yours. Under this special rule's provisions, we must:
•Meet a professional standard of care when making investment recommendations (give prudent
advice);
•Never put our financial interests ahead of yours when making recommendations (give loyal
advice);
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•Avoid misleading statements about conflicts of interest, fees, and investments;
•Follow policies and procedures designed to ensure that we give advice that is in your best
interest;
•Charge no more than is reasonable for our services; and
•Give you basic information about conflicts of interest.
We benefit financially from the rollover of your assets from a retirement account to an account that we
manage or provide investment advice, because the assets increase our assets under management
and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in
your best interest.
As of January 31, 2024, Ameraudi managed regulatory assets under management of approximately
$1,440,282,033, of which $414,393,287 are assets managed on a discretionary basis and
$1,025,888,746 are non-discretionary assets.