Avrio was founded June 18, 2018, but did not start offering investment advisory until January 2, 2020. The majority shareholder of the company is Ann Marie Regal. Michael Borchert and Andrew Talbot also own a portion of the company. Please refer to the ADV Part 1 Schedule A for further ownership details via adviserinfo.sec.gov. The company has a Financial Advisor license issued by the Monetary Authority of Singapore. The company shall provide financial planning, insurance and investment advisory services to individuals, corporations, and institutions. Assets Under Management Avrio had $135,578,831 of Assets Under Management to report as of 12/31/2023. $67,845.890 is non-discretionary, $67,732.941 is discretionary. Assets Under Advisement As of 12/31/2023, Avrio had $116,681,951 of Assets Under Advisement. Avrio tailors our financial planning and investment advisory services to individual clients’ needs and objectives by having periodic personalized discussions among clients, their consultants and tax advisors, and the Financial Advisor at Avrio. This process generally begins with a comprehensive financial plan which includes a careful review of the client’s current financial position, future goals, cash flow requirements, tax status, suitability, and attitudes toward risk, liquidity, and volatility. Related documents supplied by the client are carefully reviewed. Clients may impose cash restrictions, asset allocation restrictions and restrict their portfolio to certain types of assets (i.e., public, or more liquid investments vs. private equity and physical assets). Avrio will manage advisory accounts on a discretionary or non-discretionary basis, depending on the client’s preference and assets. All Avrio clients have an Investment Policy Statement and an agreed upon asset allocation. Changes to a portfolio allocation must be confirmed in writing by the client. Individual portfolios may include but are not limited to: Exchange-traded Equity Securities, US State and Local Bonds, Investment Grade Corporate Bonds, Securities Issued by Pooled Investment Vehicles, alternatives such as private placements and real estate investments and cash/equivalents Avrio may review other asset types as warranted. Avrio shall provide recommendations according to the client's overall financial objectives on other asset types, such as alternative private investments and digital assets held by the client directly. Avrio does not have direct trading access to the clients' alternative private investments or digital assets. While we continuously monitor the securities in client accounts, each client account is reviewed at least quarterly and rebalanced, as necessary. If Avrio believes that a reallocation is necessary, or that a different investment is more appropriate for the client account, Avrio will suggest a different investment and will reinvest the client’s assets with the client’s approval. Account supervision is guided by the stated objectives and time horizon of the client (i.e., growth, growth and income, income). Avrio seeks to maintain

current client suitability information on file at all times. As such, the Firm requests that clients promptly notify us if there is any material change in their financial circumstances, risk tolerance, tax, or employment status. In addition, we will reach out to our clients periodically to remind them to inform us of any situation that would cause a change to their financial objectives. Avrio does not participate in wrap fee programs. We may have an inherent conflict of interest whenever we provide Financial Planning services to a client that also has retained our Investment Advisory services. The majority of Avrio’s clients are not invoiced using an Assets Under Management (AUM) fee schedule. For those clients who pay via an AUM fee schedule, it could be in our best interest not to recommend paying down debt that would directly reduce the Assets Under Management that we manage and charge a percentage fee or increases our overall Assets Under Management. We mitigate this conflict by providing an overall plan suitable and in the best interest of the client. Whenever we provide Financial Planning Services we shall: 1. Document the scope of work in an agreement. 2. Prepare a questionnaire to understand the client’s needs. 3. Conduct a reasonable level of due diligence when referring other professionals to the financial planning client. 4. Disclose all compensation methods we shall receive. 5. Conduct reasonable due diligence when recommending or using technologies when providing professional CFP® services to a client. 6. Periodically monitor the CFP Board’s Code of Ethics and Standard of Conduct. Whenever Avrio makes a recommendation for the Financial Planning client to utilize the services of a third-party professional as mentioned above, Avrio shall:
• Have a reasonable basis for the recommendation or Engagement based on the person’s reputation, experience, and qualifications.
• Disclose to the Client, at the time of the recommendation or prior to the Engagement, any arrangement by which someone who is not the Client will compensate or provide some other material economic benefit to the CFP® professional, the CFP® Professional’s firm, or a Related Party for the recommendation or Engagement; and
• When engaging a person to provide services for a Client, exercise reasonable care to protect the Client’s interests. When selecting or using and recommending technology Avrio shall document the due-diligence process which will include:
• Exercising reasonable care and judgment when selecting, using, or recommending any software, digital advice tool, or other technology while providing Professional Services to a Client.
• Having reasonable level of understanding of the assumptions and outcomes of the technology employed.
• Having reasonable basis for believing that the technology produces reliable, objective, and appropriate outcomes. The CFP® professionals of Avrio will also review the complete CFP Board Code of Ethics and Standards of Conduct and the Practice Standards to ensure proper implementation within the firm.