Overview Severin Investments LLC (SI) is a Missouri limited liability company. We have been in business since September 2013 and are principally owned by Jeffrey J Severin, President. Advisory Services SI provides the following services to our advisory Clients: 1. Portfolio Management Services (with investment discretionary authority) 2. Institutional Retirement Services 3. Consulting, Monitoring and Advice for Clients’ 401k Retirement Assets 4. Financial Planning Services (Comprehensive or Limited /Consulting) 5. Estate Planning Services Investment advice is provided to Clients through our investment professionals who are licensed in various states, as required, as investment adviser representatives (IARs) of SI. 1. Portfolio Management Services Sub-advisory Services We provide portfolio management services to broker-dealers, investment advisers and portfolio managers under contractual agreements. As such, we implement our proprietary investment models for their clients for a fee. This includes trading in the client accounts when we make changes in the models. We educate advisors on the risk and investment objectives within each model so they can accurately advise each client. It is the advisor’s responsibility to choose an appropriate model for his/her client, and our responsibility is to manage the model according to the investment objectives we have outlined. If we make changes to the investment objectives of a model, we will inform the advisor beforehand to allow adequate time to take appropriate action with his/her clients. Overlay Managers and TAMPs We provide model management services to certain overlay managers and turnkey asset management platforms (TAMPs) under contractual agreements. As such, we upload and make changes to our proprietary investment models for an asset-based fee, which is debited directly from the investment account attached to the model and paid to Severin Investments by the overlay manager or TAMP provider. The overlay manager will directly make trades as directed by us for the advisors using our models. TAMPs allow advisors to approve and make the trades themselves. Under these contracts, Severin Investments has no discretion over individual accounts and is not responsible for determining suitability. The models available to advisors/investors depends on the contractual agreement we have with the overlay manager or TAMP. Portfolio Management for Individuals We meet with our prospective Clients (at no obligation), either in person or via telephone to determine whether our services described in this Brochure will meet your needs and expectations. It is our goal to understand who you are and your investment needs. If our services and your needs align, we will enter into a Portfolio Management Agreement (PMA) with you, which describes the services, fees and related information that governs the portfolio management services described here. We then document the information gathered on you and your personal obligations. The result of this activity is a personal Investment Policy Statement (IPS). The IPS documents your:
• Personal information
• Investment goals
• Investment objectives
• Investment restrictions (if any)
• Risk tolerance
• Time horizon
• Other information This IPS is the key to our providing portfolio management services to you. The information you provide helps us match you with the appropriate investment model(s) for your risk tolerance and investment objectives. We actively manage our model portfolios according to the parameters we define for the model, rather than each client’s individual needs. Therefore, our investment adviser representatives match you with the appropriate model(s) by comparing the model’s risk and return characteristics with your risk tolerance and investment objectives. Information Regarding All Managed Accounts We maintain and monitor all Client accounts indirectly through our monitoring and management of the model portfolios. We manage different types of model portfolios to accommodate different account sizes and investment objectives. We typically invest accounts greater than $100,000 in models comprised of individual stocks, bonds, and exchange traded funds (ETFs) or mutual funds. These models generally hold 80–100 holdings, and smaller accounts may not receive proper asset allocation in such a model. Therefore, we typically invest accounts of less than $100,000 in our ETF/mutual fund models. Depending on the account custodian, fractional shares may be available to the client. In this case, we may also use the larger models that include individual stocks for these smaller accounts. Our model portfolios have varying return expectations and levels of risk. Therefore, our understanding of our models’ duration, asset allocation, and risk tolerance levels allows us to match your account to a model based on your needs. Your portfolio may be customized to reflect any reasonable restrictions you wish to have on the account. The procedure involving account restrictions is described below under “Restrictions”. Use of ETFs and Mutual Funds In our exclusively ETF/mutual fund models, we use the funds to implement tactical tilts and effect sector rotation strategies. We may also use ETFs or mutual funds to implement a tactical tilt in the larger stock, bond, and ETF models. The portfolio managers often supplement certain asset classes to which the model has less exposure with ETFs to manage the risk exposure in the particular asset class. For example, the model may contain several small-cap stocks supplemented with a diversified small-cap ETF. We often employ this strategy in the international and emerging markets equity asset classes. In international and emerging markets, using ETFs also allows us to avoid the additional expense and risk associated with trading on overseas exchanges. We often use ETFs or mutual funds rather than individual bonds for fixed income allocations. This allows us to implement sector swaps and adjust positions to capitalize on fast-moving markets in a much more efficient manner than trading in smaller blocks of bonds. Even so, we reserve the right to purchase individual bonds in the larger stock, bond, and ETF models. ETFs and mutual funds also provide us the ability to gain exposure to commodities and alternative asset classes, including real estate (typically through real estate investment trusts (REITS) which are traded on national exchanges and provide immediate liquidity). When using mutual funds, we use only no-load or load-waived mutual funds in managed accounts. However, we rarely use mutual funds. We prefer to use ETFs because they trade like stocks throughout the day rather than only at the end of the day. They also tend to have much lower and more transparent internal fees, which is something we consider important when choosing a mutual fund or ETF. Investment Discretion We provide portfolio management services on an investment discretionary basis only for our private clients and any individual with whom we have a sub-advisory agreement. Please see Item 16 for more information. The investment discretionary authority we have (through a limited power of attorney) is defined in the written PMA we have with you. Investment discretion means we have the authority to determine the securities to purchase, sell or hold for your account; the amount of the securities to purchase, sell or hold; and the timing of these transactions without discussing the transactions with you in advance. Clients may impose reasonable restrictions on our discretionary portfolio management services. Restrictions SI reviews client requests for investment restrictions (no sin, tobacco, etc. or tax harvesting) to determine whether they are reasonable before implementing them. If we believe initial or revised restrictions are too broad or extensive, we may refuse to open a new account or terminate an existing account that could not be properly diversified given the restriction. We will certainly work with Clients who have personal and specific restrictions to determine if we can accept those restrictions in a manner consistent with our fiduciary obligations and any contractual provisions. Investment restrictions must be provided in writing and accepted by SI to be implemented. The client must also sign an attestation stating they understand their restrictions may change the risk profile of their portfolio and the account’s investment performance. We typically document Client imposed restrictions on the IPS. Requests for updates to restrictions may be submitted in writing as well. Changes are not implemented until received and accepted by SI, typically by mutual agreement and as documented in the IPS. Updates to your personal information We request that you provide notification to SI as soon as possible when there is a material change to your financial situation or investment / risk profile that may have an impact on the services provided. These can include: death, marriage, inheritance, birth of a child, divorce, new job, loss of job, new home, accident, medical emergency, etc. Retirement Rollovers-Potential for Conflict of Interest When SI provides investment advice to Clients regarding ERISA retirement accounts or Individual Retirement Accounts (IRAs), SI is a fiduciary within the meaning of Title I of ERISA. When deemed to be in the Client’s best interest, SI will provide investment advice regarding distributions or rollovers from such accounts. A client or prospective client leaving an employer typically has four options for an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an IRA, or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Adviser recommends that a client roll over their retirement plan assets into an account to be managed by Adviser, such a recommendation creates a conflict of interest if Adviser will earn an advisory fee on the rolled over assets. No client is under any obligation to rollover retirement plan assets to an account managed by Adviser. Adviser’s Chief Compliance Officer remains available to address any questions that a client or prospective client may have regarding the potential for conflict of interest presented by such rollover recommendation. Services to Accounts Greater Than $100,000 (or accounts custodied at Goldman Sachs Custody Solutions) Our preference is to manage accounts that exceed $100,000 on an active basis through the utilization of individual stocks and / or bonds, supplemented with mutual funds or ETFs as may be necessary or appropriate. Accounts custodied at Goldman Sachs Custody Solutions (GSCS) may also be managed using these models, as GSCS aggregates accounts, allowing individuals to own fractional shares. For these Client relationships, we manage several model portfolios which guide our investment advice provided to each Client. Each model includes a mix of the following asset classes:
• Domestic equity, including Real Estate Investment Trusts (REITs)
• Fixed income securities
• American Depositary Receipts (shares of foreign issuers registered and traded on US exchanges)
• Commodity ETFs
• Emerging market and international ETFs Stock and bond driven Investment Portfolios for accounts greater than $100,000 include:
• SI Current Equity Income
• SI Conservative Growth
• SI Moderate Growth
• SI Moderate Growth & Income
• SI Long Term Growth
• SI Relative Strength In some circumstances, we may instead determine that one of our ETF portfolios is appropriate. These portfolios are:
• SI ETF Conservative Growth
• SI ETF Moderate Growth
• SI ETF Long Term Growth
• SI Conservative Income Services to Accounts Under $100,000 For accounts under $100,000, we will manage your account assets on an active basis; however, the portfolio holdings are limited to ETFs or mutual funds only. We manage four different portfolios under our ETF asset allocation program. These models include the following:
• SI ETF Conservative Growth
• SI ETF Moderate Growth
• SI ETF Long-Term Growth
• SI Conservative Income ETFs included in these various models can include:
• Equity (domestic and foreign exposure)
• Cash alternatives
• Fixed income (domestic and foreign exposure)
• REITs
• Commodities Descriptions of Severin Investments Model Portfolios
• SI Conservative Income: This model uses ETFs and mutual funds to obtain a conservative capital preservation and income strategy. The portfolio consists of a small amount of equity and commodities. It invests primarily in investment-grade corporate bonds, government bonds and agency bonds guaranteed by the U.S. Government, its agencies or instrumentalities. Although the strategy allows for equity exposure ranging between 10%–40%, the typical allocation is 15%. A typical portfolio will hold at least 10 securities diversified across various sectors and maturities and, generally, no single corporate position will be more than 5% of the portfolio total value. The portfolio managers will vary the portfolio’s duration based on their interest rate outlook. If they anticipate that interest rates will rise, they will shorten the average maturity to attempt to protect capital. However, if they anticipate declining rates, they will lengthen the portfolio’s duration to attempt to obtain higher rates to capture price appreciation. The investment team, utilizing a top-down approach, assesses macroeconomic data and trends to formulate an interest rate strategy. This portfolio is available to all account sizes within our managed program.
• SI Moderate Growth and Income: This model invests in U.S, international, emerging market equities, fixed income, and commodities with the goal of providing long-term capital growth and steady income from a well-diversified strategy. There is no restriction on the market capitalization of the companies held. The strategy allows for equity exposure ranging between 45%–60%, and fixed

income exposure between 40%–50%. The model allocation may change significantly, as the portfolio managers implement tactical tilts and sector rotation to attempt to capitalize on economic and market changes. We primarily use individual stocks for equity positions and ETFs for fixed income positions. The minimum account size is $100,000 unless fractional shares are available.
• SI Current Equity Income: This model is designed for investors seeking equity income with potential long-term capital appreciation. It invests in dividend-paying stocks that we believe have moderate growth potential; sustainable dividends; a history of and projected dividend growth; and a collective current yield that is higher than the broad market average. There is no restriction on market capitalization of the companies held, however the model generally tilts toward large cap stocks. The model is fully invested in individual equities. The minimum account size is $100,000 unless fractional shares are available.
• SI Conservative Growth: This model invests in U.S, international, and emerging market equities, fixed income, and commodities with the goal of providing long-term capital growth from a well-diversified strategy. There is no restriction on the market capitalization of the companies held. Although the strategy allows for equity exposure ranging between 60%–85%, the typical allocation is between 70%–80%. The model allocation may change significantly, as the portfolio managers implement tactical tilts and sector rotation to attempt to capitalize on economic and market changes. We primarily use individual stocks for equity positions and ETFs for fixed income positions. The minimum account size is $100,000 unless fractional shares are available.
• SI ETF Conservative Growth: This model invests in U.S, international, and emerging market equities, fixed income, and commodities with the goal of providing long-term capital growth from a well-diversified strategy. There is no restriction on the market capitalization of the companies held. Although the strategy allows for equity exposure ranging between 60%–85%, the typical allocation is between 70%–80%. The model allocation may change significantly, as the portfolio managers implement tactical tilts and sector rotation to attempt to capitalize on economic and market changes. We primarily use ETFs but may also use mutual funds. It is available to all account sizes within our managed program.
• SI Moderate Growth: This model invests in U.S, international, and emerging market equities, fixed income, and commodities with the goal of providing long-term capital growth from a well-diversified strategy. There is no restriction on the market capitalization of the companies held. Although the strategy allows for equity exposure ranging between 60%–95%, the typical allocation is between 80%–90%. The model allocation may change significantly, as the portfolio managers implement tactical tilts and sector rotation to attempt to capitalize on economic and market changes. We primarily use individual stocks for equity positions and ETFs for fixed income positions. The minimum account size is $100,000 unless fractional shares are available.
• SI ETF Moderate Growth: This invests in U.S, international, and emerging market equities, fixed income, and commodities with the goal of providing long-term capital growth from a well-diversified strategy. There is no restriction on the market capitalization of the companies held. In times of increased market volatility, the model’s characteristics may change significantly. Although the strategy allows for equity exposure ranging between 60–95%, the typical allocation is between 80–90%. The model allocation may change significantly, as the portfolio managers implement tactical tilts and sector rotation to attempt to capitalize on economic and market changes. We primarily use ETFs but may also use mutual funds. It is available to all account sizes within our managed program.
• SI Long Term Growth: This model invests in U.S, international, and emerging market equities, fixed income, and commodities with the goal of providing long-term capital growth from a well-diversified strategy. There is no restriction on the market capitalization of the companies held. Although the strategy allows for equity exposure ranging between 70–100%, the typical allocation is between 90–100%. The model allocation may change significantly, as the portfolio managers implement tactical tilts and sector rotation to attempt to capitalize on economic and market changes. We primarily use individual stocks for equity positions and ETFs for fixed income positions. The minimum account size is $100,000 unless fractional shares are available.
• SI ETF Long Term Growth: This model invests in U.S, international, and emerging market equities, fixed income, and commodities with the goal of providing long-term capital growth from a well-diversified strategy. There is no restriction on the market capitalization of the companies held. Although the strategy allows for equity exposure ranging between 70–100%, the typical allocation is between 90–100%. The model allocation may change significantly, as the portfolio managers implement tactical tilts and sector rotation to attempt to capitalize on economic and market changes. We primarily use ETFs but may also use mutual funds. It is available to all account sizes within our managed program.
• SI Relative Strength: This is a rules-based model calculated by Standard & Poor’s Custom Indexes. The index is predicated upon the 14-Day Relative Strength Index. The Relative Strength Index is a momentum indicator that measures the magnitude of recent price changes to analyze overbought or oversold conditions. The index methodology selects 49 stocks derived from the Standard & Poor's 500 Index and which offer the most attractive 14-day relative strength index as of the first trading day of the month. This model has up to 100% turnover every month. The minimum account size is $50,000 unless fractional shares are available. Severin Investments Wrap Fee Program We sponsor the Severin Investments Wrap Fee Program (Wrap Fee Program). Only our investment advisor representatives can open accounts for clients through the Wrap Fee Program. Therefore, participants must be advisory clients of Severin Investments. All clients in the Wrap Fee Program must execute a Wrap Fee Program Portfolio Management Agreement before establishing an account. Participation in our Wrap Fee Program is not required of advisory clients, and there are no differences between the management styles of wrap fee accounts and non-wrap accounts. In fact, all our models are available in the Wrap Fee Program. The only difference between the two is the fees incurred by the account. Non-wrap accounts incur our management fee plus any trading charges the custodian imposes when we trade in the account. In contrast, our wrap fee covers all trading costs associated with trading securities. As the sponsor of the Wrap Fee Program, SI receives a portion of the wrap fee for our services. This section is intended as a summary of the Wrap Fee Program. Clients contracting for the Wrap Fee Program will receive the Severin Investments Wrap Fee Program Brochure which provides more detailed information. 2. Institutional Retirement Services We offer investment advisory services to fiduciaries of 401(k) plans. We provide our actively managed models that we match to the needs of each participant. We usually recommend our stock and ETF models for accounts that are at least $100,000, and our ETF-only models for accounts that are less than $100,000. If the custodian of the plan allows fractional shares, our account minimum for the stock and ETF models is reduced. Plan participants can consult with one of our investment adviser representatives for advice on which model(s) and/or ETFs are best suited for the participant’s needs and risk tolerance at no additional cost. Failure to consult with an investment adviser representative will result in the account’s allocation to SI Conservative Growth, SI Moderate Growth, or SI Long Term Growth depending on the participant's time horizon. Investment options include any of Severin Investments model portfolios or individual ETFs and mutual funds upon request. Please see “Descriptions of Severin Investments Model Portfolios” on page 8 for a full list of investment options. Because some types of investments involve additional risk, they will only be implemented/recommended when consistent with the responsibilities of a plan fiduciary as defined by the Department of Labor. 3. Consulting, Monitoring & Advice Services for 401k Retirement Assets Our individual clients may request us to provide our professional expertise in the management of their retirement assets in an employer’s defined contribution plan (usually a 401k). This is a stand-alone service, meaning we require Clients to enter into a separate agreement for this service. Consulting and Monitoring services are significantly different from our Portfolio Management Services. Under this consulting service, we provide asset allocation recommendations based upon:
• Securities available to participants within the defined contribution plan (as determined by the Plan’s Trustees or other fiduciary to the plan); and
• Your account value as determined by the custodian / administrator of your 401k account As a result, we provide asset allocation recommendations based solely on the 401k account assets you own. These assets are held by the custodian or administrator of your 401k Plan. Severin Investments has no investment discretionary authority over the management of these assets. SI will help you determine the most appropriate asset allocation of these 401k retirement assets. This may or may not include the development of an IPS. After entering into a Consulting and Monitoring agreement with you, we will initially and periodically (quarterly or yearly as determined necessary) make recommendations to your asset allocations across the available securities in your 401k plan. Although SI cannot place the transactions at your 401k broker / custodian, we can provide continuous monitoring services over the securities (and your asset allocation) within your 401k. To do so, we will rely on each Client to provide confirmation of transactions to us, which reflect your implementation of the asset allocation recommendations we provide to you. We may also request that SI be identified with your 401k provider as an “interested party” to receive duplicate confirmations of transactions and duplicate copies of your monthly / quarterly account statements. This will facilitate our monitoring services to determine if you were able to implement recommended transactions. You are not required to follow our asset allocation recommendations in your 401k, or you may implement some recommendations and disregard others. The goal of the service is to help our clients better align their employer sponsored retirement plans with their other accounts and their investment goals. 4. Financial Planning SI also provides advice in the form of a written (comprehensive) or limited (consulting) financial plan. Comprehensive Plans When providing Comprehensive Financial Planning services, we take a holistic approach for you and your family. The topics include, but are not limited to, the following:
• Goals and objectives
• Personal and family obligations
• Educational needs for children
• Retirement planning
• Tax management /planning
• Estates and estate plans; and
• Risk management (i.e., insurance protection) Through personal and in-depth interviews, we tabulate your personal data in third party financial planning software which utilizes various predictions / models to estimate and provide recommendations on courses of actions you should follow. This written plan is a roadmap for you to use as a guide to achieve your stated financial goals and objectives. Plans are “generic” in nature, so financial planning recommendations are not specific to any product or service offered by a broker-dealer or insurance company. As plan recommendations are generic in nature, you are also free to utilize any broker or insurance agency you choose to implement plan recommendations. We request that our Comprehensive Planning Clients meet with us at least annually to update the Plan, in part by assessing the success of the plan over the previous 12 months. In addition, a change in your personal circumstances should be communicated to us as soon as possible. These events can significantly impact Plan recommendations. Examples include:
• Marriage or divorce
• Birth of a child
• Death in the family
• New dependents (i.e., caring for elderly family members)
• Change or loss of jobs
• Medical conditions
• Inheritance
• Other Limited Planning Services From time-to-time, Clients may have a need for more limited / consultative planning services. To facilitate this type of financial planning, SI is available to provide investment advice in a more limited nature, which may include advice on any of the topics included in our Comprehensive Financial Planning service. 5. Estate Planning We offer Estate Planning services for our clients to assist with general information as it applies to reviews of existing plans, gathering information needed to provide outside firms in the creation of documents, and updating existing plans for clients. The fees associated with estate planning related services are separate and in addition to your ongoing financial planning or advisory fees and are disclosed in Item 5. Depending on the client's needs and desires for estate planning document review, preparation, or updates, we will engage with EncorEstate Plans, a third-party scrivener service, or estate planning attorneys. Though Tess Severin Butler, JD is an attorney, she does not provide any legal advice on estate planning documents or draft the documents. Assets Under Management: As of February 12, 2024, we manage $102,710,000 of client assets on a discretionary basis and $9,998,000 on a non-discretionary basis for a total of $112,690,000 in regulatory assets under management.