A. Firm Information
AlbanyAdvisor Group LLC (“AAG” or the “Advisor”) is a registered investment advisor with the U.S. Securities and
Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of
the State of New York. AAG was founded in September 2021 and is owned and operated by Marc A. Agel
(Founding Partner), Susan B. Hart (Founding Partner) and Lori G. Murphy (Founding Partner).
This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory
services provided by AAG. For information regarding this Disclosure Brochure, please contact Michael J. Carrillo
(Chief Compliance Officer) at (518) 689-3577.
B. Advisory Services Offered
AAG offers investment advisory services to individuals, high net worth individuals, trusts, estates, small businesses,
and retirement plans. (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. AAG's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Services
AAG provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing either discretionary or non-discretionary investment
management and related advisory services. AAG works closely with each Client to identify their investment goals
and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. AAG will then
construct an investment portfolio, consisting exchange-traded funds (“ETFs”), mutual funds, individual stocks,
and/or individual bonds to achieve the Client’s investment goals. The Advisor may also utilize other types of
investments, as appropriate, to meet the needs of the Client. The Advisor may retain certain types of investments
based on a Client’s legacy investments based on portfolio fit and/or tax considerations.
AAG’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. AAG will
construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
AAG evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence
process. AAG may recommend, on occasion, redistributing investment allocations to diversify the portfolio. AAG
may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend
employing cash positions as a possible hedge against market movement. AAG may recommend selling positions
for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure
to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change
in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the
Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
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to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Advisor.
At no time will AAG accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Financial Planning Services
AAG will typically provide a variety of financial planning and consulting services to Clients as part of the investment
management engagement or billed separately pursuant to a written financial planning agreement. Services are
offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such
financial planning services involve preparing a formal financial plan or rendering a specific financial consultation
based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas
of need, including but not limited to, investment planning, retirement planning, personal savings, education savings,
insurance needs, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
AAG may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation.
For certain financial planning engagements, the Advisor will provide a written summary of the Client’s financial
situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide
a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming
all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to
act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Advisory Services
AAG provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the
company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan
Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized
to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
These services are provided by AAG serving in the capacity as a fiduciary under the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is
provided with a written description of AAG’s fiduciary status, the specific services to be rendered and all direct and
indirect compensation the Advisor reasonably expects under the engagement.
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C. Client Account Management
Prior to engaging AAG to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – AAG, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
• Asset Allocation – AAG will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – AAG will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
• Investment Management and Supervision – AAG will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
AAG does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by AAG.
E. Assets Under Management
As December 2022, AAG manages $9,301,164 in discretionary assets and $163,384,181 in non-discretionary
assets. Total assets under management are $172,685,345. Clients may request more current information at any
time by contacting the Advisor.