A. Description of the Advisory Firm
Aperture Advisors LLC (hereinafter “AAL”) is a Limited Liability Company organized in
the State of Connecticut. The firm was formed in June 2023, and the principal owner is
Christian De Berardinis.
B. Types of Advisory Services
Portfolio Management Services
AAL offers ongoing portfolio management services based on the individual goals,
objectives, time horizon, and risk tolerance of each client. AAL creates an Investment
Policy Statement for each client, which outlines the client’s current situation (income, tax
levels, and risk tolerance levels). Portfolio management services include, but are not
limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring
AAL evaluates the current investments of each client with respect to their risk tolerance
levels and time horizon. AAL will request discretionary authority from clients in order to
select securities and execute transactions without permission from the client prior to each
transaction. Risk tolerance levels are documented in the Investment Policy Statement,
which is given to each client.
AAL seeks to provide that investment decisions are made in accordance with the fiduciary
duties owed to its accounts and without consideration of AAL’s economic, investment or
other financial interests. To meet its fiduciary obligations, AAL attempts to avoid, among
other things, investment or trading practices that systematically advantage or
disadvantage certain client portfolios, and accordingly, AAL’s policy is to seek fair and
equitable allocation of investment opportunities/transactions among its clients to avoid
favoring one client over another over time. It is AAL’s policy to allocate investment
opportunities and transactions it identifies as being appropriate and prudent, including
initial public offerings ("IPOs") and other investment opportunities that might have a
limited supply, among its clients on a fair and equitable basis over time.
Due Diligence and Monitoring of Alternative Investments
AAL offers initial and ongoing due diligence on alternative and private investments for
clients who qualify as accredited investors. AAL will collect and review available
information including any marketing materials, prospectuses, subscription agreements,
financial statements, audit reports, performance reports, and other investment-specific
information to evaluate whether the opportunity is in the best interest of the client. AAL
will attend calls and meetings with managers and sponsors of alternative and private
investments to ensure a thorough understanding of all aspects of the
information and
documents received. AAL also conducts an ongoing review of the alternative and private
investments and analyzes how these investments impact the client’s traditionally
managed portfolio.
Services Limited to Specific Types of Investments
AAL generally limits its investment advice to mutual funds, fixed income securities, real
estate funds (including REITs), insurance products including annuities, equities, ETFs
(including ETFs in the gold and precious metal sectors), treasury inflation
protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds
and private placements, although AAL primarily recommends equities and fixed income.
AAL may use other securities as well to help diversify a portfolio when applicable.
Written Acknowledgement of Fiduciary Status
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);
• 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.
C. Client Tailored Services and Client Imposed Restrictions
AAL offers the same suite of services to all of its clients. However, specific client
investment strategies and their implementation are dependent upon the client Investment
Policy Statement which outlines each client’s current situation (income, tax levels, and risk
tolerance levels). Clients may not impose restrictions in investing in certain securities or
types of securities in accordance with their values or beliefs.
D. Wrap Fee Programs
A wrap fee program is an investment program where the investor pays one stated fee that
includes management fees and transaction costs. AAL does not participate in wrap fee
programs.
E. Assets Under Management
AAL has the following assets under management:
Discretionary Amounts: Non-discretionary Amounts: Date Calculated:
$0 $0 December 2023