General Description of Primary Advisory Services
A & I Financial Services, LLC, doing business as A & I Wealth Management (“A & I Wealth Management”
or “we”) is a registered investment adviser based in Lone Tree, CO. We are organized as a limited liability
company under the laws of the State of Colorado. We have been providing investment advisory services
since 2009. In 2018, A & I Financial Services LLC ownership structure changed from being owned directly
by Karl F. Frank and Stacey K. Frank to full ownership by A & I Holdings, LLC. Karl F. Frank and Stacey
K. Frank are our principal owners. Currently, we offer the following investment advisory services, which
are personalized to each individual client:
• Asset Management Services
• Use of Third Party Money Managers
• Financial Planning Services (Plans and Consultations)
• Retirement Plan Services
Asset Management Services
We offer investment supervisory services defined as giving continuous investment advice to you (or
making investments for you) based on your individual needs, goals and objectives. Through this service,
we offer a customized investment program providing you with advice regarding allocation among various
asset classes, ongoing assistance with evaluation and selection of investments, and adjustment and
balancing of portfolios. We meet with you to conduct a detailed financial analysis and assess your
financial situation, financial goals and risk tolerance. Based on this analysis, we select portfolio strategist
and investment managers. The portfolio strategist and investment managers may be representatives
associated with us, they may be sub-advisors who provide model portfolio recommendations, or they may
be registered with outside money managers with whom we have relationships. We manage multiple
model portfolios that utilize different asset mixes and trading strategies. A client account may participate
in several model portfolios or a single model portfolio. We continuously monitor and review each model
portfolio and implement block trades when we determine that investment changes are required.
Use of Third Party Money Managers
As part of our overall asset management strategy, we may also recommend third party money managers
or programs to manage all or a portion of your account. All third party money managers recommended by
our firm must either be registered as investment advisers or exempt from registration requirements. We
will periodically monitor the third party investment advisor’s performance to ensure its management and
investment style remains aligned with your investment goals and objectives.
After gathering information about your financial situation and objectives, we will recommend that you
engage a specific third-party money manager or investment program. Factors that we take into
consideration when making our recommendation(s) include, but are not limited to, the following: the
money manager’s performance, methods of analysis, fees, your financial needs, investment goals, risk
tolerance, and investment objectives.
Where we are appointed as your agent to buy and sell securities or other investments for your account on
a discretionary basis, you delegate to A & I Wealth Management the authority to retain one or more third
party investment advisor(s) to provide all, or a portion, of the discretionary management services with
respect to your account. We shall have the discretion to hire and fire any third party investment advisor.
To the extent you participate in a specific program offered by A& I Wealth Management that is provided
through a third party investment advisor or platform, the investments that are available to you through that
program may be limited to certain types of securities. You may not be able to impose investment
restrictions with respect to the securities and other assets that are purchased for, or held in, the account
by such third party investment advisor(s).
We may also act as solicitor and refer you to unaffiliated third-party investment advisors offering asset
management and other investment advisory services. We perform due diligence in selecting the third-
party money managers. Each solicitation arrangement is performed pursuant to a written solicitation
agreement and is in compliance with SEC Rule 206(4)-3 and applicable state securities rules and
regulations.
In some cases, you may be required to sign an agreement directly with the third party investment
advisor(s). In which case, you may terminate your advisory relationship with the third investment
advisor(s) according to the terms of your agreement with the third party investment advisor(s). You should
review each third party investment advisor’s brochure for specific information on how you may terminate
your advisory relationship with the third party investment advisor and how you may receive a refund, if
applicable. You should contact the third party investment adviser directly for questions regarding your
agreement with the third party investment adviser. Our representatives are available to answer questions
regarding your account. Our representatives also act as the communication conduit between you and the
third-party investment advisors.
Third party managed programs generally have account minimum requirements and these minimum
requirements vary from investment advisor to investment advisor. Account minimums are generally
higher on fixed income accounts than equity-based accounts. A complete description of the third-party
investment advisor’s services, fee schedules and account minimums are disclosed in the third-party
investment advisor’s Disclosure Brochure that is provided to clients at the time an agreement for services
is executed and an account established. The type and frequency of reports provided to clients will also
depend upon the third-party investment advisor selected.
Third-party investment advisors may take discretionary authority to determine the securities to be
purchased and sold for the client. In some instances, we may be considered a sub-advisor because we
are responsible for the initial and on-going suitability review and are also responsible for maintaining your
current information. The third-party investment advisor may also use other sub-advisors in providing
management and other advisory services to your accounts.
Recommendation of Variable Annuities
We offer discretionary asset management of variable annuity portfolios through Nationwide Advisory
Solutions. The Nationwide platform gives us access to a large range of investment strategies and
securities. Investments are determined by the investment adviser representative managing the account
and in accordance with the client’s investment objectives. Variable annuities managed through the
Nationwide Advisory Solutions platform are fee based and do not incur commission charges. For its
services as custodian, Nationwide Advisory Solutions charges a flat monthly insurance charge of $20
without regard to the size of account. Specifics regarding the annuities are found in the annuities’
prospectuses and application documents.
Financial Planning Services (Plans and Consultations)
A & I Wealth Management offers financial planning services that focus on your specific needs and
concerns. The services may be comprehensive in nature (focusing on your overall financial situation, risk,
goals, and objectives) or they may be modular in nature (focusing on specific areas of concern that you
have.) Financial planning services may include giving advice on investment and non-investment related
matters. For example, we also conduct business exit strategy planning on a stand-alone basis.
Additionally, we offer consulting services in regard to your specific needs and concerns and this can
include both investment and non-investment matters. Consultations can also include specialized
business exit planning services. Consultation services can be contracted on a case-by-case basis
(limited) or on an on-going basis. You have sole discretion whether or not to implement any
recommendation from us. It is your responsibility to notify us if there are any changes in your financial
situation or investment objectives that could affect the advice provided by us.
We collect a variety of information from you that
is necessary to perform the requested services. We
gather the information to review your current financial condition, assist you in determining your attitude
toward risk and identify your financial goals, objectives and challenges. Financial data that we gather and
review may include statements and account data from banks, broker/dealers and mutual funds, as well as
tax returns and insurance policies. Depending on the level and scope of the financial planning
engagement, we may also review wills and trusts. We rely on the information provided by you. Therefore,
it is important the information you provide is complete and accurate. Neither we nor our investment
advisor representatives (“representatives”) are responsible for verifying the information you provide. In
addition, if authorized by you, we will gather information or documentation from your other professionals
and are expressly authorized to rely on the information provided. We urge you to work closely with your
attorney, accountant or other professionals regarding your financial and personal situation.
We meet with you to discuss our recommendations and outline steps you must take to implement those
recommendations. Although financial planning services are provided with the intention that you will
implement the recommendations contained in the plan, you are not obligated to do so. You retain
discretion over implementing decisions relating to financial planning services and are free to accept or
reject any recommendation from us. It is your responsibility to notify us of any changes in your financial
situation or investment objectives. You should notify us of any changes so that we can work with you to
determine if the changes will affect the advice provided by us. Together, we will determine if you wish to
engage us to review, evaluate and revise previous recommendations.
Retirement Plan Services
A & I Wealth Management offers retirement plan services to retirement plan sponsors and to individual
participants in retirement plans. Our services can include, but are not limited to, the following:
• Preparation of Investment Policy Statement. An Investment Policy Statement (“IPS”) is a
document drafted for the purpose of determining an investment philosophy for the retirement plan
investment program which may exceed the tenure of the various individuals charged with
managing it. The IAR assists The Plan in the preparation and implementation of a suitable IPS.
• Non-Discretionary Investment Advice. Advisor provides non-discretionary investment advice
regarding assets classes and investment options, consistent with the plan’s investment policy
statement.
• Default Investment Alternative Advice. We provide non-discretionary investment advice to assist
with development of qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg.
Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the plan or who
otherwise fail to make an investment election. The Plan Sponsor retains the sole responsibility to
provide all notices to participants required under ERISA Section 404(c)(5).
• Investment Recommendations. IAR recommends, for selection by the Plan, an array of
investments to be offered under the Plan consistent with the policies outlined in the IPS.
• Investment Monitoring. IAR monitors the plan investments and determine their suitability pursuant
to the criteria set forth in the IPS. When appropriate, IAR will recommend, for selection by the
Plan, suitable replacement investments.
• Performance Reports. IAR prepares and presents reports evaluating the performance of plan
investments pursuant to the criteria set forth in the IPS.
• Participant Enrollment and Education. IAR conducts retirement plan investment education
seminars and individual (one-on-one) meetings with participants for the purpose of providing
them with the opportunity to take full advantage of the benefits provided by the retirement plan.
A & I Wealth Management acknowledges that in performing the services it is acting as a limited scope
“fiduciary” as defined under Section 3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974
(“ERISA”) for purposes of providing non-discretionary investment advice only. A & I Wealth Management
acts in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and
circumstances, such services cause A & I Wealth Management to be a fiduciary as a matter of law.
However, in providing the fiduciary consulting services, A & I Wealth Management (a) has no
responsibility and does not (i) exercise any discretionary authority or discretionary control respecting
management of the client’s retirement plan, (ii) exercise any authority or control respecting management
or disposition of assets of the client’s retirement plan or (iii) have any discretionary authority or
discretionary responsibility in the administration of the client’s retirement plan or the interpretation of
retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and
does not have the power to manage, acquire or dispose of any plan assets and (c) is not the
“Administrator” of the retirement plan as defined in ERISA.
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 interests ahead of yours.
All recommendations are submitted to the client for ultimate approval or rejection. It is the client’s
responsibility to evaluate the Advisor’s recommendations and make changes to the plan itself.
Limits Advice to Certain Types of Investments
We offer advice on equity securities, corporate, municipal and government debt securities, certificates of
deposit, investment company securities, options contracts on securities and interest in partnerships
investing in real estate, oil and gas interests, and others.
We also advise on certain investment products such as variable life insurance and annuity contracts, and
assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these
situations, we direct or recommend the allocation of Client assets among the various investment options
available with the product. Client assets are generally maintained at either the insurance company or the
custodian designated by the product’s provider.
Additionally, we may advise you on types of investments that we deem appropriate 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.
You may request that we refrain from investing in particular securities or certain types of securities. You
must provide these restrictions to our firm in writing.
Tailor Advisor Services to Individual Needs of Clients
We provide services based on your specific needs. You are given the ability to impose restrictions on
your accounts, including specific investment selections and sectors. However, we will not enter into an
investment advisor relationship with a client whose investment objectives may be considered
incompatible with our investment philosophy or strategies or where the prospective client seeks to impose
unduly restrictive investment guidelines.
Wrap-Fee Program versus Portfolio Management Program
In traditional management programs, advisory services are provided for a fee but transaction services are
billed separately on a per-transaction basis. In wrap-fee programs, advisory services and transaction
services are provided for one fee. We do not act as a portfolio manager of or sponsor wrap fee
programs.
Client Assets Managed by Advisor
As of December 31, 2023, we manage $369,416,647 in client assets on a discretionary basis, and non-
discretionary assets under management of approximately $42,679,215.