Allied Investment Advisors, LLC is an investment advisor registered with the U.S. Securities and Exchange
Commission and is a Limited Liability Company formed under the laws of the State of Montana.
Gary Lucas is the Managing Member and majority owner of Allied Investment Advisors.
Bart Aby is a Member and part owner of Allied Investment Advisors.
Dan Kelly is a Member and a part owner of Allied Investment Advisors.
Eric Vermulm is a Member and part owner of Allied Investment Advisors.
Allied Investment Advisors has been registered as an investment advisor since December 2011.
Description of Advisory Services
Investment Management Services
Our firm specializes in providing portfolio management services which involve providing clients with on-
going supervision over client accounts. This means that we monitor a client’s account and make trades in
client accounts when necessary. Through this service, we implement a customized and individualized
investment program for clients by applying our investment strategy and philosophy. We actively manage
client investment portfolios in accordance with the client's individual needs, return objectives and risk
tolerance.
We will be granted trading authorization on the client’s account. Trading authority allows us the ability to
make trades in the client’s account. Such authorization may be provided on a discretionary or non-
discretionary basis depending on the individual needs and request of each client. Discretionary authority
provides the ability to make trades in the client’s account without contacting the client prior to each trade.
When non-discretionary trading authorization is granted, Allied Investment Advisors must get the client’s
approval prior to making any changes in the client’s account. Please refer to Item 16 of this brochure for
more details.
You are always responsible for notifying us of any changes to your financial situation or investment
objectives. At least annually, we will contact each client for the specific purpose to determine whether the
client’s financial situation or investment objectives have changed, or if the client would like to impose and/or
modify any reasonable restrictions on the management of their accounts. We are always reasonably
available to consult with clients relative to the status of their accounts. A client’s beneficial interest in a
security does not represent an undivided interest in all the securities held by the custodian, but rather
represents a direct and beneficial interest in the securities which comprise the accounts. A separate account
is always maintained for each client with the broker-dealer/custodian and the client retains all rights of
ownership to their accounts (e. g. right to withdraw securities or cash, exercise or delegate proxy voting,
and receive transaction confirmations).
It is important that you understand that we manage investments for other clients and may give them advice
or take actions for them or for our own personal accounts that is different from the advice we provide to you
or actions we take for you. We are not obligated to buy, sell or recommend to you any security or other
investment that we may buy, sell or recommend for any other clients or for our own accounts.
Conflicts may arise in the allocation of investment opportunities among accounts we manage. We strive to
allocate investment opportunities believed appropriate for your account(s) and other accounts advised by
our firm among such accounts equitably and consistent with the best interests of all accounts involved.
However, there can be no assurance that a particular investment opportunity that comes to our attention
will be allocated in any particular manner. If we obtain material, non-public information about a security or
its issuer that we may not lawfully use or disclose, we have absolutely no obligation to disclose the
information to any client or use it for any client’s benefit.
We provide investment management services through accounts maintained at Charles Schwab &
Company, Inc. (“Charles Schwab”) and in some situations, may manage accounts at a qualified custodian
selected by the client. Charles Schwab or the client selected qualified custodian (which may include a
broker-dealer, bank, or product sponsor) will maintain custody of all funds and securities. Please see Items
12 and 15 of this brochure for more details.
Financial Planning Services
Our firm offers financial planning services to our investment management clients. Through our relationship
with MoneyGuidePro, our firm is able to conduct an analysis of your current situation and identify
appropriate financial planning and investment management techniques to help you to meet your specific
financial objectives. Such services include various reports on specific goals and objectives or general
investment and/or planning recommendations, and periodic updates.
Newsletters
We publish a monthly newsletter providing general information on various financial topics including, but not
limited to, estate and retirement planning, and market trends. No specific investment recommendations are
provided in this newsletter and the information provided does not purport to meet the objectives or needs
of any individual. No advisory client is required to subscribe to any newsletters or periodicals. This
newsletter is distributed free of charge to our advisory clients, but our Firm may enter into an arrangement
with an unaffiliated firm to distribute our newsletter for a flat subscription fee.
Employer Sponsored Retirement Plan Services
For employer-sponsored retirement plans with participant-directed investments, Allied Investment Advisors
provides its advisory services as an investment advisor as defined under Section 3(21) and 3(38) of the
Employee Retirement Income Security Act of 1974, as amended (“ERISA”).
When serving as an ERISA 3(21) investment advisor, the plan sponsor and Allied Investment Advisors
share fiduciary responsibility. The plan sponsor retains ultimate decision-making authority for the
investments and may accept or reject the recommendations in accordance with the terms of a separate
ERISA 3(21) Investment Advisor Agreement between Allied Investment Advisors and the plan sponsor.
Allied Investment Advisors provides the following services to the plan sponsor:
Screen investments and make recommendations.
Monitor the investments and suggests replacement investments when appropriate.
Provide an investment monitoring report at least annually.
Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
Provide a comprehensive fiduciary investment review designed to meet Plan Sponsor fiduciary
responsibility and enhance the participant experience. This includes fiduciary education as
requested by the Department of Labor (DOL).
When serving as an ERISA 3(38) investment manager, the plan sponsor is relieved of fiduciary
responsibility for the investment decisions made by Allied Investment Advisors. Allied Investment Advisors
is a discretionary investment manager in accordance with the terms of a separate ERISA 3(38) Investment
Management Agreement between Allied Investment Advisors and the plan sponsor. Allied Investment
Advisors’ investment management is limited in that it has the discretion solely to replace funds in plan fund
lineups and initiate the transfer of existing balances to the replacements without prior approval from the
client.
Allied Investment Advisors provides the following services to the plan sponsor:
• Select the investments.
• Monitor the investments, replace the investments and asset allocations when appropriate.
• Provide an investment monitoring report at least annually.
• Assist the plan sponsor in developing an Investment Policy Statement (“IPS”).
• Provide a comprehensive fiduciary investment review designed to meet Plan Sponsor
fiduciary responsibility and enhance the participant experience. This includes fiduciary
education as requested by the Department of Labor (DOL).
Our goal in identifying the plan’s investment options is to provide a range of options that will enable plan
participants to invest according to varying risk tolerances, savings time horizons or other financial goals.
The plan's investment options may consist of ETFs, CITs, mutual funds, model portfolios, or other similar
investment funds. The investment funds
from which our Firm will select from will be those that are available
on the plan record-keeper’s investment platform.
We can also be engaged to provide Plan Consulting Services. Plan Consulting Services includes financial
education to plan participants, benchmarking the plan services, education to fiduciary committee members,
and monitoring the service provider. The scope of education provided to participants will not constitute
“investment advice” within the meaning of ERISA, and participant education will relate to general principles
for investing and information about the investment options currently in the plan. We may also participate in
initial enrollment meetings and periodic workshops.
We provide Plan Consulting Services separately or combined. Clients may choose to use any or all of these
services as indicated on the Investment Advisory Agreement with our Firm.
Participant Education
For pension, profit sharing and 401(k) plan clients in self-directed plans, we may provide periodic
educational support, electronic educational materials and investment workshops designed for the plan
participants, if provided for in our agreement with the client. Topics to be discussed will be determined in
conjunction with the plan sponsor and in accordance with guidelines established in ERISA Section 404(c).
The educational support and investment workshops will not provide plan participants with individualized,
tailored investment advice or individualized, tailored asset allocation recommendations.
SIMPLE IRA
A Savings Investment Match Plan for Employees (SIMPLE IRA) is a way to set up a retirement program for
self-employed individuals and small businesses with 100 or fewer employees. Eligible employees can fund
their own SIMPLE IRA accounts through regular salary deferrals and Employers make additional
contributions. Allied Investment Advisors provides the following services:
• Select the investments.
• Monitor the investments, replace the investments and asset allocations when appropriate.
• Provide an investment monitoring report at least annually.
Services may be offered through Schwab or another Retirement Plan Services provider.
Disclosure Regarding Rollover Recommendations
A client or prospect leaving an employer typically has four options regarding 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) rollover to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could,
depending upon the client’s age, result in adverse tax consequences). Our Firm may recommend an
investor roll over plan assets to an IRA for which our Firm provides investment advisory services. As a
result, our Firm and its representatives may earn an asset-based fee. In contrast, a recommendation that
a client or prospective client leave their plan assets with their previous employer or roll over the assets to a
plan sponsored by a new employer will generally result in no compensation to our Firm. Our Firm therefore
has an economic incentive to encourage a client to roll plan assets into an IRA that our Firm will manage,
which presents a conflict of interest. To mitigate the conflict of interest, there are various factors that our
Firm will consider before recommending a rollover, including but not limited to: (i) the investment options
available in the plan versus the investment options available in an IRA, (ii) fees and expenses in the plan
versus the fees and expenses in an IRA, (iii) the services and responsiveness of the plan’s investment
professionals versus those of our Firm, (iv) protection of assets from creditors and legal judgments, (v)
required minimum distributions and age considerations, and (vi) employer stock tax consequences, if any.
All rollover recommendations are reviewed by our Firm’s Chief Compliance Officer and remains available
to address any questions that a client or prospective client has regarding the oversight.
We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to
you regarding your retirement plan account or individual retirement account, we are also 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. We have to act in your best interest and not
put our interest ahead of yours. At the same time, the way we make money creates some conflicts with
your interests.
Model Portfolio Subscription services
Our Firm offers model portfolios on Black Diamond for independent financial institutions including
unaffiliated Registered Investment Advisors, banks, broker-dealers (“Financial Institutions”) to subscribe to.
This service will allow Independent RIAs access to our Firm’s models/positions. In this arrangement, our
Firm will not be given access to Independent RIAs client accounts. Our Firm does not enter direct
relationships with these clients. Instead, our Firm will send the investment recommendations to the
subscribing firms or Independent RIA. The Independent RIA Adviser(s) will be responsible for executing
the trades and determining what asset allocation is suitable for their clients. Financial Institutions maintain
their own custodial relationships and offer separate execution and clearing services. Our Firm provides
ongoing monitoring and supervision of the strategies and periodically recommends purchase and sale
transactions with respect to the management of the model investment strategies by adjusting positions.
Subscribing firms or Independent RIAs are also responsible for providing all administrative and performance
reporting services to their clients. On occasion, these models can hold slightly different funds than our direct
discretionary asset management accounts due to custodial relationship constraints that are outside of our
control.
Limits Advice to Certain Types of Investments.
Allied Investment Advisors provides investment advice on the following types of investments:
Exchange-listed equity securities (i.e. stocks)
Securities traded over-the-counter (i.e. stocks)
Foreign issues
Fixed income securities
Commercial paper
Corporate debt paper
Certificates of deposit
Municipal securities
Mutual Fund shares
Exchange Traded Funds (ETFs)
United States government securities
Allied Investment Advisors does not provide advice on warrants, variable life insurance, variable annuities,
options contracts on securities, options contracts on commodities, futures contracts on tangibles or
intangibles, interests in partnerships investing in real estate, oil, and gas interests, or hedge funds and other
types of private (i.e. non-registered) securities.
When constructing individual portfolio strategies for clients we may hold any of the securities listed above,
but we typically construct each client’s account holdings using individual equity securities, fixed income
securities, mutual funds cash and ETFs. All of which are considered asset allocation categories for the
client’s investment strategy. It is not our typical investment strategy to attempt to time the market. We
may modify our investment strategy to accommodate special situations such as low basis stock, stock
options, legacy holdings, inheritances, closely held businesses, collectibles, or special tax situations.
Please refer to Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss for more information.
Tailor Advisory Services to Individual Needs of Clients
Our services are always provided based on the individual needs of each client. This means, for example,
that you are given the ability to impose restrictions on the accounts we manage for you, including specific
investment selections and sectors. We work with each client on a one-on-one basis through interviews and
questionnaires to determine the client’s investment objectives, risk tolerance and suitability information.
Client Assets Managed by Allied Investment Advisors
As of December 31, 2022, Allied Investment Advisors has $721,339,559 of discretionary assets under
management and $12,991,207 of non-discretionary assets under management. Total regulatory assets
under management are $734,330,766 as of December 31, 2022.