Our firm is dedicated to providing individuals and other types of clients with a wide array of
investment advisory services. Our firm is a limited liability company formed under the laws of the
State of Delaware in 2019 and has been in business as an investment adviser since that time. Our firm
is wholly owned by Aria Khalili.
The purpose of this Brochure is to disclose the conflicts of interest associated with the investment
transactions, compensation and any other matters related to investment decisions made by our firm
or its representatives.
As a fiduciary, it is our responsibility to provide fair and full disclosure of all material facts and to act
solely in the best interest of each of our clients at all times. Our fiduciary duty is the underlying principle
for our firm’s Code of Ethics—Item 11 of this Brochure—which includes procedures for personal
securities transactions and insider trading. Our firm requires all representatives to conduct business
with the highest level of ethical standards and to comply with all federal and state securities laws at all
times. Upon employment with our firm, and at least annually thereafter, all representatives of our firm
will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and
representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients.
Our firm has established a service-oriented advisory practice with open lines of communication for
many different types of clients to help meet their financial goals while remaining sensitive to risk
tolerance and time horizons. Working with clients to understand their investment objectives while
educating them about our process, facilitates the kind of working relationship we value.
Types of Advisory Services Offered
Financial Planning & Consulting:
Our firm provides a variety of standalone financial planning and consulting services to clients for the
management of financial resources based upon an analysis of current situation, goals, and objectives.
Financial planning services will typically involve preparing a financial plan or rendering a financial
consultation for clients based on the client’s financial goals and objectives. This planning or
consulting may encompass Investment Planning, Retirement Planning, Estate Planning, Charitable
Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study,
Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of
Credit Evaluation, or Business and Personal Financial Planning.
Written financial plans or financial consultations rendered to clients usually include general
recommendations for a course of activity or specific actions to be taken by the clients.
Implementation of the recommendations will be at the discretion of the client. As requested by our
clients our firm provides a written summary of the clients financial situation and our observations.
Financial consultations are not typically accompanied by a written summary as the process is less
formal than the planning service. Further, it is important to note that this service is not offered on a
standalone basis and is only available on a complimentary basis when requested by our Wrap Asset
Management Clients.
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Retirement Plan Consulting:
Our
firm provides retirement plan consulting services to employer plan sponsors on an ongoing
basis. Generally, such consulting services consist of assisting employer plan sponsors in managing
and monitoring their company's retirement plan assets. As the needs of the plan sponsor dictate,
areas of advising may include:
• Asset Allocation and Portfolio Construction – Our firm will develop strategic asset allocation
models to aid Participants in developing strategies to meet their investment objectives, time
horizon, financial situation and tolerance for risk.
• Investment Monitoring – Our firm will monitor the performance of the investments and
notify the client in the event of over/underperformance and in times of market volatility.
In providing services for retirement plan consulting, our firm does not provide any advisory services
with respect to the following types of assets: employer securities, real estate (excluding real estate
funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other
illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement
plan consulting services shall be in compliance with the applicable state laws regulating retirement
consulting services. This applies to client accounts that are retirement or other employee benefit
plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended
(“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide
services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section
3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to
the provision of services described therein.
Portfolio Monitoring:
Our Portfolio Monitoring Service provides for general asset allocation guidance within parameters of
a plan held with outside custodians. This service is solely consultative in nature and involves no on-
going supervision, trading, or discretion with respect to securities transactions. Clients are
responsible for placing and executing their own trades, either on their own or with another
investment adviser. We provide non-continuous and periodic outside account monitoring. Further, it is
important to note that this service is not offered on a standalone basis and is only available on a
complimentary basis when requested by our Wrap Asset Management Clients.
Tailoring of Advisory Services
Our firm only offers individualized investment advice to our Wrap Asset Management clients. Our
firm does not provide non-wrap services.
Our firm does not usually allow Wrap Asset Management clients to impose restrictions on investing
in certain securities or types of securities due to the level of difficulty this would entail in managing
their account. Exceptions will be made on a case-by-case basis.
Participation in Wrap Fee Programs
Our firm offers and sponsors a wrap fee program, as further described in Part 2A, Appendix 1 (the
“Wrap Fee Program Brochure”). Our firm does not offer advisory services on a non-wrap basis. All
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accounts are managed on an individualized basis according to the client’s investment objectives,
financial goals, risk tolerance, etc.
Regulatory Assets Under Management
As of December 31, 2022, our firm manages $105,398,000 on a discretionary basis.