Description of Services We are a registered investment adviser based in Louisville, Kentucky and Southern Indiana area. We are organized as a limited liability company under the laws of the State of Indiana. We are a fee-only independent adviser and have been providing investment advisory services since 2003. Brian Breidenbach is the sole owner. Currently, we offer the following services to clients and prospective clients:
•Institutional Services, which may include:
•Pension and Retirement Plan Consulting
•Foundation & Endowment Consulting
•Specialized Project Consulting
•Expert Witness Services
•Performance Reporting Services
•Wealth Management Services, which may include:
•Project based Financial Planning, Consulting, and Asset Allocation Services
•Portfolio Management The combination of industry experience and comprehensive research allows our firm to provide quality advisory services to our clients.
Please refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. Also, you may see the term Associated Person throughout this Brochure. As used in this Brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm.
Institutional Services Pension and Retirement Plan Consulting We offer pension and retirement plan consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary.
We may also assist with participant enrollment meetings and provide investment-related educational seminars to plan participants on such topics as:
•Diversification
•Asset allocation
•Risk tolerance
•Time horizon Our educational seminars may include other investment-related topics specific to the particular plan.
We may also provide additional types of pension consulting services to plans on an individually negotiated basis. 4 Other Institutional Services We offer other institutional services to clients which may encompass, but are not limited to, Foundation & Endowment Consulting, Specialized Project Consulting, Expert Witness Services and Performance Reporting Services. Details of the above institutional services are as follows:
•Foundation & Endowment Consulting - Includes investment policy development, asset allocation review/development, investment manager searches, spending rate policy analysis/development, and performance reporting.
•Specialized Project Consulting - Includes internal portfolio reviews, asset allocation review/development, investment policy review / development, investment manager review/searches and performance reporting. These services are typically bid upon by a client's RFP (request for proposal) bidding and the scope of these services are defined in an RFP that we would submit a response/bid on the RFP.
•Expert Witness - Support service to attorneys on behalf of their clients (plaintiff or defense). These services require specialized investment analysis/experience/expertise. Services typically result in a report for counsel or exhibit creation as well as testimony that can center around performance benchmarking as well as fraud detection.
•Performance Reporting - Performance analysis of an investment or portfolio of investments over a specific time period/range is conducted. Analysis can involve benchmarking and peer review. Wealth Management Services Financial Planning, Consulting Services and Asset Allocation Services We offer financial planning services to our clients and prospective clients. Financial planning will typically involve providing a variety of advisory services to clients regarding the management of their financial resources based upon an analysis of their individual needs. If you retain our firm for financial planning services, we will meet with you to gather information about your financial circumstances and objectives. Once we review and analyze the information you provide to our firm we will offer to help you achieve your stated financial goals and objectives.
Financial plans are based on your financial situation at the time we present the plan to you, and on the financial information you provide to our firm. You are encouraged to promptly notify our firm if your financial situation, goals, objectives, or needs change.
You are under no obligation to act on our financial planning recommendations.

Should you choose to act on any of our recommendations, you are not obligated to implement the financial plan through any of our other investment advisory services. Moreover, you may act on our recommendations by placing securities transactions with any brokerage firm.
Portfolio Management We offer discretionary and non-discretionary portfolio management services. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf.
As part of our portfolio management services, we may customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. We may also invest your assets using a predefined strategy, or we may invest your assets according to one or more model portfolios developed by our firm. Once we construct an investment portfolio for you, or select a model portfolio, we will monitor your portfolio's performance on an ongoing basis, and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances.
5 If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm, a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased for your account) by providing our firm with your restrictions and guidelines in writing. If you enter into non-discretionary arrangements with our firm, we must obtain your approval prior to executing any transactions on behalf of your account. Discretionary authority is not offered to Kentucky clients. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties.
IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. 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. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest.
Types of Investments We primarily offer advice on exchange traded funds (ETFs) and investment company securities (Mutual Funds). We may also offer advice on separate account managers and individual securities.
Additionally, we may advise you on any type of investment 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.
6 Assets Under Management As of June 30, 2023, we provide continuous management services for $47,937,883 in client assets on a non-discretionary basis.