Effective Date · 23 April 2026
Last Revised · 23 April 2026
Document Version · 1.0
§ 01

Important Notice

This website is for informational purposes only. It does not constitute an offer to sell, a solicitation to buy, or a recommendation of any security or investment product. Nothing on this website should be construed as personalized investment advice.

The information on this website is intended for residents of jurisdictions where Arbor Portfolio Management, LLC (“Arbor,” “we,” or “the Firm”) is properly registered or exempt from registration. Arbor does not offer investment advisory services to persons in jurisdictions where we are not authorized to do so.

Investment advisory services are available only through a separately executed investment management agreement between the client and Arbor. Prospective clients should carefully review our Form ADV Part 2A (Disclosure Brochure) before entering into any advisory relationship.

§ 02

Regulatory Status

Arbor Portfolio Management, LLC is a limited liability company organized under the laws of the State of Georgia. The Firm is in the process of registering as an investment adviser with the Georgia Secretary of State, Securities Division, under the Georgia Uniform Securities Act of 2008.

Registration as an investment adviser does not imply a certain level of skill or training. Registration is a regulatory classification and does not constitute an endorsement of the Firm by any governmental authority.

Upon completion of registration, our Form ADV Parts 1, 2A, and 2B will be publicly available through the Investment Adviser Public Disclosure (IAPD) database at adviserinfo.sec.gov. Clients and prospective clients may request a copy of our current Form ADV at any time.

Pre-Registration Notice

Until registration is effective, Arbor is not offering investment advisory services and is not accepting client accounts. Inquiries received during this period will be retained for follow-up once the Firm is authorized to commence operations.

§ 03

Investment Advisory Services

Arbor provides discretionary investment management services to clients through separately managed accounts (“SMAs”). The Firm's primary strategy employs a systematic, rules-based framework that allocates capital among exchange-traded funds (ETFs) based on signals derived from credit and equity market data.

Scope of Services

For each client, Arbor will exercise discretionary trading authority over the assets in the client's designated investment account, held at a qualified custodian. Our services do not include:

  • Comprehensive financial planning, tax preparation, or estate planning
  • Insurance advisory services or insurance product recommendations
  • Investment advice on assets held outside the managed account
  • Recommendations regarding specific individual securities outside the strategy

Client Relationship

Clients retain full ownership of their assets at all times. Arbor has limited trading authority granted by written agreement but does not take custody of client funds or securities. Clients may deposit or withdraw funds from their accounts subject to the terms of their advisory agreement and the operational constraints of the systematic strategy.

§ 04

Performance Information

Hypothetical & Backtested Performance

Any performance figures referenced on this website, in research publications, in email communications, or in discussions with prospective clients are hypothetical and based on backtested simulation unless explicitly designated as “live” or “actual” results.

Hypothetical performance results have inherent limitations. Backtested results are generated with the benefit of hindsight; they do not represent actual trading and cannot account for all factors that would have affected real-world performance, including but not limited to execution costs, market impact, financing costs, operational friction, and the psychological challenges of adhering to a strategy through drawdowns.

Performance Disclosure Framework

All performance figures presented by Arbor are intended to comply with the SEC Investment Adviser Marketing Rule (Rule 206(4)-1 under the Investment Advisers Act of 1940) and analogous state regulations. When performance is referenced, the following standards apply:

  • Hypothetical performance is presented only to persons who have the financial sophistication and resources to independently analyze the limitations of such performance.
  • Backtested results are accompanied by disclosure of the methodology, assumptions, and limitations of the simulation, including the specific period tested and any adjustments for fees, trading costs, or financing charges.
  • Live account performance, once available, will be presented net of all fees and expenses, calculated using time-weighted methodology, and accompanied by relevant benchmarks.

No Guarantee of Future Results

Past performance, whether actual or hypothetical, is not indicative of future results. Investing involves risk, including the possible loss of principal. There is no assurance that any strategy described on this website will achieve its investment objectives or that past performance patterns will continue.

Availability of Detailed Performance Data

Detailed performance data, including backtest methodology, monthly returns, drawdown statistics, and risk metrics, is available upon request to prospective clients who meet applicable qualification standards. All such disclosures include the regulatory disclaimers required by the SEC Marketing Rule.

§ 05

Risk Disclosures

Investing in securities involves substantial risk, including the risk of losing some or all of the capital invested. The following represents a summary of material risks associated with Arbor's investment strategy. A complete discussion of risks will be provided in our Form ADV Part 2A and in the investment management agreement.

Market Risk

The value of investments managed by Arbor will fluctuate with general market conditions. Adverse market movements may result in losses, and there is no assurance that the strategy's risk management framework will prevent or limit losses in all market environments.

Model & Systematic Strategy Risk

Arbor's strategy relies on systematic decision rules informed by quantitative analysis. These models may contain errors, may rely on assumptions that prove incorrect, or may perform differently in live markets than in backtested simulation. Market regime changes, structural shifts, or unprecedented events may cause the strategy to underperform or produce losses.

Leverage Risk

Certain strategy variants may employ leverage through margin borrowing or exposure to leveraged instruments. Leverage magnifies both gains and losses and may result in losses exceeding the capital invested in a given position.

ETF-Specific Risks

The strategy invests primarily in exchange-traded funds. ETFs are subject to tracking error, bid-ask spreads, premium/discount to net asset value, and the risks of their underlying assets. Inverse and leveraged ETFs, where used, are subject to additional risks including daily rebalancing effects and compounding over longer holding periods.

Liquidity Risk

Although the strategy invests primarily in liquid ETFs, there may be circumstances in which markets become disorderly, trading is halted, or execution is materially impaired. Such conditions may prevent the strategy from executing trades as intended.

Concentration & Correlation Risk

The strategy may at times concentrate exposure in a limited number of sectors, asset classes, or instruments. Correlations among positions may rise during periods of market stress, reducing the diversification benefit of the portfolio.

Operational & Technology Risk

The strategy depends on data feeds, trading systems, and execution infrastructure that may fail, produce errors, or be unavailable. Arbor maintains operational controls to mitigate these risks but cannot eliminate them entirely.

§ 06

Qualified Client Status

Certain performance-based fee arrangements offered by Arbor are available only to clients who meet the definition of a “qualified client” under SEC Rule 205-3 of the Investment Advisers Act of 1940.

Qualification Standards

A natural person is generally considered a qualified client if they meet at least one of the following criteria at the time an advisory contract is entered into:

  • The client has at least $1,100,000 under management with the adviser immediately after entering into the advisory agreement; or
  • The adviser reasonably believes the client has a net worth of more than $2,200,000, excluding the value of the client's primary residence and certain related liabilities.

These thresholds are subject to periodic adjustment by the SEC and the current figures reflect the adjustment effective August 16, 2021. Clients should verify the current thresholds at the time of engagement.

Non-Qualified Clients

Clients who do not meet qualified client status remain eligible for advisory services at a management-only fee structure. Performance-based compensation is not available to non-qualified clients under applicable law.

§ 07

Fees & Compensation

Arbor's compensation is derived exclusively from fees paid by advisory clients pursuant to written investment management agreements. The specific fee arrangement is individually negotiated and disclosed in each client's advisory agreement.

Fee structures may include a management fee calculated as a percentage of assets under management, a performance-based fee calculated against a high-water mark (available only to qualified clients), or a combination of both. All fees are disclosed in our Form ADV Part 2A and in the client's individual advisory agreement before services commence.

Arbor does not receive commissions, payments for order flow, soft-dollar benefits in excess of those permitted under Section 28(e) of the Securities Exchange Act of 1934, or compensation from any product issuer. Our interests are aligned with our clients through the fee relationship alone.

Additional Costs Borne by Clients

In addition to Arbor's advisory fees, clients will bear the following costs at their custodian or broker:

  • Brokerage commissions and transaction costs
  • Exchange and regulatory fees
  • ETF expense ratios (paid indirectly through the ETFs themselves)
  • Margin interest, where leverage is used
  • Custodian account fees, wire transfer fees, and similar administrative costs
§ 08

Conflicts of Interest

Arbor operates under a fiduciary standard and seeks to identify, disclose, and mitigate conflicts of interest that may arise in the course of providing advisory services. The following represents a summary of potential conflicts; a complete discussion is available in our Form ADV Part 2A.

Performance-Based Fees

Where performance-based fees apply, the Firm may have an incentive to pursue higher-return, higher-risk strategies than it would under a management-only fee structure. Arbor mitigates this conflict by applying the same systematic strategy to all client accounts within a given product tier, regardless of fee arrangement, and by incorporating high-water marks that reduce the incentive for short-term performance chasing.

Proprietary Trading

Principals of Arbor may invest their personal capital in the same strategies offered to clients. Personal trading is subject to the Firm's Code of Ethics, which is available upon request, and is conducted on terms that do not disadvantage clients.

Research Publications

Research published by Arbor on this website, on Seeking Alpha, or on other platforms is intended for general educational purposes. Research may discuss securities or strategies that Arbor owns or trades for client accounts. Readers should assume that any security mentioned may be held in client portfolios or in proprietary accounts.

§ 09

Custody & Brokerage

Arbor does not maintain custody of client assets. All client funds and securities are held at Interactive Brokers LLC (“Interactive Brokers”), a qualified custodian that is a member of the Securities Investor Protection Corporation (SIPC) and registered with the SEC, FINRA, and other regulatory authorities.

Clients open accounts directly with Interactive Brokers and grant Arbor limited trading authority through the custodian's standard advisor authorization process. Clients retain direct access to their accounts, receive independent statements from Interactive Brokers, and may withdraw funds at any time subject to their advisory agreement.

The selection of Interactive Brokers as custodian is based on the firm's institutional-grade execution infrastructure, competitive financing rates, and suitability for systematic ETF-based strategies. Clients should understand that Arbor does not receive any compensation, payment for order flow, or soft-dollar benefits from Interactive Brokers for directing client business to the platform.

§ 10

Research Content & Editorial Independence

Research, commentary, and analysis published on this website and on third-party platforms such as Seeking Alpha are produced for educational and informational purposes. Such content:

  • Does not constitute personalized investment advice or a recommendation to buy or sell any security;
  • Reflects the author's views and analysis as of the date of publication and may not be updated as circumstances change;
  • May discuss securities or strategies held in client or proprietary accounts;
  • Is not a substitute for independent research, professional advice, or careful consideration of individual circumstances.

Research content is editorially independent and is not influenced by third-party compensation, advertising relationships, or affiliations with issuers of the securities discussed.

§ 11

Privacy Policy

Arbor is committed to protecting the privacy of current and prospective clients. This summary describes the information we collect, how we use it, and the rights you have with respect to your personal information.

Information We Collect

  • Information you provide through contact forms, research signups, or prospective-client inquiries, including name, email address, and any information you voluntarily share;
  • Information necessary to establish and manage advisory relationships, collected during account onboarding in accordance with applicable law;
  • Website usage information collected through standard analytics tools, which may include IP address, browser type, pages visited, and referral source.

How We Use Information

  • To respond to inquiries and provide information you request;
  • To provide investment advisory services to clients;
  • To send research publications, newsletters, or firm updates to subscribers;
  • To comply with regulatory, legal, and tax obligations;
  • To improve the operation of this website and our services.

Information Sharing

Arbor does not sell personal information. We may share information with service providers (such as our custodian, technology vendors, and regulatory authorities) as necessary to operate the business and comply with applicable law. Service providers are contractually obligated to protect the confidentiality of information received.

Your Rights

You may request access to, correction of, or deletion of personal information we hold about you by contacting us at the address below. We will respond to such requests in accordance with applicable law.

§ 12

Website Terms of Use

Your use of this website is subject to the following terms. By accessing this website, you agree to be bound by these terms.

No Advisory Relationship

Use of this website does not create an investment advisory relationship between you and Arbor. An advisory relationship is established only through a separately executed written investment management agreement.

Accuracy & Updates

Arbor endeavors to ensure the accuracy of information on this website but makes no warranty, express or implied, regarding the accuracy, completeness, or currency of any content. Information may be updated, changed, or removed at any time without notice.

Third-Party Links

This website may contain links to external websites operated by third parties. Arbor is not responsible for the content, accuracy, or privacy practices of third-party sites.

Intellectual Property

All content on this website, including text, research, graphics, logos, and design elements, is the property of Arbor Portfolio Management, LLC or its licensors and is protected by copyright, trademark, and other applicable laws. Reproduction or distribution without written permission is prohibited.

Limitation of Liability

To the fullest extent permitted by law, Arbor disclaims all liability for any direct, indirect, incidental, consequential, or special damages arising from your use of this website or reliance on any information contained herein.

Governing Law

These terms are governed by the laws of the State of Georgia, without regard to its conflict of laws principles. Any dispute arising out of or relating to this website shall be subject to the exclusive jurisdiction of the state and federal courts located in Fulton County, Georgia.

§ 13

Contact

Questions, comments, or requests for additional information regarding these disclosures or Arbor's services may be directed to:

Prospective clients requesting our Form ADV, Privacy Notice, or other regulatory documentation may submit such requests through the same channels. We will respond within a reasonable time and in accordance with applicable law.

Effective Date 23 April 2026
Document Version 1.0
Continue reading
Explore · Approach

The methodology, in depth.

Our intellectual framework: credit-first regime detection, systematic execution, and the discipline of economic interpretability over factor proliferation.

Explore · Services

How engagement works.

The practical structure of a client relationship: the separately managed account, the role of the custodian, onboarding, and what you receive as a client.

Questions on these disclosures

Speak with us directly.

For qualified investors evaluating whether the strategy is a fit, we welcome a direct conversation about methodology, structure, and terms.

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