This brochure provides information about the qualifications and business practices of Interchange Advisers LLC. If you have any questions about the contents of this brochure, contact us at 855-468-7934. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority.
Additional information about Interchange Advisers LLC is available on the SEC's website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Interchange Advisers LLC's CRD number is 338973.
Interchange Advisers LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training.
Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate.
Since this is our initial registration brochure, there are no material changes to report.
Interchange Advisers LLC ("Interchange Advisers") is a registered investment adviser primarily based in Vancouver, Washington. We are organized as a Limited Liability Company ("LLC") under the laws of the State of Delaware. We began providing investment advisory services in July 2026. Interchange is principally owned by Interchange Financial Technologies Inc. which in turn is principally owned by Harland Group LLC. Harland Group LLC is principally owned by Michael H. Giles.
The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "the Company", "we," "our," and "us" refer to Interchange Advisers and the words "you," "your," and "Customer" refer to you as either a Customer or prospective Customer of our Company.
We offer non-discretionary portfolio management services. When you enter into a non-discretionary arrangement with us, we must obtain your approval prior to entering or directing transactions regarding your account. You have an unrestricted right to decline the advice provided by our Company and implementation thereof when entering into a non-discretionary arrangement. Our obligations to monitor investments in non-discretionary advisory accounts will be set out in the investment advisory agreement.
We do not serve as sponsor or manager to a wrap fee program.
We primarily offer advice regarding Exchange Traded Funds. Refer to the Methods of Analysis, Investment Strategies and Risk of Loss below for additional disclosures on this topic.
We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship.
As of July 2026, Interchange Advisers provided continuous management services for $0 in Customer assets on a discretionary basis and $0 in Customer assets on a non-discretionary basis.
Interchange Advisers annual fees for Investment Supervisory Services are based upon a percentage of assets under management and generally range from 30 bps to 150 bps.
Interchange Advisers does not impose a stated minimum fee or minimum portfolio value for starting and maintaining an investment management relationship.
Interchange Advisers may, in its sole discretion, negotiate to charge a lesser fee based upon certain criteria including anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, service requirements, pre-existing/legacy Customer relationship, account retention and pro bono activities.
Our annual fee is charged or invoiced payable monthly in arrears for the calendar month-end based on the average market value of the Customer's account of the previous billing period. The Account Management Fee is prorated for periods less than a full billing cycle and adjusted to cover additional contributions made during that period.
Termination of the Advisory Relationship: An Interchange Advisers Customer agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days written notice or other mutually agreed upon termination notification terms.
All fees paid to Interchange Advisers for investment advisory services are separate and distinct from the fees and expenses charged to shareholders by mutual funds and/or ETFs. These fees and expenses are described in each fund's prospectus. Such fees generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a Customer may pay an initial or deferred sales charge. A Customer could invest in a mutual fund directly, without our services. In that case, the Customer would not receive the services provided by Interchange Advisers which are designed, among other things, to assist the Customer in determining which mutual fund or funds are most appropriate to each Customer's financial condition and objectives. Accordingly, the Customer should review both the fees charged by the funds and Interchange Advisers fees to fully understand the total amount of fees to be paid by the Customer and to thereby evaluate the advisory services being provided.
In addition to Interchange Adviser's advisory fees, Customers are responsible for the fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transactions for the Customer's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information.
Customers should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees.
Under no circumstances does Interchange Advisers require or solicit payment of fees more than six months in advance of services rendered.
Interchange Advisers acknowledges that it is deemed to be a fiduciary to advisory Customers that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act ("ERISA"). As such, Interchange Advisers is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, Interchange Advisers may only charge fees for investment advice about products for which our Company and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our Company and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset Interchange Adviser's advisory fees.
Persons providing investment advice on behalf of our Company are registered representatives with Interchange Clearing LLC a securities broker-dealer, and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. This creates a conflict of interest. Such persons have an incentive to recommend securities for which they are separately compensated.
Interchange Advisers does not provide any services for a performance-based fee (i.e., a fee based on a share of capital gains or capital appreciation of a Customer's assets).
Interchange Advisers provides advisory services to the following types of Customers:
Our investment strategies and advice may vary depending upon each Customer's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial information, liquidity needs and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. Risks for all forms of analysis rely on the assumption that the publicly available sources of information about the securities are accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information.
We may use one or more of the following methods of analysis or investment strategies when providing investment advice to you:
Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the Customer's investment goals and risk tolerance. A risk of asset allocation is the Customer may not participate in sharp increases in a particular security, industry or market sector. Another risk is the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the Customer's goals.
Interchange Advisers may manage certain accounts using managed "model" portfolios, whereby the Company allocates all or a portion of its Customers' assets among various mutual funds and/or securities on a discretionary basis using one or more of its proprietary investment strategies. In managing assets through the use of models, the Company remains in compliance with the safe harbor provisions of Rule 3a-4 of the Investment Company Act of 1940. While the Company seeks to ensure that Customers' assets are managed in a manner consistent with their individual financial situations and investment objectives, securities transactions effected pursuant to a model investment strategy are usually done without regard to a Customer's individual tax ramifications.
We use mathematical models in an attempt to obtain more accurate measurements of a company's quantifiable data, such as the value of a share price or earnings per share and predict changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect.
We subjectively evaluate non-quantifiable factors such as quality of management, labor relations, and strength of research and development factors not readily subject to measurement and predict changes to share price based on that data. The risk associated with using qualitative analysis is subjective judgment and may prove incorrect.
Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the investing of your assets.
Custodians and broker dealers report the cost basis of equities acquired in Customer accounts. Your custodian will default to the First-In First-Out ("FIFO") accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, provide written notice to our Company immediately and we will alert your account custodian of your individually selected accounting method. Decisions about cost-based accounting methods will need to be made before trades settle, as the cost-based method cannot be changed after settlement.
Investing in securities involves risk of loss. We do not represent or guarantee that our services or methods of analysis predict future results, successfully identify market tops or bottoms, or insulate Customers from losses due to market corrections or declines. There are no guarantees or promises that your financial goals and objectives will be met. Past performance is not an indication of future performance.
When evaluating risk, financial loss may be viewed differently by each Customer and may depend on many different risks, each of which may affect the probability and magnitude of any potential losses. The following other risks are not all-inclusive but should be considered carefully by a prospective Customer before retaining our services:
Investing in emerging and growth markets entails social, economic, technological, political and regulatory risks not usually associated with investing in developed markets. Certain jurisdictions may allow for clawback arrangements with counterparties as a result of changes in law. Emerging and growth markets in certain countries could also face other significant internal or external risks, including heightened risk of war, civil unrest, and other conflicts.
There are numerous ways of measuring the risk of equity securities (also known simply as "equities" or "stock"). In very broad terms, the value of a stock depends on the financial health of the company issuing it. However, stock prices can be affected by many other factors including but not limited to the class of stock (for example, preferred or common); the health of the market sector of the issuing company; and, the overall health of the economy. In general, larger, more established companies ("large cap") tend to be safer than smaller start-up companies ("small cap") but the mere size of an issuer is not, by itself, an indicator of the safety of the investment.
The risk that your investment horizon is shortened because of an unforeseen event, for example, the loss of your job. This may force you to sell investments that you were expecting to hold for the long term. If you must sell when the markets are down, you may lose money. Longevity Risk is the risk of outliving your savings. This risk is particularly relevant for people who are retired or are nearing retirement.
The risk of being unable to sell your investment at a fair price at a given time due to high volatility or lack of active liquid markets. You may receive a lower price or it may not be possible to sell the investment at all.
Mutual funds and exchange traded funds ("ETF") are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds and ETFs generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. ETFs differ from mutual funds since they can be bought and sold throughout the day like stock and their price can fluctuate throughout the day. The returns on mutual funds and ETFs can be reduced by the costs to manage the funds. Also, while some mutual funds are "no load" and charge no fee to buy into, or sell out of, the fund, other types of mutual funds do charge such fees which can also reduce returns. Mutual funds can also be "closed end" or "open end". So-called "open end" mutual funds continue to allow in new investors indefinitely whereas "closed end" funds have a fixed number of shares to sell which can limit their availability to new investors.
The risk that the value of the assets invests decreases (potentially dramatically) in response to the prospects of individual companies, or financial markets.
Interchange Advisers is required to disclose any legal or disciplinary events that are material to a Customer's or prospective Customer's evaluation of our advisory business or the integrity of our management. We do not have any required disclosures under this item.
Persons providing investment advice on behalf of our Company are registered representatives with Interchange Clearing LLC a securities broker-dealer, and a member of the Financial Industry Regulatory Authority and the Securities Investor Protection Corporation. See the Fees and Compensation section in this brochure for more information on the compensation received by registered representatives who are affiliated with our Company.
Interchange Advisers has adopted a code of ethics in compliance with applicable securities laws ("Code of Ethics") that sets forth the standards of conduct expected of its Supervised Persons. Interchange Adviser's Code of Ethics contains written policies reasonably designed to prevent certain unlawful practices such as the use of material non-public information by the Company or any of its Supervised Persons and the trading by the same of securities ahead of Customers in order to take advantage of pending orders.
The Code of Ethics also requires certain of Interchange Adviser's personnel to report their personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial public offerings, limited offerings). However, the Company's Supervised Persons are permitted to buy or sell securities that it also recommends to Customers if done in a fair and equitable manner that is consistent with the Company's policies and procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently broad markets to permit transactions by certain personnel to be completed without any appreciable impact on the markets of such securities. Therefore, under limited circumstances, exceptions may be made to the policies stated below.
When the Company is engaging in or considering a transaction in any security on behalf of a Customer, no Supervised Person with access to this information may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and adults living in the same household) a transaction in that security unless:
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii) money market instruments, bankers' acceptances, bank certificates of deposit, commercial paper, repurchase agreements and other high-quality short-term debt instruments, including repurchase agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit investment trusts that are invested exclusively in one or more mutual funds.
Customers and prospective Customers may contact Interchange Advisers to request a copy of its Code of Ethics.
We recommend the brokerage and custodial services of Interchange Clearing LLC. Your assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. In recognition of the value of the services the Custodian provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere.
We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, the most favorable compared to other available providers and their services. We consider various factors, including:
We do not have any soft dollar arrangements.
As a registered investment adviser, we have access to the institutional platform of your account custodian. As such, we also have access to research products and services from your account custodian and/or other custodian broker dealers. These products may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our Company in the performance of our investment decision-making responsibilities. Such research products and services are provided to all investment advisers that utilize the institutional services platforms of these firms and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by a particular broker for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge.
Some of the products, services, and other benefits provided by custodians benefit us and may not benefit our Customer accounts. Our recommendation that a Customer place assets with a specific custodian may be based in part on benefits the custodian provides to us, or our agreement to maintain certain Assets Under Management at the custodian, and not solely on the nature, cost or quality of custody and execution services provided by the broker-dealer custodian.
Interchange Advisers places trades for its Customers' accounts subject to its duty to seek best execution and its other fiduciary duties. We may use broker dealers other than the custodial broker dealer to execute trades for Customer accounts, but this practice may result in additional costs to Customers so that we are more likely to place trades through the custodial broker dealer rather than other broker-dealers. These custodial broker dealers' execution quality may be different than other broker-dealers.
We do not receive Customer referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research.
We require that you direct our Company to execute transactions through Interchange Clearing LLC. As such, we may be unable to achieve the most favorable execution of your transactions than you might otherwise receive through another broker dealer that offers the same types of services.
Interchange Advisers monitors Customer portfolios on a continuous and ongoing basis.
Customer Account Statements and Reports are provided with transaction confirmation notices and regular summary account statements directly from the custodians where their assets are held. From time-to-time or as otherwise requested, Customers may also receive written or electronic reports from Interchange Advisers and/or an outside service provider, which contain certain account and/or market-related information. Customers should compare the account statements they receive from their custodian with any documents or reports they receive from Interchange Advisers or an outside service provider. We monitor your accounts to ensure the advisory services provided to you are consistent with your investment needs and objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to:
The individuals conducting reviews may vary from time to time, as personnel join or leave our company.
We may provide you with additional or regular written reports in conjunction with account reviews. Reports we provide you contain relevant account and/or market-related information such as an inventory of account holdings and account performance, etc. You will receive trade confirmations and monthly or quarterly statements from your account custodian(s).
As disclosed under the Fees and Compensation section in this brochure, persons providing investment advice on behalf of our Company are registered representatives with Interchange Clearing LLC, a clearing broker-dealer, and a member of the Financial Industry Regulatory Authority, Inc. and the Securities Investor Protection Corporation. For information on the conflicts of interest this presents, and how we address these conflicts, refer to the Fees and Compensation section.
We do not receive any compensation from any third party in connection with providing investment advice to you nor do we compensate any individual or company for Customer referrals.
Our Company, or persons associated with our Company, may effect wire transfers from Customer accounts to one or more third parties designated, in writing, by the Customer without obtaining written Customer consent for each separate, individual transaction as long as the Customer has provided us with written authorization to do so. Such written authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such third-party wire transfers has access to the Customer's assets and therefore has custody of the Customer's assets in any related accounts.
However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by reason of having custody, as long as we meet the following criteria:
We hereby confirm that we meet the above criteria.
Interchange Clearing LLC in its capacity as a clearing broker-dealer and custodian, generally custodies the funds and securities in advisory accounts. Customers who custody funds and securities with Interchange Advisers receive account statements from Interchange Clearing LLC (generally, monthly). Customers should understand that the statements received from the custodian of their funds or securities are the official records for the advisory account.
When you enter into non-discretionary arrangements with our Company, we will obtain your approval prior to the execution of any transactions for your account(s). You have an unrestricted right to decline to implement any advice provided by our Company on a non-discretionary basis.
As provided in our investment advisory contract with each Customer, we do not vote proxies on behalf of Customer advisory accounts. At Customer's request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. However, if you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder.
We are required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual commitments to our Customers.
Our Company does not have any financial condition or impairment that would prevent us from meeting our contractual commitments to you. We do not take physical custody of Customer funds or securities, or serve as trustee or signatory for Customer accounts, and we do not require the prepayment of more than $1,200 in fees six or more months in advance. Therefore, we are not required to include a financial statement with this brochure.
We have not filed a bankruptcy petition at any time in the past ten years.
We are a federally registered investment adviser. Therefore, we are not required to respond to this item.
We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you.