Eight 31 Financial, LLC

Eight 31 Financial, LLC, established in Midland, TX, offers discretionary investment advisory services through its Wrap Program, charging an annual fee based on assets under management. The fee structure is tiered, ranging from 1.25% for accounts valued over $25 million to 2.00% for accounts under $5 million. The firm's investment advisory fee is negotiable based on various factors. Clients have access to investment professionals to discuss their accounts and can amend discretionary authority limitations. There is no minimum annual fee, except for assets managed via the Pontera platform, subject to a $2,500 minimum fee. The Wrap Fee Agreement is terminable with a pro-rated refund. The firm primarily uses long-term purchases, short-term purchases, and trading strategies, with potential risks outlined, including market, interest-rate, and liquidity risks. Clients are responsible for promptly notifying the firm of any changes in their financial situation or investment objectives. The firm does not vote client proxies and maintains a Code of Ethics to prevent the misuse of material non-public information. The firm does not compensate individuals for client referrals and does not solicit fees exceeding $1,200 in advance. The firm's Principal and Chief Compliance Officer are available for any client inquiries.