For AdvisorsCompliance

Compliance, on the record.

You advise. The firm's compliance program sits around that work: a written code of ethics, a chief compliance officer, scheduled account reviews and the disclosures your clients receive. Each part below names the item of Form ADV Part 2A, brochure dated March 3, 2026, where it is written down.

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  1. Item 4AThe chief compliance officer
  2. Item 5EOutside compensation
  3. Item 10Other roles and affiliations
  4. Item 11Code of ethics and personal trading
  5. Item 13Review of accounts
  6. Item 15Custody

One chief compliance officer, named in the brochure

Charles Anthony Truhlar is Acrylic's president and chief compliance officer.

All financial planning accounts are reviewed by him when the plan is created and again when it is delivered. The duties of the compliance officer are one of the areas the firm's code of ethics covers.

Beyond the reviews the brochure sets out, Acrylic works with its advisors on a regular basis on the tools they use and the service they give their clients.

Acrylic has its own compliance team, and every advisor goes through background checks, training and coaching.

Form ADV Part 2A, Items 4A, 11A and 13A. The last two lines are the firm's own practice, not brochure items.

The rules you work under

Five areas of your own conduct as an advisor at Acrylic, each with the item that sets it out.

  1. Code of ethics

    A written code covering prohibited purchases and sales, insider trading, personal securities transactions, exempted transactions, prohibited activities, conflicts of interest, gifts and entertainment, confidentiality, service on a board of directors, compliance procedures, compliance with laws and regulations, procedures and reporting, certification of compliance, reporting violations, compliance officer duties, training and education, recordkeeping, annual review and sanctions. It is available free on request to any client or prospective client.

    Form ADV Part 2A, Item 11A

  2. Personal trading

    Acrylic monitors the personal investment accounts of its investment adviser representatives and keeps a restricted security list: the securities it uses in its client models. Trades in those securities are flagged and reviewed to confirm none took place on or near the time the models were traded, which is monthly.

    Items 11C and 11D

  3. Outside roles

    In advisory work through Acrylic, you are held to a fiduciary standard. Work as a registered representative of a broker-dealer or as an insurance agent follows the rules for that role and is not conducted through Acrylic; insurance sales are not made in a fiduciary capacity. Those roles and their conflicts are disclosed, and clients are told that advisory fees are separate from commissions and that they are not required to buy a commissionable product through you.

    Items 5E, 10A and 10C

  4. Books and records

    Recordkeeping is one of the areas the code of ethics covers, and the firm documents any transaction that could be read as a conflict of interest.

    Items 11A and 11C

  5. Marketing review

    Advertising and marketing materials go to the firm for review before use. Any paid referral arrangement is made in writing and follows Rule 206(4)-1 under the Advisers Act, with the required disclosures to clients and ongoing oversight.

    Item 14B, for referral arrangements

The checks on client accounts

What gets reviewed, how often and by whom, as the brochure sets it out.

  • Account reviews

    Every ongoing account is reviewed on an ongoing basis and at least quarterly, and more often when market conditions or a client's circumstances call for it. Acrylic also engages with each of those clients once a year to review the portfolio.

    Form ADV Part 2A, Item 13A

  • Review triggers

    Material market, economic or political events, or a change in a client's situation, such as retirement, the end of a job, a move or an inheritance.

    Form ADV Part 2A, Item 13B

  • Financial plan review

    Each financial plan is reviewed by the chief compliance officer when it is created and when it is delivered.

    Form ADV Part 2A, Item 13A

  • Recommendations

    Acrylic periodically reviews the recommendations of its supervised persons, to assess whether they rest on an objective evaluation of each client's risk profile and investment objectives, rather than on commissions or other benefits.

    Form ADV Part 2A, Item 10C

  • Conflicts in the file

    Conflicts are avoided where possible. Where they are not, they are disclosed in the Form ADV delivered before account opening, and documented in the client file.

    Form ADV Part 2A, Item 5E

  • Block trades

    When the same security is bought or sold for several clients in one order, trades are reviewed periodically to check that accounts are not systematically disadvantaged.

    Form ADV Part 2A, Item 12B

Custody and billing, checked from both sides

Acrylic does not accept or maintain physical custody of client funds or securities. When advisory fees are deducted from a client's account, the firm is deemed to have custody and must have that client's written authorization.

Clients receive statements directly from the qualified custodian, and are encouraged to compare them with the invoices they receive from Acrylic and to tell the firm promptly about any discrepancy.

Acrylic does not ask for, or accept, voting authority for client securities. Clients receive proxies directly from the issuer or the custodian.

Form ADV Part 2A, Items 15 and 17. Read the brochure

The documents your clients receive

And the firm's own record, which anyone can check.

Form ADV Part 2A
Delivered before account opening, with the conflict disclosures. Clients may request the current brochure at any time at (833) 422-7954 or info@acrylicfinancial.com. Items 2 and 5E
Form CRS
The firm's relationship summary, dated April 30, 2025. Form CRS
Brochure supplement
The individual brochure supplement you provide, about you. Form CRS, Item 5
Code of ethics
Free on request to any client or prospective client. Item 11A
Monthly statement
From the custodian: the assets held, their value and the fee calculation. Item 13C
Disciplinary history
None to report: no criminal or civil actions, no administrative proceedings and no self-regulatory organization proceedings. Item 9. Form CRS, Item 4

Form ADV Part 2AForm CRSThe firm on IAPD

Registration as an investment adviser does not imply a certain level of skill or training.

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Bring your compliance questions to the first conversation: your registrations, your outside roles, how you market your practice today. The form starts it.

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Advisory services through Acrylic Financial, Inc., an SEC-registered investment adviser, CRD 288263. Registration does not imply a certain level of skill or training.