Valhalla Advisors LLC

• A percentage of assets under your management
• Hourly charges
• Fixed fees (other than subscription fees)

Item 5.E lists how the firm is compensated for its advice; Items 5.B, 6.A, and 7.A show whether its people or related companies can also earn commissions. Percentage of assets, fixed, hourly, subscription, and performance-based fees come from clients (a performance-based fee depends on investment results); commissions come with a sale or a trade, often from the company behind the product. How fees, commissions, and other arrangements differ

$22,881,851 as of October 2026, filing dated March 30, 2026.

A measure of scale, not skill or returns. Discretionary means the firm decides trades; non-discretionary means clients approve each one. What assets under management means

A firm with no individual clients is an institutional manager even if it manages billions; the mix tells you whom the practice is built around.

• Financial planning services
• Portfolio management for individuals and/or small businesses
• Educational seminars/workshops
• Other

Registration

State-registered investment adviser. Status as filed: APPROVED.

Registered since

2020 (5 years)

Employees

Total: 2. Performing investment advisory functions: 2.

Wrap fee program participation

No.

States registered or notice-filed

1 state or jurisdiction

AZ

State-registered investment advisers are examined by their state securities regulator. SEC, state, and exempt registration

2 Reports 2 disclosure items on Form ADV Item 11. View on IAPD.

Questions answered yes on this filing

Regulatory matters Items 11.C to 11.G

• 11.G Is the firm or an advisory affiliate now the subject of a regulatory proceeding that could result in a yes answer to any part of 11.C, 11.D, or 11.E?

Civil court matters Item 11.H

• 11.H(2) Is the firm or an advisory affiliate now the subject of a civil proceeding that could result in a yes answer to any part of 11.H(1)?

Each question covers the firm and its advisory affiliates: its current employees other than clerical staff, its officers, partners, and directors, and anyone who controls the firm or is controlled by it. One event can produce yes answers to several questions. SEC-registered advisers and exempt reporting advisers may leave out events more than ten years old, and may answer 11.A(2) and 11.B(2) for pending charges only. What happened, and who was involved, is on the Disclosure Reporting Pages of the IAPD record. Reading a firm's disclosures

No changes to these filed facts in the last 12 months of filing data.

Compared month to month from the SEC's monthly adviser data and the state compilation feed. Owners and control persons are summarized, never named.