Regulatory Disclosure

Form ADV Part 2A — Firm Brochure

Firm: Shorebird, LLC
CRD #: 290121
Date: March 3, 2026
Address: 2549 Eastbluff Drive, Suite 752, Newport Beach, CA 92660
This brochure provides information about the qualifications and business practices of Shorebird, LLC. If you have any questions about the contents of this brochure, please contact us at (951) 216-9355. 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. Registration of an investment adviser does not imply any level of skill or training. Additional information about Shorebird, LLC is available on the SEC's website at www.adviserinfo.sec.gov.

Item 2 — Material Changes

We have the following material change to report since our firm's last annual update on March 3, 2026.

Item 5 — Our financial planning hourly rate has been updated to $125. Please refer to Item 5 for additional details regarding fees and compensation.

Item 4 — Advisory Business

Ownership / Advisory History

Shorebird, LLC was founded in August 2017 by Corey Johnson. We are a California Limited Liability Company and became registered as an investment adviser in September 2017. Additional information about Mr. Johnson can be found under Item 19 along with his attached Supplemental Brochure.

Financial Planning

We offer financial planning services to evaluate the client's financial situation, goals, and risk tolerance. Through a series of personal interviews and/or the use of questionnaires we collect pertinent data, identify goals, objectives, financial problems, and potential solutions. With this information, we tailor the client's financial plan and advice we give to the client. Our advice may cover any of the following topics: retirement planning; general investing; current net worth situation; savings plans; cash flow analysis; 401k review; or other needs as identified during our meetings with the client. The client will receive a written financial plan following our meetings.

Ongoing Financial Advising

We offer ongoing financial advising that involves an ongoing relationship beyond simply creating a written financial plan for the client. At the beginning of the relationship we create a written financial plan to get a baseline of the client's financial situation. After, we continuously monitor the client's financial situation through meetings and telephone calls to update the written financial plan as needed. Additionally, the ongoing service covers the client's assets not managed by us, such as the client's employer sponsored retirement plan and/or the client's personal investments held in personal brokerage accounts. With the employer sponsored retirement plans and personal assets held away from our management, we review the investment options available and make an asset allocation recommendation to the client.

Portfolio Management Services

We offer portfolio management services that involve assisting with the ongoing management of a client's investment accounts. We work with the client to formulate an individualized portfolio that is comprised of one or more of our model portfolios. Our recommendation is based upon the client's objectives, time frame, risk parameters, and other investment considerations. Once we have this information we create the individualized portfolio for the client. The client's portfolio is unique to the client. We regularly monitor the client's portfolio and adjust it as determined by stock market and world events.

Recommendation and Monitoring of Third Party Investment Advisers

When deemed appropriate, we may recommend the services of a third-party investment adviser ("Third-Party Adviser"). We currently recommend Betterment LLC (CRD # 149117), although additional Third-Party Advisers may be added in the future. The recommendation will depend on the client's circumstances, goals and objectives, strategy desired, account size, risk tolerance, or other factors. We work with each client to determine which Third Party Adviser may be appropriate. Clients are never obligated to use a recommended Third-Party Adviser.

We will review Third Party Advisers prior to making a recommendation to the client. We consider the following factors during our review: fees, reputation, performance, financial strength, management, price, reporting capabilities, client's financial situation, client's goals, client's needs, and client's investment objectives. If the client wishes to proceed with the recommendation, the client will sign an agreement with us along with the separate agreement with the Third-Party Adviser. Our agreement with the client states that we will monitor the client's account managed by the Third-Party Adviser, make recommendations about the Third-Party Adviser, meet with the client at least annually, and act as the client's primary financial adviser.

When we recommend the service of a Third-Party Adviser, clients will be given a copy of its Form ADV Part 2A upon the recommendation. We will not refer a client to a third party unaffiliated investment adviser unless it is registered or exempt from registration as an investment adviser in the client's state of residence.

Tailored Services

The goals and objectives for each client are documented before any investing takes place. Clients may impose restrictions on investing in certain securities or types of securities.

Wrap Program

We do not sponsor a wrap program. This section is not applicable.

Client Assets Managed

As of December 31, 2025, we manage $0 in client assets on a discretionary basis and $1,825,956 in client assets on a non-discretionary basis.

Item 5 — Fees and Compensation

Financial Planning Services

Our financial planning services are provided on an hourly or fixed fee basis. For our hourly fee we charge a rate of $125 per hour with a minimum of two hours per engagement. For our fixed fees, we charge between $500 to $5,000 for our financial planning services. The total fee depends on the client's financial situation, the number of topics to be covered in the written plan, number of meetings, and time to conduct research and writing of the plan. The fee is negotiable and is agreed to at the time of engagement. Depending on the specific planning service, we may collect one half of the fee upon engagement with the second half upon delivery of the financial plan.

A client may terminate any service for any reason within the first five (5) business days after signing an advisory contract and receive a 100% refund of any prepaid fees, without any cost or penalty. Thereafter, the financial planning contract may be terminated at any time by giving ten (10) days' written notice to Shorebird, LLC, 2549 Eastbluff Drive, Suite 752, Newport Beach, CA 92660.

Note: When we provide financial planning services and the client implements the financial plan through our representative, the representative will receive compensation in the form of a commission or fee. This creates a conflict of interest. Therefore: (a) a conflict exists between the representative's interests and the interests of the client; (b) the client is under no obligation to act upon the recommendation; and (c) if the client elects to act on any of the recommendations, the client is under no obligation to affect the transaction through the representative.

Ongoing Financial Advising

We charge a monthly fee between $100 to $500 for our ongoing financial advising services. The exact monthly fee is negotiable based on the client's financial situation, the number of topics to be covered in the written plan, number of meetings scheduled, number of non-managed accounts, and time to conduct research and writing of the plan.

Portfolio Management Services

Our management fee is based on a percentage of assets under management. The annual management fee is 1.00%, collected monthly in arrears based on the account's average daily balance as reported by the custodian. The management fee is negotiable based on the size of the client's account.

Our management fee does not include brokerage commissions, transaction fees, or other related costs and expenses. Clients may incur charges imposed by custodians, brokers, and other third parties such as custodial fees, deferred sales charges, transfer taxes, wire transfer fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund's prospectus.

A client may terminate the advisory contract at any time within the first five (5) business days after signing without cost or penalty. Thereafter, the contract may be terminated at any time by giving ten (10) days' written notice to Shorebird, LLC, 2549 Eastbluff Drive, Suite 752, Newport Beach, CA 92660.

Recommendation and Monitoring of Third-Party Investment Advisers

For recommendation and monitoring of Third-Party Advisers, we charge a management fee of 0.75% annually based on assets under management in the account managed by the Third-Party Adviser. The fee is calculated and collected by the Third-Party Adviser and distributed to us on their schedule.

Our fee is exclusive of the Third Party Adviser's management fee, brokerage commissions, transaction fees, and other related costs and expenses. A client may terminate the advisory contract at any time within the first five (5) business days after signing without cost or penalty, or thereafter by giving ten (10) days' written notice.

Other Securities Compensation

We do not receive any additional securities compensation. This item is not applicable.

Comparable Services Disclosure

Clients should note that lower fees for comparable services may be available from other sources.

Item 6 — Performance-Based Fees and Side by Side Management

We do not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client) or provide side by side management.

Item 7 — Types of Clients

We offer our services to individuals, high net worth individuals, corporations, and other business entities. We do not require a minimum balance.

Item 8 — Methods of Analysis, Investment Strategies and Risk of Loss

Methods of Analysis and Investment Strategies

When we create a client's portfolio we use asset allocation with the intention of holding securities for the long-term. Asset allocation is an investment strategy that aims to balance risk and reward by apportioning a portfolio's assets according to an individual's goals, risk tolerance, and investment horizon. The asset classes typically include equities, fixed-income, international, and cash and equivalents.

We purchase securities with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. The risk associated with using a long-term purchase strategy is that it generally assumes the financial markets will go up in the long-term, which may not be the case.

Investment Risks

All investment programs have certain risks that are borne by the client and investing in securities involves risk of loss that clients should be prepared to bear. Our goal is to reduce the risk of loss, but not at the expense of portfolio growth. To manage risk, we rebalance model portfolios on an as-needed basis to bring the asset allocations back to their intended balances.

Recommended Securities

We primarily use mutual funds and ETFs in client accounts. Some of the risks associated with investing in securities include:

  • Credit risk: The risk that an issuer of a bond could suffer an adverse change in financial condition that results in a payment default, security downgrade, or inability to meet a financial obligation.
  • Inflation risk: The risk that inflation will undermine the performance of an investment and/or the future purchasing power of a client's assets.
  • Interest rate risk: The chance that bond prices overall will decline because of rising interest rates.
  • International investing risk: Investing in the securities of non-U.S. companies involves special risks not typically associated with investing in U.S. companies. Foreign securities tend to be more volatile and less liquid, and may lose value because of adverse political, social, or economic developments overseas or due to changes in exchange rates.
  • Manager risk: The chance that the proportions allocated to the various securities will cause the client's account to underperform relative to benchmarks or other accounts with a similar investment objective.
  • Stock market risk: The chance that stock prices overall will decline. Stock markets tend to move in cycles, with periods of rising and falling prices.

Item 9 — Disciplinary Information

Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of each supervised person providing investment advice. We do not have information applicable to this item.

Item 10 — Other Financial Industry Activities and Affiliations

Broker-Dealer Affiliation

We are not affiliated with a broker-dealer.

Futures/Commodities Firm Affiliation

We are not affiliated with a futures or commodities broker.

Other Industry Affiliations

Our owner, Mr. Johnson, is also co-owner and Chief Analyzer for Finch, PC, a finance and accounting company for businesses, churches, and nonprofits. This service pays him fees or commissions that are separate from the adviser fees outlined in Item 5. This is a conflict of interest because it creates a financial incentive to recommend this service to the firm's clients. However, Mr. Johnson attempts to mitigate any conflicts of interest to the best of his ability by placing the client's interest ahead of his own through his fiduciary duty and by informing clients they are never obligated to purchase recommended services through him.

Recommendation of Third-Party Investment Adviser

We may recommend a third-party adviser to manage a portion of the client's account. Please see Items 4 and 5 above for additional details.

Item 11 — Code of Ethics, Participation or Interest in Client Transactions and Personal Trading

Description

Our Code of Ethics establishes ideals for ethical conduct based upon fundamental principles of openness, integrity, honesty, and trust. We will provide a copy of our Code of Ethics to any client or prospective client upon request.

Our Code of Ethics covers all supervised persons and describes our high standard of business conduct and fiduciary duty to our clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition on rumor mongering, restrictions on the acceptance of significant gifts, and personal securities trading procedures. All supervised persons must acknowledge the terms of the Code of Ethics annually or as amended.

Material Interest in Securities

We do not have a material interest in any securities.

Investing In or Recommending the Same Securities

Our owners may buy or sell for their own account the same securities at or about the same time that they recommend those securities to clients or purchase them for client accounts. A conflict of interest may exist because they can trade ahead of client trades. We mitigate any conflict of interest in two ways. First, our Code of Ethics requires employees to report personal securities transactions on at least a quarterly basis. Second, we require client transactions to be placed ahead of our associates' personal trades. The records of all associates' personal and client trading activities are reviewed and made available to regulators to review on the premises.

Item 12 — Brokerage Practices

Recommendation Criteria

We do not maintain custody of client assets that we manage, although we may be deemed to have custody of those assets if the client gives us authority to withdraw advisory fees from his or her account (see Item 15 — Custody, below). Client assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. We recommend that our clients use either Interactive Brokers, LLC or MTG, LLC dba Betterment Securities, both registered broker-dealers and members SIPC, as the qualified custodians. We are independently owned and operated and are not affiliated with either firm.

How We Select Brokers/Custodians

We seek to recommend a custodian/broker that will hold the client's assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers. We consider a wide range of factors, including:

  • Capability to execute, clear, and settle trades
  • Capability to facilitate timely transfers and payments
  • Availability of investment research and tools
  • Quality of services
  • Competitiveness of price and willingness to negotiate
  • Reputation, financial strength, and stability
  • Prior service to us and our other clients

The Clients' Brokerage and Custody Costs

For client accounts that Betterment Securities maintains, Betterment Securities generally does not charge the client separately for custody services, but is compensated as part of the Betterment Institutional platform fee. We have determined that having Betterment Securities execute trades is consistent with our duty to seek "best execution" of trades.

Services Available to Us via Betterment Institutional

Betterment Institutional makes available various support services including access to investment products, execution of securities transactions, and custody of client assets. Betterment Institutional also makes available other products and services that may assist us in managing and administering our clients' accounts, such as software and technology for back-office functions, recordkeeping, and client reporting.

The availability of these services from Betterment Institutional benefits us because we do not have to produce or purchase them. These services may be contingent upon us committing a certain amount of business to Betterment Securities in assets in custody, which represents a potential conflict of interest. We believe, however, that our selection of Betterment Securities as custodian and broker is in the best interests of our clients, primarily supported by the scope, quality, and price of their services.

Research and Soft Dollars

We do not receive any soft dollars.

Brokerage for Client Referrals

We do not receive client referrals or any other incentive from any broker-dealer or custodian.

Directed Brokerage

Some clients may direct us to a specific broker-dealer to execute securities transactions for their accounts. When so directed, we may not be able to effectively negotiate lower brokerage commissions or achieve best execution, which can result in substantially higher fees or charges.

Trade Aggregation

We do not block or aggregate trades. This section is not applicable.

Item 13 — Review of Accounts

Periodic Reviews

Our owner, Mr. Johnson, performs all periodic reviews. For financial planning clients, he reviews written financial plans at the client's request. He reviews portfolio management and Betterment client accounts on a quarterly basis. These reviews consist of an analysis of the client's objectives and risk tolerance against the investments in the accounts.

Other Reviews

Additional reviews are conducted periodically depending on market conditions, economic or political events, or by changes in a client's financial situation (such as retirement, termination of employment, physical move, or inheritance).

Reports

We provide financial planning clients with a written financial plan after the financial planning process. Portfolio management and recommendation of Third-Party Adviser clients receive at least quarterly account statements from their custodian.

Item 14 — Client Referrals and Other Compensation

Other Compensation

We receive a non-economic benefit from Interactive Brokers and Betterment Institutional in the form of support products and services made available to us and other independent investment advisors whose clients maintain their accounts with those custodians. The availability of these products and services is not based on us giving particular investment advice, such as buying particular securities for our clients.

Client Referrals

We do not pay for client referrals or use solicitors.

Item 15 — Custody

All client funds, securities, and accounts are held at a qualified custodian. We do not take possession of a client's securities. However, the client will be asked to authorize us with the ability to deduct our management fee directly from the client's account. This authorization will apply to our management fee only and is considered a limited form of custody.

When deducting the fee, we send a billing invoice to each client and their custodian, showing the management fee to be debited, the amount on which the management fee was calculated, the time period covered, and how the management fee was calculated. In addition, the client will receive at least quarterly statements from the broker-dealer, bank, or other qualified custodian that holds and maintains the client's assets. We urge each client to carefully review such statements.

Item 16 — Investment Discretion

We offer discretionary and non-discretionary investment management services. Discretionary authority is granted when the client signs the investment management agreement, which contains a limited power of attorney allowing us to select the security, the amount, and the time of the purchase or sale in the client's account without the client's prior approval. In all cases, such discretion is to be exercised in a manner consistent with the stated investment objectives for the client account.

With non-discretionary investment management services, the client retains full discretion to supervise, manage, and direct the assets of the account. We will make recommendations on how the account should be managed, but trades will only be placed after we receive the client's permission.

Item 17 — Voting Client Securities

We do not vote proxy votes for any client. All proxy materials are mailed or emailed directly to the client from the custodian. Any proxy materials received by us will be forwarded to clients for response and voting. In the event the client has a question about a proxy solicitation, the client should feel free to contact us.

Item 18 — Financial Information

Balance Sheet

We do not require or solicit prepayment of more than $500 in fees per client, six months or more in advance. Therefore, we are not required to provide a balance sheet.

Financial Condition

We do not have a financial commitment that impairs our ability to service our clients.

Bankruptcy

We have not been the subject of a bankruptcy proceeding.

Item 19 — Requirements for State-Registered Advisers

We have one principal executive officer, Corey Johnson ("Mr. Johnson"). Mr. Johnson's biographical information is provided in the attached brochure supplement (Form ADV Part 2B).

Mr. Johnson is co-owner and Chief Analyzer for Finch, PC, an accounting and finance company for businesses, churches, and nonprofits. This activity and any conflicts of interest associated therewith are discussed in Item 10 of this brochure and his brochure supplement.

Mr. Johnson has no information to report regarding performance-based fees, relationships or arrangements with issuers of securities, or arbitration, civil, self-regulatory organization, or administrative proceedings.

Conflicts of Interest Disclosure

Pursuant to California Code of Regulations Section 260.238(k), the firm, its representatives, and employees have disclosed all material conflicts of interests that could reasonably be expected to impair the rendering of unbiased and objective advice, including: (a) compensation arrangements connected with advisory services which are in addition to the advisory fees; (b) other financial industry activities or affiliations; or (c) participation or interest in client transactions.

Business Continuity Plan

We have a Disaster Recovery and Business Continuity Plan in place that provides detailed steps to mitigate and recover from the loss of office space, communications, and/or services. The plan covers natural disasters such as snowstorms, hurricanes, tornadoes, and flooding, as well as man-made disasters such as loss of electrical power, fire, bomb threats, internet outages, and aircraft accidents. Electronic files are backed up daily and stored on an encrypted cloud service.

Alternate offices are identified to support ongoing operations in the event the main office is unavailable. It is the firm's intention to contact all clients within five days of a disaster that dictates moving its office to an alternate location.

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