Section A. THE COMPANY Chronos is organized as a limited liability company under the laws of the state of Florida. Chronos is headquartered in Miami, Florida and has been in business since 2016. OWNERSHIP Chronos is owned by Ernesto Bruna and Patricio Filippi. Section B. TYPES OF ADVISORY SERVICES Chronos is an independent multi-family office advisor. Chronos provides nondiscretionary investment advisory services regarding securities and non-securities holdings primarily to high net-worth and ultra-high net worth individuals and families, businesses entities and institutional clients (collectively “Clients”). Chronos may also provide discretionary investment management services regarding securities and non-securities to Clients, though it does not anticipate a significant volume of such activity. We are held to a fiduciary standard that covers our entire investment advisory relationship with you. For example, we are required to monitor your portfolio, investment strategy and investments on an ongoing basis. We must identify and eliminate conflicts of interest. Or tell you about them in a way you can understand, so that you can decide whether or not to agree to them. Section C. OVERVIEW OF ADVISORY SERVICES Advisory Services Given the customized nature of Chronos’ services, the processes described below are not required for every Client account. Furthermore, it is not anticipated that accounts having identical or substantially similar investment objectives will necessarily have identical or substantially similar investment portfolios. Different investment portfolios can be expected as the result of several factors, including, without limitation, the following:
• Pre-existing (or “legacy”) portfolio exposures;
• Regulatory constraints that apply to certain accounts but not to others;
• Investment constraints imposed by the Client; and
• The amount of cash available for investment at certain times As a result of factors such as these, accounts may have a different investment portfolio and, resultantly, different performance results, from other accounts even though the accounts have substantially similar investment objectives. In addition, there may be circumstances when one account will sell a security while another account may purchase the security on the same day. In the event Chronos acts in a discretionary advisory capacity, Chronos will have discretion to determine the type and amount of securities to be purchased or sold for a Client. Such discretion is to be exercised in a manner consistent with the Client’s stated investment objectives as outlined in the Client’s Investment Advisory Agreement. For some Clients, Chronos provides investment supervisory services using unaffiliated investment managers and pooled investment vehicles including, but not limited to, domestic limited partnerships and hedge funds. Chronos will generally only recommend investment managers, pooled investment vehicles and other investment products that are in the Client’s best interests and the respective custodian’s approved product list. A due diligence and evaluation process is used to evaluate investment managers and funds, employing both quantitative and qualitative techniques to identify the managers we feel are best qualified to meet our clients’ objectives. We will not assume discretionary authority to hire and fire manager(s) and/or reallocate your assets to other managers unless you provide prior authorization to do so. To the extent Clients invest directly or indirectly in funds, limited partnerships, or similar investment vehicles, the managers of such funds will have their own investment practices, and those independent investment practices will be described in each managers’ Form ADV disclosure documents, Form CRS, or the funds’ offering documents. With regard to its non-discretionary portfolio management services, Chronos’ specialization is not in one given instrument or asset class, but rather in the ongoing process of assessing Client objectives, developing an appropriate asset allocation to best achieve those objectives, and modifying that allocation when risks/opportunities are present, and evaluating investment managers and assessing where it is most appropriate to use active or passive strategies. Non-discretionary portfolio management services require Chronos to obtain the Client’s specific consent to each transaction, while discretionary services do not. Non-discretionary Clients in all cases make the final decisions regarding transactions, even in cases where Chronos facilitates the communication with their custodians or other financial entities. Accordingly, non-discretionary Clients may forego a particular recommended transaction, or a particular transaction may be delayed, if Chronos cannot obtain the Client’s prior consent. Chronos’ advisory team is primarily responsible for advising on asset allocation, portfolio recommendations, investment strategies and tailored solutions on behalf of its clients. The Client services include financial planning concepts with those of investment management. The advisory process typically encompasses the following steps: 1. Listen to the Client and

Understand the Asset Base: Chronos works closely with the Client to understand, among other things, the following: a. Family priorities; b. The Client’s current assets and liabilities, portfolio structure and asset allocation; c. Income and liquidity needs; d. Family structure; and e. Estate planning strategies and structures 2. Design the Portfolio: Chronos advises Clients by creating a portfolio that uses the Client’s long-term goals to balance risk and return. Chronos may assist with development of an Investment Policy Statement. At some point during this stage, we may use third-party software to obtain and chart various statistics for differing time periods, asset allocation structures, and potential capital market environments. Designing the portfolio is a multi-faceted task, which can include (among other elements) an understanding and articulation of the following: a. Asset allocation (at multiple levels); b. Asset location (e.g., selecting the appropriate accounts for specific investments); and, c. Client-imposed constraints (e.g., avoiding certain stocks or sectors), including unmanaged assets 3. Execute the Investment Advisory Agreement: Chronos primarily advises its clients in portfolio construction, asset allocation and implementation strategies. Chronos endeavors to select the investment strategies in each asset class to achieve the Client’s strategic portfolio. 4. Review, Monitor and Report on the Portfolio: Chronos monitors Client accounts on an ongoing basis and provides regular and comprehensive investment composition reports. When appropriate, Chronos will recommend subsequent modifications to the portfolio (e.g., manager changes, tactical asset allocation tilts). Chronos provides the following services:
• Supervisory oversight of the Client’s investment portfolios held at various financial institutions and managed by the Client’s financial advisors, brokers, private bankers, or portfolio managers (collectively “Financial Intermediaries”);
• Communicating to the Financial Intermediaries the Client’s objectives and any Client imposed constraints or limitations;
• Negotiating agreements commissions, fees, and volume discounts, as applicable, between the Client and the Financial Intermediaries and custodian(s);
• Reviewing existing Financial Intermediary and custody arrangements and if appropriate, identifying new Financial Intermediaries to manage the Client’s investment portfolios, or new Qualified Custodians, as defined under Rule 206(4)- 2 of the Investment Advisers Act of 1940, (“Advisers Act”), to hold client’s assets. Family Office Services Chronos’ family office services may be comprehensive or limited in scope. Chronos is flexible in creating customized service solutions, which may include some (or all), of the following: 1. Personal Accounting and Banking: Chronos can manage a Client’s personal accounting and banking activities, such as cash flow forecasts and credit facilities. 2. Strategic Philanthropy: Chronos can help Clients achieve philanthropic goals by coordinating with the Clients’ philanthropy advisors regarding such issues as optimal funding strategies, the establishment of gifting plans, and grant- making administration. 3. Estate Planning and Trust Services: Chronos can work with a Client’s estate planning attorney to coordinate, implement, manage, and report on trusts and estate plans. 4. Real Asset Management: Chronos can manage activities associated with large assets (e.g., real estate, boats, airplanes), including entity creation (as necessary), human resource management, and budgeting. 5. Consolidated Reporting: Chronos consolidates information received from custodians and other sources and presents it to the Client in a user-friendly format. 6. Family Governance: Chronos can assist in the creation of a family succession plan and in the creation and maintenance of a family communication process and governance system. This process may also include, as necessary, family meeting facilitation and participation in the family’s investment committee or providing next generation education and guidance. However, Chronos does not provide legal services. 7. Lifestyle Planning: Chronos can help with creation and on-going monitoring of a customized, goals-based financial plan, including capital sufficiency analysis, assistance with the acquisition and financing of lifestyle assets, and certain banking and other financial services. Execute Custom Analysis/Projects Chronos may provide other services related to the evaluation and management of investment programs and strategies, as requested by a client. Such services are customized such that there is no standardized analysis or project service. These customized services may include but are certainly not limited to cash flow management and financing alternatives, among others. Section D. WRAP FEE PROGRAMS Chronos does not participate in wrap fee programs. Section E. ASSETS UNDER MANAGEMENT As of February 29, 2024, Chronos managed assets of USD 174,418,328 million in non- discretionary regulatory assets under management.