Spectra Investment Management, LLC (hereinafter “Spectra”) is a registered investment advisor based in Stuart, Florida with a second office location in West Palm Beach, FL. We are a limited liability company, organized under the laws of the State of Delaware. We have been providing investment advisory services since 2017. We serve high-net worth clients, families and their related entities. On a limited basis, we may provide portfolio management services or investment consulting services to businesses and non-profit entities. Amount of Supervised Assets As of March 19, 2024, the following represents the amount of Spectra’s clients’ assets under management on a discretionary and non-discretionary basis: Discretionary: $207,449,419 Non-Discretionary: $12,529,181 Total: $219,978,600 Spectra also receives compensation for directing the asset allocation and investment selection of investible assets and advising on illiquid assets and wealth transfer strategies on an additional $119,389,891 of client assets. Scott Alan Roads is the majority owner and Managing Member of Spectra. Julia Elizabeth Zaino is a minority owner, Member and the Chief Compliance Officer. Spectra is headquartered in Stuart, Florida at 401 SE Osceola Street, Suite 202, Stuart, Florida and has a second office location in West Palm Beach, FL at 501 Palm Street, Suite B-6, West Palm Beach, Florida. You may see the term Associated Person throughout this Brochure. As used in this Brochure, this term refers to anyone from our firm who is an officer, employee, and all individuals providing investment advice on behalf of our firm. Where required, such persons are properly registered as investment advisor representatives. Currently, we offer the following investment advisory services, personalized to each Client:
• Portfolio Management Services
• Family Office Services
• Financial Planning Services
• Investment Consulting Services
• Outsourced Chief Investment Officer Services 5 | Form ADV Part 2A: Firm Brochure Portfolio Management Services Our firm offers continuous discretionary and, in limited cases, non-discretionary portfolio management services. Discretionary portfolio management means we will make investment decisions and place buy or sell orders in your account without contacting you. These decisions are made based upon your stated investment objectives. You may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Non-discretionary portfolio management service means that we must obtain your approval prior to making any transactions in your account. Our investment advice is tailored to meet your needs and investment objectives. If you decide to hire our firm to manage your portfolio, we will meet with you to gather your financial information, determine your goals, and decide how much risk you should take in your investments. The information we gather will help us implement an asset allocation strategy that will be specific to your goals, whether we are actively investing for you with discretionary management or providing you with non-discretionary investment advice. Spectra mainly uses equity securities, exchange traded funds, mutual funds, U.S. government securities, corporate debt securities, municipal securities, and options strategies in its portfolio management programs. We may also recommend investments in private limited partnerships such as hedge funds and private equity. Hedge funds and private equity investments involve risk of loss and are often illiquid. These private partnership interests, commonly referred to generically as private equity, may be composed of equity, debt, venture capital or real estate. Because some types investments involve certain additional degrees of risk they will only be implemented/recommended when suitable with the client's stated investment objectives, tolerance for risk, and tolerance for illiquidity. Family Office Services Spectra may be asked to review, coordinate or source certain wealth management and lifestyle services. Spectra does not charge a separate fee for these services and will be handled on a case-by-case basis to be a helpful resource to our clients. These services are not a core function of our business and involve idiosyncratic risks to the client and to Spectra. These services will be handled with professional care and fiduciary judgement. Some of these products and services include:
• Review, coordinate or source wealth, asset and business management services and services of banks, trust departments, brokers, asset managers, insurance, accountants, lawyers, property managers and construction services.
• Bill payment with standing letters of authorization.
• Aggregate and report on non-discretionary financial, non-financial and illiquid assets using technology with direct data feeds to custodians or by other means of asset data entry.
• Coordinate tax reporting with CPA firms, coordinate commercial real estate activity, coordinate and source charitable vehicles and entities, reconcile ad-hoc client requested financial activities.
• Provide ongoing financial education to second and third generation family members. 6 | Form ADV Part 2A: Firm Brochure
• Review, coordinate or source lifestyle services for private travel, yacht acquisition and management, collectables, personal and cyber security and real estate acquisition and management related to primary and secondary residence(s), ranch(s), hanger(s), dock(s). Financial Planning Services We offer various financial planning related services, which assist some, but not all, Clients in the management of their financial resources. Financial planning services are based upon an analysis of your individual needs and begin with one or more information gathering consultations. Once we collect and analyze all documentation gathered during these consultations, we provide a written financial plan designed to achieve your financial goals and objectives. In this way, Spectra assists you in developing a strategy for the successful management of income, assets, and liabilities. In general, financial planning services may include any one or all of the following:
• Cash Flow Analysis – Assessment of your present financial situation by collecting information regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans, employee benefit statements etc. The firm advises on ways to reduce risk, coordinate, and organize records, or estate information.
• Retirement Analysis – Identification

of your long-term financial and personal goals and objectives including advice for accumulating wealth for retirement income or appropriate distribution of assets following retirement. Tax consequences and implications are identified and evaluated.
• Insurance Analysis – Spectra does not analyze or recommend insurance programs or policies. Insurance policies and placement are a highly specialized financial planning field that requires a dedicated insurance specialist who can gauge the quality and pricing of insurance policies and carriers.
• Portfolio Analysis/Investment Planning – We provide investment analysis, including asset allocation, and effect on your portfolio. We evaluate economic and tax characteristics of existing investments as well as their suitability for your objectives. We identify and evaluate tax consequences and their implications.
• Education Savings Analysis – Alternatives and strategies with respect to the complete or partial funding of college or other post-secondary education.
• Estate Analysis – Spectra does not practice law or prepare tax returns. Because many of the clients we serve have taxable estates, we strongly believe estate analysis should involve the expertise of an experienced trust, estate, or tax lawyer. The recommendations and solutions are designed to achieve your desired goals, subject to periodic evaluation of the financial plan, which may require revision to meet changing circumstances. Financial plans are based on your financial situation based on the information provided to the firm. We should be notified promptly of any change to your financial situation, goals, objectives, or needs. 7 | Form ADV Part 2A: Firm Brochure You can also request financial planning or investment consulting services that cover a specific area, such as retirement or estate planning, asset allocation analysis, manager due diligence and 401(k) platform due diligence. We offer consultative services where we set an appointment to meet with you for financial planning advice for an hourly fee. You may choose to accept or reject our recommendations. If you decide to proceed with our recommendations, you may do so either through our investment advisory services or by using the advisory, brokerage, or insurance provider of your choice. Investment Consulting Services Spectra provides several investment consulting services on a stand-alone basis or in combination with other services. While the primary Clients for these services will be businesses, individuals, trusts, estates, donor advised funds and charitable organizations, Spectra will also offer these services, where appropriate, to pension, profit sharing, 401(k) and 403(b) plans. Investment consulting services are generally comprised of four distinct services. Clients may choose to use any or all of these services.
• Investment Policy Statement Preparation (hereinafter referred to as ''IPS''): Spectra will meet with the Client (in person or over the telephone) to determine an appropriate investment strategy that reflects the Client’s stated investment objectives for management of the overall portfolio. Spectra then prepares a written IPS detailing those needs and goals, including an encompassing policy under which these goals are to be achieved. The IPS also lists the criteria for selection of investment vehicles as well as the procedures and timing interval for monitoring of investment performance.
• Selection of Investment Vehicles: Spectra will review various investment vehicles or portfolios of equity securities, exchange traded funds, mutual funds, U.S. government securities, corporate debt securities, and municipal securities in its portfolio management programs. We may also evaluate or recommend investments in limited partnerships such as hedge funds and private equity. Hedge funds and private equity investments involve risk of loss and are often illiquid. Private partnership interests, commonly referred to generically as private equity, may be composed of equity, debt, venture capital or real estate. The number of investments to be recommended will be determined on a case by case basis considering the Client’s preferences and total portfolio.
• Monitoring of Investment Performance: If specified in the Investment Consulting Services agreement, Client portfolios can be monitored continuously based on the procedures and timing intervals outlined in the Investment Policy Statement. Although Spectra will not be involved in any way in the purchase or sale of these investments, Spectra will supervise the Client's portfolio and will make recommendations to the Client as market factors and the Client's needs dictate. Spectra provides limited scope investment advisory services to 401(k), 457(b), and 403(b) retirement plans. The scope of investment consulting services we provide to these retirement plans is limited to the evaluation of mutual fund performance, participant choices, pricing, and testing for retirement plan conflicts of interest. Working together with the plan sponsor’s attorney, Spectra provides independent investment expertise to plan decision makers but not to individual account participants. 8 | Form ADV Part 2A: Firm Brochure All of our investment consulting services, whether general or customized, will be outlined in a written agreement that shows the services that will be provided and the fees that will be charged for those services. Outsourced Chief Investment Officer Services Spectra’s Outsourced CIO Services (OCIO) is a hybrid of discretionary asset management and non- discretionary investment consulting. Each of the service engagements is customized with the scope of services outlined in a customized written agreement. Under this arrangement, Spectra works with individuals, entities or committees to set appropriate investment policy, portfolio construction, trading, and administrative functions. Spectra’s Outsourced CIO Services are most suitable for ultra-high-net-worth clients seeking a comprehensive investment management framework. OCIO services may include:
• Determination of goals, investment beliefs and preferences expressed in the Investment Policy Statement.
• Engagement and termination of investment managers that fit or fall outside of Investment Policy Statement parameters.
• Portfolio construction based on quantitative and qualitative measures or within the parameters of the Investment Policy Statement.
• Support client’s outside legal and tax advisors with investment insights.
• Report on manager and aggregate performance, asset allocation, transactions and fees.