General Vitral Advisors, LLC (“Vitral” or the Advisor or the Firm) is a limited liability company organized in the State of Florida and registered to conduct business as a Registered Investment Adviser since June 2018. Vitral is wholly owned by Vitral Holdings Ltd. Description of Advisory Services Clients may engage Vitral to manage all or a portion of their assets on a discretionary or non- discretionary basis or to provide investment advice on a consulting non-binding basis. Vitral and its representatives provide advice that is tailored to the individual needs of the client based on the financial information and the investment objective(s) communicated by the client. Clients may impose restrictions on investing in certain securities or groups of securities by notifying the firm or representative in writing. The Adviser’s investment management services include the design, structure, and implementation of various personalized investment strategies for managed discretionary and non-discretionary accounts (the “Accounts”). Investment activities are focused on investments to various kinds of assets classes and securities in a variety of markets that are intended to fit within the client’s investment objectives, investment strategies and risk tolerance profile as described by each client. The overall advisory services offered by Vitral fall within the following categories:  Customized Discretionary Portfolios Adviser offers discretionary Customized Separately Managed Accounts (CMA) that are customized to each client. CMA may focus on investments in specified and/or limited types of assets and securities, in limited markets, or they may be broad-based across many asset classes and markets. Such accounts are intended to fit within the investor’s objectives, strategies and risk profile as described by each client. The strategies utilized for these customized accounts may be similar to or may vary widely from the core strategies typically utilized by the Adviser, as further described in this Brochure or customized for each client based upon variety of factors. Clients may place targets on these accounts and may restrict the types of financial instruments traded in such accounts. Vitral tailors’ investment advisory services to the individual needs of the client. The goals and objectives for each client are documented via new account documentation. Client Profiles are created that reflect the stated goals and objective. Vitral’s clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to Vitral in writing.  Other Non-Discretionary Advisory Services Adviser provides non-discretionary advisory services to the types of clients described in this Brochure in accordance with a non-discretionary advisory agreement between Adviser and the client. Each agreement typically defines the scope and terms of services to be provided and fees and other charges these services might be subject to. Adviser also may provide recommendations and research in connection to the client’s investment objective and risk tolerance. These services are individually tailored to each client’s needs and such advice may be provided to accounts with assets maintained by various third parties.  Family

Office Services The Adviser offers family office investment advisory services. Such services include but are not limited to furnishing advice to clients on matters not involving securities, such as financial planning matters, retirement planning, real estate planning, trust services that often include estate planning and educational services. The Adviser also may provide personalized confidential financial planning, investment management and financial advisory, as well as family office services to individuals, corporations, trusts, and charitable organizations. Advice is provided through consultation with the client and may include determination of financial objectives, identification of financial problems, cash flow management, insurance review, investment management, education funding, retirement planning, estate planning, real estate analysis and educational services.  Other Services Adviser from time to time may provide additional services to clients as might be agreed between the client and the Adviser. Regulatory Assets Under Management As of December 31, 2023, Vitral maintained approximately $79,370,018.83 of regulatory assets under management on a non-discretionary basis and approximately $38,443,097.47 of regulatory assets under management on a discretionary basis as of December 31, 2023. Additional General Information Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended to clients or engaged directly by the client on an as-needed basis. Conflicts of interest related to recommendations of other professionals will be disclosed to the client in the event they may occur. Vitral may recommend that clients authorize the active discretionary management of all or a portion of their assets by and/or among certain Independent Money Managers (“IMM”), based on the stated investment objectives of the client or upon the client's request. The terms and conditions under which the client engages the IMM are set forth in a separate written agreement between the client and the designated IMM. Vitral provides the service of selecting or recommending the IMM. Vitral also periodically monitors and reviews the account performance and the client's investment objectives. Vitral receives an advisory fee which is based on a percentage of the market value of the assets being managed, including assets being managed by the IMM. Clients should be aware that non-U.S. IMM’s who serve only non-U.S. clients may not be registered in the United States, with the U.S. Securities and Exchange Commission or any State; depending on the laws of their home jurisdictions, they may be registered in their home jurisdictions. In addition to Vitral's Brochure, the client also receives the Brochure or other disclosure documents, if applicable, from the IMM’s. Fees charged by the broker-dealer/custodian of the client's assets are exclusive of, and in addition to, Vitral's investment advisory fee, and the client may incur additional fees beyond those charged by Vitral and the broker-dealer/custodian. Vitral investment advisory agreements may not be assigned without client consent. Participation or Offering Wrap Fee Programs Vitral does not participate in or offers participation in any Wrap Fee Program currently.