General Advisory Investor Services LLC (AIS) is a limited liability company duly organized under the laws of the State of Florida on September 2, 2014. AIS’s members are Vicente Ferrera (CRD No. 4313925), Daniel Martinez (CRD No.5832289) and Andreina Garcia (CRD No. 6396022). From its offices in 1200 Brickell Ave. (Main Office), 1395 Brickell Ave. and Weston, Fl, AIS offers the following services to its advisory clients: Investment Advisory Services Adviser provides investment advisory services to its clients through various types of discretionary and non-discretionary accounts in accordance with each client’s investment objectives. Investment activities focus on investments in various kinds of assets and securities in a variety of markets that is intended to fit within the client’s objectives, strategies and risk profile as described by each client. AIS offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. AIS creates an Investment Policy Statement for clients, which outlines the client’s current investment profile (income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Policy Statement may include, but not limited to, the following: ▪ Investment strategy ▪ Asset allocation ▪ Risk tolerance ▪ Personal investment policy ▪ Asset selection ▪ Regular portfolio monitoring AIS evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Advisory Agreement and in some cases in the Investment Policy Statement. Accounts may focus on investments in specified and limited kinds 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 Item 8. Clients may place targets on these accounts and may restrict the types of investments made in such accounts. As an investment adviser, AIS provides portfolio management and administrative services to client accounts (the “Accounts”), including investigating, analyzing, structuring and negotiating potential P a g e | 5 investments, monitoring the performance of investments and advising the Accounts as to the disposition of investment opportunities. Adviser provides investment advisory services to Adviser’s clients through the management of investment portfolios in accordance with the objectives, guidelines and risk profiles of individual clients. Clients provide such information to Adviser at or before the time they enter into an advisory agreement with Adviser. AIS offers several specialized programs, as follows: 1. Third Party Managers Based upon the Investment Policy Statement defined for each client (as described above), the Adviser may recommend to certain clients that they authorize the active discretionary management of a portion of their assets by certain investment managers that are not affiliated with the Adviser. Adviser continues to render services to the client and, in addition, monitor and review the performance of the third-party manager and the performance of the client’s accounts that are being managed. Adviser offers a discretionary program that utilizes Envestnet Asset Management Inc.’s (“Envestnet’s”) Private Wealth Management Programs, including Separately Managed Accounts, Unified Managed Accounts and Mutual Fund Solutions (together, the “Program”) as described in Envestnet’s Form ADV Part 2A Brochure. Assets in the Program are managed on a discretionary basis by either third-party investment managers available on the Envestnet platform and selected by Adviser’s Investment Adviser Representatives or by Adviser’s representatives directly selecting mutual funds and ETFs. The overall strategy and asset allocation for Program portfolios are customized to each client. Clients who participate in the Program pay a fee, which is described in Item 5 below, to both Envestnet and to Adviser. Assets invested in the Program are custodied with Pershing Advisor Solutions and Morgan Stanley & Company LLC, which also provides brokerage services to the Program. Brokerage fees for transactions in the Program are not separately charged to clients, and third-party investment managers in the Program do not receive additional fees from Adviser’s clients. At the end of December 2022, the Firm did not have any clients participating on this program. 2. Schwab's Managed Account Services Schwab's Managed Account Services consist of the Managed Account Select® Program (the "Select Program"), the Managed Account Access Program (the "Access Program") (the Select and Access Programs are collectively referred to as the "Sponsor Programs") and other managed account services, currently Managed Account Marketplace ("Market- place"). The Managed Account Services include brokerage, custody and related services that allow our Clients to engage money managers ("Managers") to provide discretionary investment portfolio advisory services to designated accounts opened and maintained at Schwab ("Client Accounts"). In the Sponsor Programs, Schwab acts as program sponsor. In the Select Program, Schwab provides research on a select group of Managers. In the Access P a g e | 6 Program, by contrast, Schwab does not undertake to perform any screening or due diligence in the acceptance of Managers participating in that Program, and the Managers participating in the Access Program may or may not be affiliated with Schwab. The fee for Schwab's brokerage, custody, research and other services in the Sponsor Programs is bundled with the Managers' fees for their portfolio management services. Marketplace contains a more extensive list of Managers whose portfolio management services are available through Schwab. Schwab does not act as a sponsor in relation to Marketplace, and its compensation for Marketplace services is separate from the Manager's fee. Marketplace includes Managers providing separate account management services, overlay managers (for multi-strategy portfolios and unified managed accounts), Turnkey Asset Management Providers ("TAMPs") and sub-advisors to any of the foregoing that have trading authority over Client Accounts. The services of TAMPs may include separately managed accounts, multi-strategy portfolios, unified managed accounts, mutual fund wrap programs and exchange-traded fund wrap programs. 3. Multi Strategy Portfolios (“MSPs”) Clients may elect to have their assets managed through an MSP. An MSP is a discretionary account invested in several products, including but not limited to Mutual Funds, ETFs, stocks, bonds and alternative investments. Clients may select different investment portfolios from a selection that is updated regularly, each based on a particular investment objective / risk tolerance. Currently the selection of MSBs includes: P a g e | 7 MSP INCOME PORTFOLIOS: This portfolio has an emphasis on generating

current income by investing in securities with various degrees of risk of loss of principal (volatility), including bonds, equities (dividend paying stocks), mutual funds and cash equivalents. Note: depending on client personal income target, the strategy may require increasing credit risk to achieve higher target income; in this case, volatility will increase to moderate. MSP INCOME AND GROWTH PORTFOLIO: This portfolio has an emphasis on generating capital appreciation and current income by investing in securities having a combination of lower and higher degree of risk of loss of principal (medium volatility). This portfolio gives to the investor the opportunity of capitalizing on growth and income while maintain a specific level of risk (Lower / Medium / Higher) through equities, equity mutual funds, bonds, bond mutual funds, and depending on the client risk profile, alternative investments. MSP GROWTH PORTFOLIO: This portfolio has an emphasis on generating capital appreciation by investing in securities with a higher degree of risk of loss of principal. This portfolio is suitable for investor who wants to participate mostly in the global equity markets, global bond markets and alternative investments. The Advisor manages three different Growth Portfolios, with different levels of volatility, depending on the client’s profile and risk appetite. 4. Family Wealth Services As an investment adviser, AIS provides portfolio management and administrative services to our clients, including investigating, analyzing, structuring, and negotiating potential investments, monitoring the performance of investments and advising the clients as to the disposition of investment opportunities. Other Services Adviser provides investment advisory services to clients through the management of investment portfolios in accordance with the objectives, guidelines and risk profiles of the individual clients. Clients provides such information to Adviser at or before the time they enter into an advisory agreement with the Adviser. The Adviser may provide additional services to the clients. The scope of services and additional fees are negotiated individually with each client and incorporated into the Portfolio Management Agreement. Portfolio Review & Consulting Services. AIS provides clients with advice and recommendations on cash flow analysis, cash management, portfolio trading, portfolio management selection, operational and administrative support services for estate planning structures of the clients provided by a 3rd party and other investment related topics. The firm may charge either a fixed fee or an hourly fee dependent upon the scope of the assignment. AIS has signed a Memorandum of Understanding with Participant Capital INTL LLC, the General Partner of Participant Capital Growth Fund LP, a commercial real estate investment platform that P a g e | 8 allows clients to invest in commercial real estate assets through a limited partnership structure. AIS has negotiated an institutional subscription fee for the clients it may refer. AIS is not compensated in any way by the General Partner or the fund. These fees are disclosed to each client in the Offering Documents, which includes a Subscription Agreement. AIS may recommend to its clients to invest a portion of their assets in domestic commercial real estate, as part of their asset allocation, according to each client’s investment profile and risk tolerance. AIS will count any and all assets invested in domestic commercial real estate structures as part of the client’s Assets Under Management and its Advisory Fees calculations. AIS has signed a Placement Agreement with ECC Fund Manager LLC, the Manager of Emerald Creek Capital Cayman Income Fund LP, an offshore private equity fund. AIS has negotiated an institutional subscription fee for the clients it may refer. AIS is not compensated in any way by the General Partner or the fund. These fees are disclosed to each client in the Offering Documents, which includes a Subscription Agreement. AIS may recommend to its clients to invest a portion of their assets in domestic commercial real estate, as part of their asset allocation, according to each client’s investment profile and risk tolerance. AIS will count any and all assets invested in domestic commercial real estate structures as part of the client’s Assets Under Management and its Advisory Fees calculations. AIS may also refer clients to other financial services companies, including banks1, as a courtesy to the client and with no compensation from the institution. AIS does not assume any responsibilities for the products and services offered by said institutions. AIS strongly recommends clients to perform their own due diligence on these institutions before opening a new account / relationship with them. AIS maintains an agreement with R.E. Brandon & Company for the sale of Life Insurance policies to its clients. AIS may also offer Health Insurance Policies to its clients through an arrangement between United Healthcare and Andreina Garcia. AIS and/or Andreina Garcia may also use other providers if needed. AIS maintains an agreement with Trident Trust Group and its affiliates Trident Corporate Services (Bahamas), Trident Trust Company (BVI) Limited and Morning Star Holdings (Nevis). Trident operates as a trust company that offers corporate and fiduciary administration services. It provides company incorporation, trustee, authorized signatory, registered agent and office services, accounting, and director and nominee shareholder services. AIS may refer existing / prospective clients to Trident for corporate and trust services. Trident pays back AIS a rebate on the fees charged to referred clients. AIS clients are free to use any trust or corporate services firm. This arrangement creates a conflict of interest with the client as AIS has an incentive to refer clients to these companies because of the existing compensation arrangements. Additional General Information 1 Banco Popular de Puerto Rico (Miami Office), Banesco USA (Doral Office), Ocen Bank (Doral Office) and Valley National Bank (Miami, FL). P a g e | 9 Other professionals (e.g., trust companies, 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 should occur. Additionally, AIS’s client agreements may not be assigned without client consent. Investment Restrictions Adviser offers an array of services and clients can select among the services that the client and the Adviser feel are suited for the client. Clients may impose reasonable restrictions on the management of their accounts, including by restricting particular securities or types of investments. Clients should be aware that performance of restricted accounts may differ from performance of accounts without such impediments, possibly producing lower overall results. Assets Under Management As of December 31, 2022 AIS, provided investment advisory services to approximately 205 clients, with a total of $166,288,353.18 in assets under management (“AUM”), with custody with Pershing Inc. (through Miura Capital, LLC), Charles Schwab, Morgan Stanley and Interactive Brokers. Approximately$163,854,865.09 are managed on a Discretionary basis.