General Davivienda Investment Advisor USA LLC, d/b/a Davivienda Advisors, a limited liability company organized under the laws of the State of Florida on March 2, 2022, is an Investment Adviser registered with the Securities and Exchange Commission (SEC). Davivienda Advisors is wholly owned by Davivienda Corredores S.A. Comisionista de Bolsa, a broker dealer incorporated in Colombia, under the supervision of the Colombian Financial Superintendence, created in 1980 and with head office in Bogotá and branches in Cali, Bucaramanga, Medellín, Cartagena and Barranquilla. For more information, we encourage you to review Part 1 of our Form ADV which is available online at www.adviserinfo.sec.gov. This brochure provides you with information regarding our qualifications, business practices, and advisory services. We recommend that you review it carefully. Description of the Wrap Fee Program Under this Wrap Fee Program, Davivienda Advisors bundles, or “wraps”, investment advisory (portfolio selection and management), execution, settlement, custody, and various administrative services together and charges a single fee. The fee is based on the value of the assets under management (“AUM”). Davivienda Advisors provides discretionary investment advisory services to clients through a digital platform by utilizing algorithms and methodologies for developing and implementing Model Portfolios (described below) with differing risk criteria. Due to the discretionary nature of the services offered, Davivienda Advisors will invest the available funds in a selected portfolio and make periodic adjustments and rebalancing transactions without asking clients for their concurrence or approval. Davivienda Advisors provides its advisory services utilizing BCP Advisors LLC (d/b/a BCP Global) as a sub-adviser and using their proprietary online and mobile platform to digitize the processes of customer onboarding (individuals), account services, investment profile assessment, portfolio recommendation, and investment management. Under our sub-advisory agreement, BCP Global is responsible for operating the platform and its related services. Davivienda Advisors will provide its clients access to the BCP Global platform via its interactive website and mobile application. BCP Global has retained the services of Interactive Brokers LLC (member FINRA/SIPC) (“Interactive Brokers” or “custodian”) for all the execution, clearing, and custody services. Clients will open cash accounts at Interactive Brokers to maintain their assets. Investment Advisory Process As a first step, clients complete an online investment profile questionnaire by answering nine questions, including, investment knowledge and experience, financial situation, relative size of the investment, access to emergency funds, investment goal or objective, investment horizon, and risk tolerance. Based on the analysis of the information provided by the client, the algorithm embedded in the platform will recommend one or more suitable investment portfolios (the “Model Portfolios”) that are designed to meet the client’s investment profile. The client will have the ability to choose \the recommended portfolio or disregard it and select another available portfolio. Clients could impose reasonable restrictions on the Model Portfolio, including the designation of particular securities or types of securities that should not be purchased or maintained for the client accounts; provided, however, that nothing herein requires that the Client has the ability to require that particular securities or types of securities be purchased for the client accounts. The algorithm considers only the information provided by the client in answering the questionnaire. Other important information, if not included in the answers to the questionnaire, will not be considered in the recommendation. Once the account has been funded and invested in the selected Model Portfolio, BCP Global will periodically rebalance the portfolio according to the recommendations of BlackRock Financial Management, Inc. (“BlackRock”), our model provider. Inflows and outflows would require buy or sell transactions to be made in adequate proportions to maintain target exposure weights. Furthermore, significant market movements may put the portfolio out of balance and require transactions to bring target exposure weights back to normal. Clients may use the online platform to request a portfolio change anytime. Davivienda Advisors, in its role as investment advisor and fiduciary, supervises and customizes the investment profile questionnaire, provides parameters for the algorithm controlling the portfolio recommendations, and monitors the investment management process, including portfolio rebalancing. Model Portfolios The Model Portfolios consist mainly of a combination of exchange-traded funds (“ETFs”) or Undertakings for Collective Investment in Transferable Securities (“UCITS”) that have been pre- selected because of their suitability to provide efficient market exposure and adequate diversification. ETFs are investment funds made up of a collection of assets, such as stocks and bonds, that are traded like individual stocks. UCITS are mutual funds registered in Europe under A unified regulatory framework that can be sold to investors worldwide. UCITS ETFs are issued under the UCITS framework, suitable for non-US customers, and usually trading in European exchanges. Each Model Portfolio has been designed to meet one or more investment goals or objectives and, in this sense, will provide an expected level of return with a corresponding level of residual (non- diversifiable) risks. This investment approach relies on the Modern Portfolio Theory (MPT) tenets. According to this theory, the optimal investment portfolio seeks to maximize returns for a certain level of residual risk. This is achieved by reducing diversifiable risks by combining asset classes and issuers with low and, in a few cases, negative correlations. The investment styles reflected in our Model Portfolios may include long-term (buy and hold) allocations which would rebalance about once per year and tactical (active) allocations which would rebalance about 4-6 times per year. The purpose of our Model Portfolios is to deliver efficiency, transparency, and cost-effectiveness. The ETFs and UCITS

(ETFs) that comprise the Model Portfolios' components aim to meet specific goals, such as broad diversification, targeted exposure, and tax efficiency. The ETF selection process uses a database of more than 300 ETFs and is primarily driven by the exposure provided and their cost and operational efficiency. More information is available under Item 6. Portfolio Manager Selection and Evaluation. Fee Schedule The management fees charged by Davivienda Advisors are established in each client’s written agreement. Davivienda Advisors bundles, or “wraps,” investment advisory, portfolio management, and most brokerage, custody, clearing, settlement, and other administrative services and charges a single fee. Management fees may be flat, fixed, or mixed upon negotiation. However, generally, and pursuant to the contract, fees for the management of accounts will be based upon a percentage of the total assets in the account. Davivienda Advisors typically charges an annual management fee as per the table below: Up to $100,000 1.60% of the AUM (Assets under Management) $100,001 to $500,000 1.40% of the AUM $500,001 to $1,000,000 1.20% of the AUM Over $1,000,000** 1.00% of the AUM **Management fees for AUM over $1,000,000 are negotiable. No management fees are assessed on zero balance accounts. The outlined management (wrap) fee pays for all Davivienda Advisors’ advisory and portfolio management services as well as Interactive Brokers’ covered brokerage services. Interactive Brokers will not charge you any fee in connection with the Program other than the specified wrap fee unless you request services beyond the covered brokerage services, which can include, without limitation, the transfer of shares from your Interactive Brokers’ account to a brokerage account not associated with the Adviser, among others. The advisory fee is automatically calculated and charged by Interactive Brokers. The calculation is made daily based on the ending market value (“EMV”) of the assets managed by the Adviser. To make the daily calculation, Interactive Brokers applies the annual agreed-upon tiered rate to the EMV and divides it by 252 business days for the year. The monthly fee charged is the sum of the daily fee calculations. The client shall pay Davivienda Advisors in arrears for services provided under the contract during each calendar month. You will grant us the authority to receive our advisory fees from your account at Interactive Brokers. Clients agree that all fees will be deducted monthly from their accounts. When services are provided for less than one calendar month, the fee will be prorated based on the number of business days for which services were provided within the month. In rare cases where the automatic fee deduction arrangement is not in place, we will bill you directly for our services. As previously mentioned, commissions charged by Interactive Brokers for trade execution will be absorbed by Davivienda Advisors. Davivienda Advisors does not charge performance-based fees, that is, advisory fees based on a share of the capital gains or appreciation of a client's assets. If Davivienda Advisors, BCP Global, or Interactive Brokers suspend all services under the Wrap Fee Program, Davivienda Advisors, at its sole discretion, will credit to your advisory account maintained at Interactive Brokers the prorated fee for the period during which all services for the account were suspended. Fees charged directly by the ETFs and UCITS Clients acknowledge that certain investments, such as the ETFs and UCITS that comprise the Portfolios, charge their own fees and/or expenses. In such cases, the deduction of the fees and expenses of the ETFs and UCITS occurs from the ETFs and UCITS’ average net assets, including the brokerage fees and other costs and charges incurred internally in the ETFs and UCITS. These fees and expenses are reflected in the price of the ETF and UCITS shares and are not separately deducted from your advisory account held with Interactive Brokers. The fees and expenses charged by the ETFs and UCITS are separate and distinct from the wrap fee for our advisory services. By participating in Davivienda Advisors’ services, clients acknowledge that they have access to information concerning the fees charged and costs incurred by each. ETF and UCITS are outlined in the applicable fact sheets available on the Davivienda Advisors’ Website and BCP Global online platform. Please note if you request the delivery of paper documents (i.e., account statements) that Davivienda Advisors or the broker/custodian provides typically in electronic format, additional fees may be assessed by Davivienda Advisors or the broker/custodian. Termination of the Agreement Either party may terminate the Investment Advisory Agreement (the “Agreement”) at any time by written notice. Termination of the Agreement will not affect (a) the validity of any actions previously taken by us under the Agreement; (b) liabilities or obligations of the parties from transactions initiated before termination of the Agreement; or (c) your obligation to pay the advisory fees (pro-rated through the date of termination). Clients may at any time elect to close the account and terminate the agreements with all entities via email at [email protected] or via a signed letter to Davivienda Advisors’ principal office address. Upon receipt of any requests to terminate the agreement and close a customer account, Davivienda Advisors through BCP Global will: ● Instruct the broker/custodian to settle any pending purchases or sales. ● Instruct the broker/custodian to initiate liquidating sales on all ETFs and UCITS shares in the account and to send the account balance, minus any portion of the wrap fee or other fees due1, to the account you have registered and instruct us to deliver the funds to. Alternatively, if a client requests to transfer the holdings in their account with us to another account in their own name and at another custodian, we will transfer the available shares if the other custodian is able to accept them. In such cases, Davivienda Advisors will instruct BCP Global to instruct Interactive Brokers to transfer the shares in accordance with the client’s instructions, minus any fees due for in-kind transfers to another custodian.