A. Description of the Advisory Firm Octavia Investments LLC is a Limited Liability Company organized in the state of Delaware. The investment advisory firm became registered in June of 2013, and the principal owner is Andre Kovensky. B. Types of Advisory Services Octavia Investments LLC (hereinafter “OI”) offers the following services to advisory clients: Investment Services OI offers clients investment portfolio strategies managed by specific OI advisors. OI creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, net worth, and risk tolerance levels). OI offers to create a detailed financial plan for each client in order to guide the construction of an investment portfolio. OI then recommends allocations across the different investment portfolio strategies based on the individual goals, objectives, time horizon, and risk tolerance of each client. OI offers the same investment portfolio strategies to all of its clients and then recommends varying allocations across such strategies based on a client’s specific situation. It is possible that none of OI’s investment portfolio strategies are in line with a potential client’s objectives, in which case such potential client is not advised to seek services from OI. OI will request discretionary authority from clients to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Services Limited to Specific Types of Investments OI generally limits its money management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, REITs, private placements, MLPs, online lending and government securities. OI may use other securities as well to help diversify a portfolio when applicable. OI may sell short securities as well as buy options. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding

your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must:
• Meet a professional standard of care when making investment recommendations (give prudent advice);
• Never put our financial interests ahead of yours when making recommendations (give loyal advice);
• Avoid misleading statements about conflicts of interest, fees, and investments;
• Follow policies and procedures designed to ensure that we give advice that is in your best interest;
• Charge no more than is reasonable for our services; and
• Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions OI offers the same suite of services to all its clients. However, specific client portfolio construction is dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, net worth, and risk tolerance levels) and is used to construct a client specific portfolio allocation across OI’s investment portfolio strategies that matches client objectives. Clients may not impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. OI does not participate in any wrap fee programs. E. Amounts Under Management Discretionary assets under management are approximately $122.4 million as of May 31, 2023. Non-discretionary assets under management are approximately $3.8 million as of May 31, 2023.