____________________________________________________________________________________________________ Overview BBVA Global Wealth Advisors, Inc. (“GWA” or “the Adviser”) was founded in 2023 and incorporated in Delaware. The Firm, whose principal office and place of business is located at 501 Brickell Key Drive, Suite 601, Miami, Florida, is an investment adviser registered with the U.S. Securities and Exchange Commission ("SEC") under the Investment Advisers Act of 1940, as amended ("Advisers Act"). Principal Owners GWA is a non-bank wholly owned subsidiary of Banco Bilbao Vizcaya Argentaria, S.A. (“BBVA S.A”). a publicly held global financial services institution and financial holding company, founded in Spain in 1857 and traded on the New York Stock Exchange (ticker: BBVA). BBVA S.A., one of the largest banks in Spain, owns the largest financial institution in Mexico and leading financial services franchises in South America. BBVA S.A. is also the leading shareholder in Garanti BBVA, a financial services company in Turkey, and has investment, transaction, and capital markets banking businesses in the U.S. The following paragraphs describe GWA's business practices, services, and fees. Conflicts of interest arising from the Adviser or its Associates are disclosed herein. Advisory Business As used in this Brochure, the words "we," "our," or "us" refer to GWA and the words "you," "your," and "client" refer to you as either a client or prospective client of our Firm. The term Associates refers to GWA's Supervised Persons - the Firm's Officers and Directors ("Control Persons"), employees, and the Investment Adviser Representatives of GWA ("Financial Advisors"), who are licensed as necessary for their roles and client base, supervised, and approved by GWA to provide investment advice or advisory services on behalf of the Adviser. GWA serves as a fiduciary to clients, as defined under the applicable laws and regulations. As a fiduciary, GWA upholds a duty of loyalty, fairness, and good faith towards each client and seeks to mitigate potential conflicts of interest. In providing investment advice to clients, GWA strives to act with a degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use. GWA's advisory services are made available to clients primarily through its Financial Advisors. Each advisory relationship at GWA is managed by one or more Financial Advisors registered with the Firm, who serve as the primary point of contact between GWA and the client. Financial Advisors collect financial profile and suitability information from clients and recommend specific advisory services or programs deemed appropriate after assessing the client’s situation, financial circumstances, goals, objectives and investor risk profile, among others. Financial Advisors are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Financial Advisor can or can not recommend certain services, investments, or models depending on the licenses or training obtained and can transact business or respond to inquiries only in the state(s) and locations in which they are appropriately qualified. For more information about the individual providing advisory services, clients should refer to their Financial Advisor's Form ADV 2B Brochure Supplement, a separate disclosure document offered to the client, along with this Brochure before or at the time of relationship inception. (If the client did not receive a Form ADV 2B Brochure Supplement, they should contact their Financial Advisor or GWA directly.) GWA's advisory services are designed and aimed to complement each client's specific needs, as described within its written services contracts (the "Investment Advisory Agreement," or "IAA") that disclose, in substance, the scope of service, contract term, advisory fee, formula for computing the fee, and type of authority granted to GWA. Final advisory fee structures are documented within the written IAA. Financial Advisors are restricted to providing the services and fees specified within each IAA, subject to the client's listed objectives, limitations, and restrictions. IAAs must be completed and executed to engage in GWA's advisory services. Clients can engage GWA for additional services at any time. (Please refer to Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management style.) Once established, no Investment Advisory Agreement can be assigned - within the meaning of the Advisers Act - by the Adviser without the client's consent as set forth in the Investment Advisory Agreement. (Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Advisers Act shall not be considered an assignment.) Non-Exclusive Relationship GWA's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client's specific financial situation. Accordingly, since investment strategies and advice are custom-tailored based on each client's specific financial situation, the advice we provide to one client can differ or conflict with that provided for the same security or investment for another. (See Item 8: Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) Other Professional Service Provider Recommendations GWA can recommend the services of other professionals for implementation purposes. These professionals, who can be lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. We do not receive referral fees for such recommendations, and clients are under no obligation to engage in any recommended professional services. Clients wishing to engage in such services will execute a separate agreement by and between the client and their selected referred professional(s). Unless disclosed otherwise, GWA is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any referred GWA client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider's separate contract, including fees and charges and for those charges when assessed, should they choose to engage the referred professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from GWA. If conflicts of interest related to recommendations of other professionals arise in the future, we will disclose them to you. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities GWA's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills their responsibilities under their IAA. Financial Advisors will rely upon the accuracy of information furnished by the client or on their behalf without further investigation. GWA will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify GWA in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if earlier disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their IAA or our authority thereunder. GWA reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, provide proper financial advice. Following is a summary description of advisory services covered by this Brochure. Clients should consult with their Financial Advisor and the applicable IAA and Fee Schedules for additional information regarding each service. Description of Advisory Services GWA is an investment advisory firm; it does not sell securities on a commission basis. Our Financial Advisors emphasize client contact and interaction in providing the following individually tailored investment advice and advisory services:
• Portfolio Management Services
• Wrap Fee Program Services* *The BBVA Global Wealth Advisors, Inc. Wrap Fee Program is offered to prospective and existing advisory clients with the option to make investment advisory services and transaction/commission costs available via a single fee in conjunction with GWA as Wrap Fee Program Manager and Sponsor for this Program. Please see GWA's Form ADV Part 2A Appendix 1 - Wrap Fee Brochure for complete details. Portfolio Management Services With GWA's Portfolio Management Services, Financial Advisors will collect financial profile information from clients at the onset of the advisory relationship through personal discussions and the use of diagnostic questionnaires designed to help the Financial Advisor assess the client's objectives and determine their risk tolerance to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with agreed-upon realistic and measurable goals set based on the disclosed information. According to the selected service(s), the client's written IAA will document the details of the advisory relationship and final advisory fee structure. GWA’s advisory services include recommending and analyzing investments, discussing market trends, and providing guidance with respect to investment product alternatives. Clients can evaluate specific trade ideas with their Financial Advisor and can trade individual stocks, ETFs, structured notes, bonds, and funds, among others, with the assistance of GWA’s Investment Team. Investment advice is provided on a non-discretionary basis, meaning the client retains the final decision-making authority for each trade or investment decision in the account. If a client elects to participate in GWA’s exclusively non-discretionary services, our representatives must obtain client approval prior to executing any transactions on behalf of the client’s account. Clients retain the unrestricted right to decline any advice provided by GWA on a non-discretionary basis. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss, and Item 16: Investment Discretion for additional details.) In connection with determining investments suited to a client's risk profile, GWA's Investment Team leverages investment analysis conducted by BBVA S.A.'s fund research team and reviews Investment Guides ("BBVA Investment Guides") developed by BBVA S.A.'s Global Wealth Investment Committee ("GWIC"), of which our Chief Investment Officer is a voting member. GWIC uses well-established investment principles and investment methodologies to develop the BBVA Investment Guides, which establish asset allocation target ranges for general client risk profiles. Typically drawing from the BBVA Investment Guides recommended by GWIC and/or other third-party information, our Investment Team develops specific asset allocation recommendations for our clients ("GWA Investment Guides"), which are subject to the review and approval of GWA's Investment and Product Committee ("GWA IPC"). (See “Types of Investments” below for additional information on the investment products used in client portfolios.) GWA does not provide advice with respect to the use of margin or securities lending. However, our advisory services are non- discretionary, and our clients can independently decide to enter into agreements with their Custodians related to using margin (i.e., leverage) in their accounts. In such cases, the Financial Advisor can facilitate the client's interaction with the Custodian for the purposes of margin investing. GWA’s Financial Advisors are not legal, estate planning or tax accounting professionals; neither GWA nor any of its Financial Advisors provide legal, estate planning, or tax advice. Clients should consult their own legal, estate planning, tax accounting and other professional advisers before implementing any investment strategy their Financial Advisor recommends. Investor Profile Through a collaborative process with each client, GWA will create an Investor Risk Profile (“IRP” or “Profile”), which will be used to determine the appropriate investment mix for the client. Financial Advisors will confer with the client periodically to review the client's investment objectives and investment mix and make a reasonable effort to confirm or update the written client information to keep the data current no less than annually. The

IRP is created using a combination of the client's responses to a questionnaire designed to help determine investment horizon, goals, expertise, risk tolerance and other relevant information gathered through personal client discussions and the overall client relationship, including but not limited to cash flow and liquidity requirements, risk management, and other factors significant to the client’s financial situation. Other financial areas of concern can also be discussed upon client request and as necessary. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. The information clients supply will become the basis for a strategic asset allocation plan designed to assist the client in striving to meet their expressed personal short and long-term financial goals and objectives. Based on the data gathered, the client's questionnaire replies, and the set of guidelines established by GWA, the client will be classified into one of the following four Profiles: 1. Conservative Risk Profile – Investor with a low-risk tolerance looking for capital preservation at the end of a defined investment period. 2. Moderate Risk Profile – Investor with a moderate risk tolerance, looking to grow capital above the inflation rate in the long term. Willing to invest a moderate percentage of assets in US and non-US equities and accept a moderate amount of volatility. 3. Moderately Aggressive Risk Profile – Investor with a higher risk tolerance, willing to invest a higher percentage of assets in US and non-US equities and riskier securities. Looking to enhance returns and willing to accept a higher level of volatility. Even though the foundation of the portfolio construction process for Moderately Aggressive investors generally takes a long-term approach, shorter-term goals might have a higher priority in this portfolio. 4. Aggressive Risk Profile – Investor with a very high-risk tolerance, willing to invest an even higher percentage of assets in US and non-US equities and riskier securities. Looking to maximize returns and willing to accept a significantly higher level of volatility. Even though the foundation of the portfolio construction process for Aggressive investors generally takes a long-term approach, shorter-term goals might have an even higher priority in this portfolio. Portfolio Construction Each client IRP typically maps to an Investment Guide approved by GWA IPC. GWA's Investment Guides represent recommended asset allocation strategies tailored for various IRPs. The GWA Investment Guides are constructed at an asset class level following a disciplined process that forecasts the expected return of different asset classes at a macro level, taking into consideration the historical risk and return of such asset classes. The GWA Investment Guides incorporate strategic (long- term) and tactical (short-term) components. The overarching principles of the GWA Investment Guide development process are as follows:
• asset selection, liquidity, and risk tolerance are key considerations when constructing asset allocation guidelines for a given IRP,
• diversification is necessary and fundamental to navigate and soften volatility; concentration could increase risk and volatility,
• valuations become increasingly more relevant over a longer investment period, and
• a disciplined allocation process can steer an investor away from making decisions based on emotional biases. When determining the Investment Solution appropriate for a particular client risk profile, as previously noted, GWA analyzes various products before recommending to its clients a customized portfolio appropriate for each client's IRP and in accordance with the client's risk tolerances and investment objectives. Client portfolios are reviewed through an ongoing process of assessing client objectives, developing an appropriate asset allocation that seeks to achieve those objectives, and modifying that allocation as necessary to address risks and opportunities. Client Tailored Services GWA offers the same suite of services to all its clients. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at GWA’s discretion, as detailed herein and defined in each client's written IAA. (For more information, see Item 5: Fees & Compensation.) Client Imposed Restrictions Clients can, at any time, impose restrictions on investing in particular securities or security types according to their preferences, values, or beliefs. Such restrictions must be submitted to GWA in writing. Clients can also amend/change such limitations by once again providing written instructions. Reasonable efforts are made to comply with client investment guidelines, including any client's reasonable limits by standard industry practices. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similar account without restrictions. It is important to note that client-imposed restrictions within their account and variations could result in positive or negative performance differences for the account compared to accounts without such restrictions. The restrictions can also potentially prevent achieving a client's specific goals. Upon receiving a client's written restrictions, GWA will discuss the restriction request's feasibility to confirm expectations are met and verify the client's acknowledgment and understanding of the imposed restriction's possible outcomes. GWA reserves the right to either reject client-imposed restrictions or end the client relationship. Client-imposed restrictions will not be effective unless accepted by GWA in writing. In no event, regardless of the advisory service provided, is GWA obligated to make any investment or enter any transaction it believes in good faith would violate any federal or state law or regulation. Wrap Fee Program Services Under our Wrap Fee Program Services, GWA is the Sponsor and investment adviser of the GWA Portfolio Adviser Program (the "Wrap Fee Program" or “Program”), a bundled asset-based fee Program that differs from a regular advisory services account in that clients receive both investment advisory services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee" or "Wrap Fee") regardless of the number of trades completed by a client. The assets in each Wrap Fee Program are regularly monitored, with investment strategy purchase and sale transactions based on the client's specific needs and investment goals. Wrap Fee Program clients will undergo the same collection of client profile information and analysis as indicated in the preceding section and enter into a separate IAA to participate in the Program that sets forth the terms and conditions of the engagement, describes the scope of the services to be provided, fees to be paid, and type of authority granted to GWA. Final advisory fee structures are documented within the written IAA. Clients will then invest in the Wrap Fee Program by establishing one or more accounts with the Wrap Fee Program's Qualified Custodian. Generally, clients participating in this type of Program will pay the Wrap Fee to the Program sponsor quarterly in arrears, based on a percentage of assets under management. With the client’s written permission, the Custodian will debit this payment from the client’s account. GWA passes on a portion of the Wrap Fee to the Broker-Dealer partner of the program for its services (e.g., execution of securities brokerage transactions) and retains a portion of the Wrap Fee for the advisory services it provides. The overall costs clients will incur if they participate in our Wrap Fee Programs can be higher or lower than they could incur by separately purchasing the types of securities available in the Program. Clients should be aware that a conflict of interest exists whenever GWA recommends participating in its Wrap Fee Program. Because the Wrap Fee Program has a higher fee, Financial Advisors have a slight incentive to offer it over a non-wrap fee program, so they could be financially incentivized to recommend such a service. The SEC rules require that a Wrap Fee Brochure be provided to clients before or when entering a Wrap Fee Program Agreement. GWA has prepared a Wrap Fee Brochure that provides clients with important information about our Program, including further information about the services and fees participating clients will pay. (Please see GWA's Form ADV Part 2A Appendix 1 - Wrap Fee Program Brochure for complete details on this advisory service offering.) Types of Investments GWA's investment advisory services are designed to accommodate a wide range of investment philosophies and objectives. We primarily offer advice on the products selected by the GWA IPC after careful analysis - specific mutual funds, exchange- traded funds ("ETFs"), equities, fixed-income investments, structured products (including structured notes), pooled investment vehicles, including but not limited to funds established in accordance with the European Union's Undertaking for Collective Investment in Transferable Securities Directive ("UCITS"), and alternative investments (collectively, the "Investment Solutions") that can be recommended to our clients. The GWA IPC uses research prepared by BBVA S.A. and third parties when selecting our Investment Solutions. The GWA Investment Guide for a client, together with the Investment Solutions recommended to and approved by the client, are collectively referred to as the client's Investment Portfolio. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss for additional information.) When selecting mutual funds, ETFs, and pooled investment vehicles for client recommendations, GWA's Investment Team primarily draws on the research of BBVA S.A.'s fund research team, which develops and publishes research on a large universe of funds representing various investment styles and categories. Based on its analysis of the various funds, ETFs, and pooled investment vehicles covered by BBVA S.A.'s fund research team, the GWA Investment Team selects and highlights what they deem the most appropriate alternatives within each asset class and for each client risk profile, which are then recommended to the GWA IPC for review. The GWA IPC reviews the GWA Investment Team's recommendations and selects funds, ETFs, and pooled investment vehicles for potential inclusion on GWA's list of Investment Solutions. We can also advise on any investment held in the client’s portfolio at the inception of the advisory relationship. Although GWA provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives and will use other securities to help diversify a portfolio when appropriate. Before acting on any analysis, advice, or recommendation, GWA recommends prospective investors consult with their legal counsel, tax, and other financial investment professionals, as necessary, to aid in due diligence as proper for their situation and determine the suitability of the risk associated with any investment. (For additional information on investment considerations, see Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss.) Conflicts of Interest Clients should be aware that the specific advisory services selected and the compensation to GWA and their Financial Advisor will differ according to the exact service chosen. The compensation we receive can be greater than the amounts otherwise received had the client participated in another service or paid separately for investment advice, brokerage, or other relevant services. Due to the differences in fee schedules among the various advisory programs and services offered by GWA and the client’s Financial Advisor, a conflict of interest exists when there is a financial incentive to recommend a particular service over others. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same services purchased separately include, but are not limited to, the type and size of the account, the historical and expected size or number of trades for the account, and the number and range of supplementary advisory and client-related services provided to the account. Clients are under no obligation to act upon any recommendations or purchase any products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through GWA or any recommended third party. The client can act on recommendations received by placing their business and securities transactions with any brokerage of their choice. GWA does not represent that the products or services offered are at the lowest available cost - clients could be able to obtain the same or similar products or services at a lower price from other providers. GWA has adopted and implemented compliance policies and procedures and a Code of Ethics (“Code”) to mitigate conflicts of interest. GWA’s Code is available for review free of charge to any client or prospective client upon request. Assets Under Management As of the date of this filing, GWA does not have any regulatory assets under management. However, GWA has applied to register with the SEC in reliance on Rule 203A-2(c) under the Advisers Act because it expects to be eligible for SEC registration within 120 days of the filing date.