EuroCapital is a Registered Investment Adviser (“Adviser”) which offers investment advice, securities and other financial services to clients. We are registered through and regulated by the United States Securities and Exchange Commission (“SEC”), our primary business office is located in the state of Florida. We provide investment advice through representatives located in Latin America and Spain (“advisor”) associated with EuroCapital. These individuals are appropriately licensed, qualified, and authorized to provide advisory services in their respective markets on behalf of EuroCapital. In addition, all advisors are required to have a college degree and 10 years of international investment industry experience. EuroCapital was founded and incorporated in 2003 by Patricio Diez who serves as a Managing Director and Pablo Alonso who serves as the President of the company. We provide solutions to high net worth clients who require personalized, independent wealth management advice. We work with you to create an investment strategy that is designed to optimize the returns on your capital in a safe and efficient way. We will work together with your existing team of bank advisers, money managers, accountants, lawyers, insurance agents, etc. to help you holistically manage your wealth. We are committed to the precept that by placing the clients’ interests first, we will add value to the asset management process and earn the client’s trust and respect. We value long term relationships among our clients whom we regard as strategic partners in our business. Services EuroCapital Advisors offers two types of investment services, an Asset Management Program and an Advisory Referral Program. The Asset Management Program offers you a choice between discretionary and non-discretionary advisory services that we will perform for you. The Advisory Referral Program offers you a choice between having your investment portfolio managed entirely by a third-party advisor or having us manage certain aspects of your portfolio while the third-party advisor manages the other aspects of your investment portfolio. If you elect to have your portfolio managed on a discretionary basis, this means that you have given us or the third-party advisor the authority to determine the following without your prior authorization:
• Securities to be bought or sold for your account
• Amount of securities to be bought or sold for your account
• Broker- dealer to be used for a purchase or sale of securities for your account
• Commission rates to be paid to a broker or dealer for your securities transaction EuroCapital Advisors, INC ADV Part 2A Page 6 If you elect to have your portfolio managed on a non-discretionary basis, this means that you have not given us or the third-party advisor the authority to determine these without your prior authorization. Your account may be rebalanced or reallocated periodically in order to reestablish the targeted percentages of your initial asset allocation. This rebalancing or reallocation will occur on the schedule you have determined with us or your third party advisor. You will be responsible for any and all tax consequences resulting from any rebalancing or reallocation of the account. EuroCapital’s advisors are not tax professionals and do not give tax advice. However, we will work with your tax professional to assist you with tax planning. As of 12/31/2022, we provided asset management services for 12 accounts managing total assets of $103,264,176. Financial Advice We provide general financial advice as an incidental service as it relates to the investment management of your portfolio. In providing financial advice, we typically examine and analyze your overall financial situation, which may include such issues as overall debt, credit, business planning, retirement savings and current investment program. Our services may focus on all or only one of these services depending upon the scope of our engagement with you. 1. Asset Management Services Asset management is the professional management of securities (stocks, bonds and other securities) and assets (e.g., real estate) in order to meet specific investment goals. With an Asset Management Account, you engage us to assist you in developing a personalized asset allocation program and custom- tailored portfolio designed to meet your unique investment objectives. The recommended portfolio may include various securities such as mutual funds, exchange traded funds, debt instruments, foreign securities, municipal securities and individual equity securities. You will have the choice whether to give us discretion over the account so we can trade as we see necessary without your prior consent or non- discretionary where we will only trade with your consent. We do not have a minimum dollar amount of assets or other conditions for opening or maintaining an account. Accounts are opened and maintained in accordance with our Investment Advisory Agreement, which is the governing agreement you and your advisor complete for your account. However, our services are directed towards high net worth individuals and families with high financial investments. Accounts are typically in excess of $1 million. We offer two types of asset management services; an Asset Management Program and an Advisory Referral Program. EuroCapital Advisors, INC ADV Part 2A Page 7 a. Asset Management Program With the Asset Management Program, we can assist you in developing a personalized asset allocation program and a custom portfolio tailored to meet your unique investment objectives. We will meet with you to discuss your financial circumstances, investment goals and objectives, and to determine your risk tolerance. We will ask you to provide statements summarizing current investments, income and other earnings, recent tax returns, retirement plan information, other assets and liabilities, wills and trusts, insurance policies, and other pertinent information. Based on

the information you share with us, we will analyze your situation and recommend an appropriate asset allocation or investment strategy. Our recommendations and ongoing management is based upon your individual financial circumstances and the investment portfolio you have selected. We will monitor the account, trade as necessary, and communicate regularly with you. Your account and financial circumstances shall be monitored and discussed in quarterly and annual account reviews with you. These reviews will be conducted in person, by telephone conference, and/or via a written questionnaire. We will work with you on an ongoing basis to evaluate your asset allocation as well as rebalance your portfolio to keep it in line with your goals as necessary. In creating your customized asset allocation, certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. However, past performance is not an indication of future performance. We cannot offer you any guarantee about how your portfolio will perform. You can expect us to do the following:
• Review your present financial situation
• Monitor and track assets under management
• Provide portfolio statements, periodic rate of return reports, asset allocation statements
• Advise on asset selection
• Determine asset allocation models
• Provide research and information on performance and fund management changes
• Build a risk management profile for you
• Assist you in setting and monitoring goals and objectives
• Provide personal consultations as necessary You must notify us promptly when your financial situation, goals, objectives, or needs change. If you decide to have us implement our recommendations, we will help you open a custodial account(s). The funds in your account will generally be held in a separate account, in your name, at an independent custodian that you have selected, not at EuroCapital. We may provide assistance or suggest custodians for you to use if you need a recommendation. We will not act as custodian for the Account and will not take possession or have custody of any cash, securities or other assets. You will sign a separate custodial agreement with the custodian. This agreement, among other things, may authorize the custodian Page 8 ADV Part 2A EuroCapital Advisors, INC to take instructions from us regarding all investment decisions for your account. The custodian will complete transactions, deliver securities, make payments and do what we instruct (if discretionary management is elected). You will at all times maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. We request that you notify us when withdrawing or depositing cash and/or securities in or from your account so that we may maintain accurate recording of your account activities. You will receive, at least quarterly, a statement from your custodian containing a description of all the activity in your account, your current positions, cost basis of securities, and current market value. The statement may be in either printed or electronic form based upon your preferences. b. Advisory Referral Program With the Advisory Referral Program, you have the option to have the entire account managed by a third party money manager or you can have a third party money manager handle a portion of your portfolio and have us manage the remainder. We have access to several third-party money managers that you may use to customize your portfolio or you may use any financial professional of your choice. If you select a third party money manager, you will receive a separate Form ADV Part 2 Brochure from them discussing their fees and expenses and your relationship with them. You should read it carefully and ask us any questions you may have. The funds in your account will be held in an account, in your name, at the custodian that is used by the third party money manager, not at EuroCapital. You will still maintain full and complete ownership rights to all assets held in your account, including the right to withdraw securities or cash, proxy voting and receiving transaction confirmations. You will receive, at least quarterly, a statement from your custodian containing a description of all the activity in your account, your current positions, cost basis of securities, and current market value. The statement may be in either printed or electronic form based upon your preferences. You will enter into a separate agreement with the third party manager and the custodian. You should read all account opening paperwork and agreements carefully and ask us any questions you may have. You shall have the ability to impose reasonable restrictions on the management of your account, no matter which option you select, including the ability to instruct us not to purchase certain mutual funds, stocks or other securities. These restrictions may be a specific company security, industry sector, asset class, or any other restriction you request. Under certain conditions, securities from outside accounts maybe transferred into your advisory account. However, we may recommend that you sell any security if we believe that it is not suitable for the current recommended investment strategy. You are responsible for any taxable events in these instances. You should always consult with your tax advisor for specific tax advice. We obtain information from a wide variety of publicly available sources such as financial newspapers and magazines, annual reports, prospectuses, filings with the Securities and Exchange Commission, and research materials prepared by others to help us determine an appropriate asset allocation to Page 9 ADV Part 2A EuroCapital Advisors, INC meetyour goals and objectives. However, we do not have any inside private information about any recommendations we make.