ITEM 4 ADVISORY BUSINESS London and Capital Wealth Advisers Ltd (“We”, “Us”, LCWA or the “Firm”) is a United Kingdom based wealth management company which is a wholly owned subsidiary of London and Capital Group Limited. LCWA was incorporated in 1986. Dominic Crabb, Stephen Murphy, James Hamper, Guy McGlashan, Pau Morilla-Giner, Robert Paul and Iain Tait are all Directors of LCWA. LCWA is a private limited company incorporated in England & Wales (Company No 02080604) and is a registered investment adviser with the US Securities and Exchange Commission (“SEC”) under reference 801- 63787. Registration with the SEC does not imply a certain level of skill or training. LCWA is also authorized and regulated by the UK Financial Conduct Authority (the “FCA”) (Firm Registration Number 120776).
LCWA provides discretionary and advisory investment management services to a broad spectrum of clients including those who have a connection to the United States of America (“US”). The range of clients include individuals, corporations, pension and profit sharing plans, pooled investment vehicles, trusts, estates, captive insurers and charitable organizations.
In providing investment advice to its clients, LCWA consults with London and Capital Asset Management Ltd. (“LCAM”), an investment adviser located in the United Kingdom and an affiliate of LCWA, in developing investment recommendations that adhere to the intent of the client’s investment objectives.
LCWA can offer both tailored and model based investment services, subject to a client’s criteria. Each client is required to enter into a separate agreement with an acceptable Custodian to provide clients with (amongst other things) custody, execution and trade settlement services. Clients will provide a limited

Power of Attorney to LCWA to allow the custodial account to be managed by LCWA.
LCWA’s model based investment service enables a client to invest into a risk rated model portfolio, ranging from low risk to high risk. All of LCWA’s models are managed on a discretionary basis and we carefully select suitable assets relevant to the model’s investment and risk strategy. Owing to their nature, it is not possible for a client to impose certain security restrictions for a model based service.
LCWA also offers a tailored investment service which can be managed on a discretionary or advisory basis. The tailored service allows for a client to impose investment restrictions Representatives of LCWA will consult with the client, and/or the client’s representatives, to obtain detailed financial information and other pertinent data to enable LCWA to identify a strategic asset allocation plan that is consistent with the investment objectives of the client. In all instances sufficient information is gathered which enables us to establish an investment strategy that considers a client’s investment objectives, attitude to risk, investment experience and financial circumstances. Subsequently an Investment Policy Statement (IPS) is proposed which will act as a mutual agreement between the client and LCWA regarding the circumstances, objectives and constraints that governs how we will manage the account.
LCWA will continuously monitor the portfolio for performance and compliance with the IPS and will meet with the client on a regular basis, or as determined by the client, to review the account.
As of September 30th, LCWA managed $2.3965 billion of assets on behalf of approximately 970 clients. LCWA does not manage any client assets on a non-discretionary basis.