Firm Description INTERNATIONAL MANAGEMENT ADVISORS, LTD. (“IMA” or “The Firm”) was founded in 2006. IMA is a registered investment adviser that provides discretionary investment management, personalized financial planning, and related advisory services to individual clients. Our financial services are provided through direct and written consultation with each client. Our investment recommendations are not limited to any specific product or service offered by any single broker-dealer, company, or institution and may include advice regarding the following types of securities:
• Exchange-listed securities
• Corporate debt securities (other than commercial paper)
• Commercial paper
• Certificates of deposit
• Municipal securities
• Mutual fund shares
• Structured Notes
• United States governmental securities Because different types of investments involve varying degrees of risk, they will only be recommended when consistent with the client’s investment objectives, risk tolerance, liquidity as well as other suitability factors. -5- IMA also offers financial planning services, tax planning, tax preparation services, bookkeeping, bill payment, accounting, and other financial services. These services are highly personalized and the specific services made available to each client vary based on individual client requests. Financial Planning is a comprehensive evaluation of a client's current and projected future financial position by using currently known variables to predict future cash flows, asset values and withdrawal plans. Clients retaining this service usually receive a written report which provides the client with a detailed statement of Net Worth, Cash Flow, and tax projections, although the specific schedules prepared may vary from client to client based on individual circumstances or the availability of information. IMA is not a public accounting firm. Generally, the financial services made available to a client by IMA may include any or all of the following areas:
• Personal: We review the client's current personal status. We gather financial records and contracts. We produce a Statement of current financial position or Net Worth.
• Tax: We arrange for the preparation of our client’s U.S. Federal, State and local tax returns through third party Certified Public Accounting Firms. We provide these preparers with information provided by the client and information obtained by us through the other services that we provide. We may assist our clients in retaining (at the client’s expense), foreign lawyers and/or professional accounting firms or we may work with the clients existing foreign lawyers, tax preparer or professional firms. These firms may make recommendations, regarding general legal matters and provide tax planning or tax preparation services. We accept no liability with respect to the plans or recommendations made or services provided by U.S. or foreign legal, accounting or tax preparation firms.
• Tax Projections: We may prepare tax projections in order to identify tax and retirement planning opportunities as part of our overall cash flow forecasting and planning.
• Investments: We analyze investment alternatives and their effect on the client’s portfolio. Portfolios are managed on a discretionary basis.
• Insurance: We provide administrative assistance in obtaining insurance coverages as specifically requested by our clients. We assist our clients with administrative matters related to insurance and provide information requested by insurance companies and their agents seeking to place coverage for our clients. We may assist clients in the completion of requests for forms and information, but we cannot provide detailed medical information or obtain reports without the cooperation and direction from our client. IMA does not assume responsibility for evaluating the need for any type of insurance coverage or policy including disability insurance

and does not provide assurance that any coverage obtained is adequate. We urge all of our clients to consider their need for medical, disability and life insurance and remain available to assist them or their agents as requested in this regard.
• Retirement: We analyze current strategies, retirement account balances, investments and allocations to assist our clients in reaching their retirement goals. We set up appropriate retirement accounts as part of our overall tax, retirement and financial planning services. We urge our clients to consider whether their current levels of discretionary spending and their long term financial and retirement goals are compatible. -7- Estate: We assist our clients in assessing their needs and developing strategies including, as appropriate, trusts, wills and marital agreements. Our efforts are directed toward assisting and encouraging our clients in gathering the information required to address these matters directly with his or her attorney. We gather the information required to develop a financial plan through in- depth meetings and discussions with our clients and through information obtained by us in providing other financial services that may be requested by our clients. Information gathered includes the client’s current financial position, tax status, future goals, return objectives and attitude towards risk. Implementation of our financial planning recommendations is entirely at the client’s discretion and all financial services are available to our clients on an "as requested" basis. Principal Owners Kurt J. Schoeppler is the 100% direct owner of International Management Advisors, Ltd. (IMA). Amount of Managed Assets IMA presently manages approximately $107,332,921 of client investment assets on a discretionary basis as of December 31, 2023. IMA Agreements IMA enters into two types of agreements with its clients. The "Investment Management Agreement" covers investment management services and clients with this type of agreement receive investment management services only. IMA also enters into "Financial Services Agreements" with clients who have contracted with IMA for other financial services. IMA charges for these services on a "flat fee" or percentage of gross receipts basis. IMA is not obligated to provide financial services to clients without current financial service agreements or to clients who are not currently paying fees for these services. Financial Services Agreement The Financial Services Agreement with each client outlines the terms and conditions of our agreement. The Financial Services Agreement covers the scope of the financial planning and other financial services made available by IMA to its clients on an “as requested basis.” The agreement also outlines fees charged, fee arrangements, and the term of the agreement. These agreements include a limitation of IMA's liability for any and all services required. The Financial Services Agreement may include investment management services and outline the additional fees charged for this service or, IMA may have a separate Investment Management Agreement. Any limitation of IMA's liability included in the Financial Services Agreement will apply to investment management services only to the extent that the limitation does not affect any client’s right to recovery under State and Federal Securities Law. The limitation of IMA’s liability included in these agreements otherwise applies fully to any other financial services made available by IMA. IMA is not a CPA firm. Investment Management Agreement IMA manages client investment accounts on a discretionary basis. Our fees for investment management are outlined in the Client Services Agreement or in a separate Investment Management Agreement. The Investment Management Agreement includes the terms and conditions under which IMA provides investment management services. Investment management -9- clients do not receive financial planning or other financial services unless a current financial services agreement exists and additional fees are currently paid.