A. Avisen Advisors, LLC (“Avisen Advisors” or “Adviser”) is a SEC registered investment advisory firm focused on providing financial planning and investment management services to a variety of institutional and private clients. The investment expertise of Avisen Advisors extends across a full range of asset classes including equity, fixed income and alternative investments, as well as asset allocation strategies. Avisen Advisors was established in 2001 and is headquartered in Sacramento, CA. The principal owners of Avisen Advisors are Kenneth Brown and A. Wayne Robello. Avisen Advisors Assets Under Management (AUM) As of 12/31/23, Avisen Advisors had reported regulatory AUM of approximately $305,430,986 on its Form ADV Part 1, $303,851,969 of which was discretionary and $1,579,017 was non-discretionary. B. Services Provided: Clients retain Avisen Advisors on both a discretionary and nondiscretionary basis. When the Adviser is retained on a discretionary basis, the Adviser has authority to supervise and direct investments of and for the Client’s account without prior consultation with the Client. Pursuant to this discretionary authority, the Adviser determines which securities are bought and sold for the account, the total amount of the purchases and sales, the brokers or dealers through which transactions are executed and the commission rates paid to effect the transactions, as applicable. The Client may restrict or prohibit transactions in certain securities or types of securities, or direct that transactions be effected through specific brokers or dealers. Clients may retain Avisen Advisors on a non-discretionary basis, requiring that portfolio transactions be discussed in advance and executed at the Client’s direction. Regarding fees, Avisen Advisors is open to discussing fee arrangements with clients. Fees may be negotiated based on a client's asset levels, service requirements or other factors in the Firm’s sole discretion. The Firm’s goal is to fully understand the scope of services for the mandate and their potential impact on fees. Based upon these discussions, Avisen Advisors’ standard fee schedule may be amended The advisory services offered by Avisen Advisors are recommended to clients based on the client’s specific investment objectives and risk tolerance based on personal financial information provided by the client. Advisory Programs Offered: Avisen Advisors Investment Portfolio Avisen Advisors, LLC (Avisen Advisors) will manage funds of advisory clients on a discretionary basis under the Avisen Advisors Investment Portfolio program. This program includes the monitoring of a client’s investment portfolio and making recommendations for appropriate investments or modifications based on the client’s description of his/her primary investment objectives and needs and in recognition of the inherent risks of investing in the financial markets by an advisor of Avisen Advisors. The fee arrangement is calculated as a percentage of assets under management with commissions charged at a discounted rate on securities transactions. All fees are payable quarterly, in advance, beginning on the first day of the month in which Avisen Advisors first provides investment advisory services. Fees will be charged directly to the client’s account when due. The value of assets under management for purposes of calculating fees will be based on closing prices on the day immediately preceding each quarterly period; provided, however, that the initial fee shall be based on closing prices on the day of the execution of an investment management agreement with a client (“the Agreement”). In the event of the termination of the Agreement before the last day of a quarterly period, the amount of the fee payable shall be prorated per the terms of the agreement. The fee schedules may be negotiated at the discretion of Avisen Advisors. Pershing LLC acts as the custodian for all Avisen Advisors accounts and shall provide monthly custodial statements for each Client Account. Global Portfolio Solution (GPS) – Lockwood Command platform GPS is a separately managed account program for investors who wish to benefit from the portfolio consulting services of a Avisen Advisors Advisor. Consulting services include the Avisen Advisors Advisor’s monitoring for a client’s investment portfolio and making recommendations for appropriate investments or modifications based on the client’s description of his/her primary investment objectives and needs and in recognition of the inherent risks of investing in the financial markets. Using the information gathered by the investor, the Avisen Advisors Advisor makes a Portfolio Manager recommendation to manage the investor’s account(s). The selected Portfolio Manager has discretion of the account and makes all trading decisions. The investor is provided a copy of the Portfolio Manager’s ADV Part 2A. Portfolio Managers in this program are selected from the Lockwood Command platform provided by Lockwood Capital Management, Inc. (LCM). All billing and reporting is generated from the Lockwood Command platform by LCM. The typical minimum, initial investment is $100,000; however some Portfolio Managers may have a higher minimum initial investment. All fees are payable quarterly, in advance, beginning on the first day of the month in which the Portfolio Manager takes acceptance of the account assets. Fees will be charged directly to the investor’s account when due. The value of assets under management for purposes of calculating fees will be based on closing prices on the business day immediately preceding each quarterly period; provided, however, that the initial fee shall be based on closing prices on the day of the execution of an investment management agreement with an investor (“the Agreement”). In the event of the termination of the Agreement before the last day of a quarterly period, the amount of the fee payable shall be prorated as of the date of such termination. The fee schedules may be negotiated at the discretion of Avisen Advisors. To total fee paid by the investor includes a program fee charged by Lockwood, the Portfolio Manager’s fee, and the Advisor’s fee. These fees may vary. Pershing LLC acts as the custodian for all GPS accounts and shall provide monthly custodial statements for each Client Account. Lockwood Investment Strategies (“LIS”) – Unified Managed Account Strategy LIS investment services are provided by Lockwood Capital Management, Inc. (LCM). LCM serves as the Portfolio Manager for the account. The Avisen Advisors Advisor serves as a consultant to the investor. Advisor consulting services includes the Avisen Advisors Advisor’s monitoring for a client’s investment portfolio and making recommendations for the most appropriate LIS investment or modifications based on the client’s description of his/her primary investment objectives and needs and in recognition of the inherent risks of investing in the financial markets. LIS is a discretionary multi-discipline managed account program housed in a single portfolio with five core models. The five (5) core models span the risk/return spectrum. A Client may also choose from four (4) additional models which include exposure to non-traditional asset classes, as described below more fully. LCM, serving as the Portfolio Manager, determines asset allocation and selects both Sub- Managers and specific investment vehicles for each investment style based on its proprietary modeling strategies, as well as its macroeconomic outlook and investment discipline. The minimum initial investment to establish an LIS account is $250,000. Depending upon the model or strategy recommended by the Avisen Advisors Advisor and chosen by the Client, a portfolio may typically hold between 5 and 350 securities. LCM selects a Sub-Manager or investment vehicle, such as an exchange-traded fund (“ETF”) or mutual fund, for each investment style. When selected for inclusion within the program, each Sub-Manager electronically provides its model portfolio (buy-list) to LCM on a daily basis. An Overlay Manager combines each of the model portfolios into one Investment Strategies portfolio designed to perform and act similar to the target benchmark for the portfolio. The Overlay Manager gathers each of the portfolios and runs an optimization program that removes security overlap, minimizes tax implications, and creates better tracking to the index. The Sub- Managers and investment vehicles currently employed in LIS portfolios are described in LCM’ ADV Part 2A Exhibit A and are subject to change at LCM’ sole discretion. LCM offers a series of strategies limited to traditional asset classes only (Traditional) and a series of Strategies that includes traditional and alternative investment asset classes (Alternative) for implementation. LCM offers five (5) diversified, discretionary, investment portfolios that include allocations to traditional asset classes including, but not limited to US Fixed Income, US Large-Cap Equity, US Small-Cap Equity, US Mid-Cap Equity, International Equity and REITs. The Traditional Strategies models, representing various levels of expected risk and return, offered within LIS are Current Income, Growth & Income, Conservative Growth, Moderate Growth, and Growth. LCM also offers four (4) diversified, discretionary, investment portfolios that include allocations to the alternative investment asset class, with the expectation of offering comparable to slightly reduced returns with notably less volatility than Traditional Strategies. Based on proprietary research, LCM has defined the alternative investment class to include the following asset classes: convertible arbitrage, distressed securities, equity hedge, equity market neutral, event-driven, fund-of- funds, merger arbitrage, macro strategies and commodities. The core asset allocation models offered within the LIS Alternative Strategies are: Growth & Income, Conservative Growth, Moderate Growth and Growth. All fees are payable quarterly, in advance, beginning on the first day of the month in which the Portfolio Manager takes acceptance of the account assets. Fees will be charged directly to the investor’s account when due. The value of assets under management for purposes of calculating fees will be based on closing prices on the business day immediately preceding each quarterly period; provided, however, that the initial fee shall be based on closing prices on the day of the execution of an investment management agreement with an investor (“the Agreement”). In the event of the termination of the Agreement before the last day of a quarterly period, the amount of the fee payable shall be prorated as of the date of such termination. The fee schedules may be negotiated at the discretion of Avisen Advisors. To total fee paid by the investor includes a program fee charged by LCM which includes any Portfolio Manager’s fee and the Advisor’s fee. These fees may vary. Pershing LLC acts as the custodian for all LIS accounts and shall provide monthly custodial statements for each Client Account. Lockwood Asset Allocation Portfolios (“LAAP”) – Mutual Fund/ETF LAAP is a discretionary, multi-discipline managed account program housed in a single portfolio. LCM, serving as the Portfolio Manager, determines asset allocation strategy and selects investment vehicles for each investment style component of the portfolios, based upon proprietary modeling strategies, macroeconomic outlook and investment research discipline. The Avisen Advisors Advisor serves as a consultant to the investor. Advisor consulting services includes the Avisen Advisors Advisor’s monitoring for a client’s investment portfolio and making recommendations for the most appropriate LAAP investment or modifications based on the client’s description of his/her primary investment objectives and needs and in recognition of the inherent risks of investing in the financial markets. The five (5) LAAP models are: Current Income, Growth & Income, Conservative Growth, Moderate Growth, and Growth. The minimum, initial investment is $50,000, with minimum subsequent investments of $1,000.00 each. Such accounts must be funded in cash. These portfolios may consist of open and closed-end mutual funds, exchange-traded funds and other types of securities, as determined by LCM, in its sole discretion. The securities currently employed in the LAAP portfolios are described in LCM’ ADV Part 2A and subject to change at LCM’ sole discretion. All fees are payable quarterly, in advance, beginning on the first day of the month in which the Portfolio Manager takes acceptance of the account assets. Fees will be charged directly to the investor’s account when due. The value of assets under management for purposes of calculating fees will be based on closing prices on the business day immediately preceding each quarterly period; provided, however, that the initial fee shall be based on closing prices on the day of the execution of an investment management agreement with an investor (“the Agreement”). In the event of the termination of the Agreement before the last day of a quarterly period, the amount of the fee payable shall be prorated as of the date of such termination. The fee schedules may be negotiated at the discretion of Avisen Advisors. To total fee paid by the investor includes a program fee charged by LCM which includes any Portfolio Manager’s fee and the Advisor’s fee. These fees may vary. Pershing LLC acts as the custodian for all LAAP accounts and shall provide monthly custodial statements for each Client Account. Avisen Advisory Solutions Program The Avisen Advisory Solutions Program is available on the Envestnet Portfolio Solutions (“Envestnet”) platform and offers eight (8) program solutions:
• Mutual Fund Advisory Solutions – Envestnet Model Driven (3 programs)
• Envestnet Mutual Fund Portfolio – Envestnet Discretionary
• Envestnet Mutual Fund Income Portfolio – Envestnet Discretionary
• Envestnet Index Enhanced Portfolio – Envestnet Discretionary
• Mutual Fund Choice – Client/Advisor Directed
• Envestnet SMA Portfolio – Envestnet Discretionary Model Driven
• SMA Choice Portfolio – Client/Advisor Directed
• Envestnet UMA Portfolio – Envestnet Discretionary Model Driven
• Advisory Choice Portfolio – Client/Advisor Directed For each Program within the Program the Client receives a comprehensive Investment Strategy Report that includes suggested allocation and historical data on asset classes, explanation of screening and investment process, analysis of investing goals versus current goals, recommended mutual funds (if applicable) for each asset category, and a detailed performance page using risk/return analysis. For each Program within the Program the Client receives a Portfolio Diagnostic Report that includes current assets, risk exposure of current assets, performance of current assets over time, and expenses and tax efficiency of current expenses. For each Program within the Program the Client receives a Consolidated Quarterly Performance Report. Fees for each Account are generally set based on the value of the Account, are negotiable and are billed and collected quarterly at the rates set forth in the Agreement. Accounts opened during any calendar quarter will be billed in advance. The annual blended fee rate is based upon the average daily balance from the inception date of the account through the end of that month. The inception fee is calculated based upon the average daily balance of the Account multiplied by the fee rate divided by the actual number of business days in the quarter multiplied by the actual number of business days the Account was opened during that quarter divided by four quarters. Client’s quarterly average daily balance is calculated based upon the number of business days the Account was opened during the previous calendar quarter. Client’s quarterly fee is calculated based upon the average daily balance of the account

multiplied by the effective fee rate divided by four quarters and billed in advance. Fees may be negotiated at the discretion of Avisen Advisors. The Avisen Advisors Advisor and Account Manager may, in their sole discretion and to the extent permitted by applicable law, pay all or a portion of the fees set forth in the Agreement to third parties involved in providing service with respect to the Account. Pershing LLC acts as the custodian for all Program Accounts and shall provide monthly custodial statements for each Client Account. Client’s are provided a copy of Envestnet’s ADV Part 2A as well as any Sub-Advisors used to manage their Account. Mutual Fund Advisory Solutions – Envestnet Model Driven (3 programs)
• Envestnet Mutual Fund Portfolio – Envestnet Discretionary
• Envestnet Mutual Fund Income Portfolio – Envestnet Discretionary
• Envestnet Index Enhanced Portfolio – Envestnet Discretionary The Mutual Fund Advisory Solutions Programs are Envestnet Driven Models. Accounts in these programs are managed on a discretionary basis by Envestnet. This program includes mutual funds and/or Exchange Traded Funds (ETFs) selected by Envestnet based on the information submitted by the client. This information recommends a model for the Client’s assets. Mutual funds shall be purchased on a “no load” or “load waived” basis through the Custodian (Pershing LLC). Envestnet acts as Account Manager for all accounts under these Programs. Avisen Advisors, nor the Avisen Advisors Advisor has discretionary investment authority for accounts in these programs. The Client and/or Avisen Advisors Advisor have the ability to select five (5) mutual fund alternatives other than those recommended by Envestnet in the Envestnet Mutual Fund Portfolio Program only. The Avisen Advisors Advisor serves as a Consultant to the Client. The Client signs an Investment Advisory Agreement that outlines the program features, fees, and expenses, if any. The Program consists of 14 models: 7 tax-sensitive and 7 non-tax-sensitive. Account Rebalancing: Automatic upon 10% variance in portfolio for 30 consecutive days. The minimum, initial investment is $50,000 / Minimum Annual Fee $1,000 (whichever is greater) Mutual Fund Choice – Client/Advisor Directed Mutual Fund Choice is a client/advisor driven model whereby the Avisen Advisors Advisor has investment discretionary authority of the account. This program includes mutual funds that shall be purchased on a “no load” or “load waived” basis through the Custodian (Pershing LLC). Information provided to the Avisen Advisors Advisor by the Client is used to determine a recommended model. The Avisen Advisors Advisor acts as Account Manager for all accounts under this Program. The Client signs an Investment Advisory Agreement that outlines the program features, fees, and expenses, if any. The Program consists of 14 models: 7 tax-sensitive and 7 non-tax-sensitive, however these models may be altered by the Avisen Advisors Advisor as needed based upon the Client’s investment objectives and risk parameters. Account Rebalancing: Avisen Advisors Advisor is alerted upon 10% variance in portfolio for 30 consecutive days. The minimum, initial investment is $50,000 / Minimum Annual Fee $1,000 (whichever is greater) Envestnet SMA Portfolio – Envestnet Discretionary Model Driven Envestnet SMA Portfolio is a discretionary managed account. Envestnet serves as the Account Manager and uses Sub-Advisors to manage the assets and make investment decisions. The Sub-Advisor (“Manager”) will have investment discretionary authority of the Account. This program includes one or more Sub- Advisors selected from the Envestnet Recommended Separate Account Manager list. Based on information submitted by the client, a recommended Manager(s) is selected to manage the Account. All transactions are executed by the Manager and custodied through the Clearing firm (Pershing LLC). Avisen Advisors, nor the Avisen Advisors Advisor has discretionary investment authority for Accounts in this program. The Client and/or Avisen Advisors Advisor have the ability to select five (5) Manager alternatives other than those recommended by Envestnet. The Avisen Advisors Advisor serves as a Consultant to the Client. The Client signs an Investment Advisory Agreement that outlines the program features, fees, and expenses, if any. The Program consists of 14 models: 7 tax-sensitive and 7 non-tax-sensitive. Includes 3 or more managers per model. Account Rebalancing: Automatic upon 10% variance in portfolio for 30 consecutive days. The minimum, initial investment is $1,000,000 SMA Choice Portfolio – Client/Advisor Directed SMA Choice Portfolio is a client/advisor driven model whereby the Client and Avisen Advisors Advisor select the Sub-Advisor (“Manager”) to manage the Account. The Manager has investment discretionary authority of the Account. The Avisen Advisors Advisor serves as Consultant on the Account and uses Sub-Advisors to manage the assets and make investment decisions. This program includes one or more Sub-Advisors selected from the Envestnet Recommended Separate Account Manager list. Based on information submitted by the Client, a recommended Manager(s) is selected to manage the Account. All transactions are executed by the Manager and custodied through the Clearing firm (Pershing LLC). Avisen Advisors, nor the Avisen Advisors Advisor has discretionary investment authority for Accounts in this program. The Client signs an Investment Advisory Agreement that outlines the program features, fees, and expenses, if any. The Program consists of 14 models: 7 tax-sensitive and 7 non-tax-sensitive. Account Rebalancing: The Manager is responsible for rebalancing. The minimum, initial investment is $100,000 Envestnet UMA Portfolio – Envestnet Discretionary Model Driven Envestnet UMA Portfolio is a discretionary managed account. Envestnet serves as the Account Manager has discretionary investment authority of the Account. Envestnet shall select mutual funds, ETF’s, bonds and general securities to be recommended to Account Owners for each portfolio model offered. Fund Quest may also select third party providers of research services (“Research Providers”) to be recommended in managing all or any portion of the Account Assets. Envestnet shall obtain purchase and sale recommendations of Research Providers in the form of model portfolios or otherwise as appropriate in order that Envestnet may manage such assets in accordance with the Research Provider’s recommendations. Based on information submitted by the client, a model is recommended to the Client. All transactions are initiated by Envestnet and custodied through the Clearing firm (Pershing LLC). Avisen Advisors, nor the Avisen Advisors Advisor has discretionary investment authority for Accounts in this program. The Avisen Advisors Advisor serves as a Consultant to the Client. The Client signs an Investment Advisory Agreement that outlines the program features, fees, and expenses, if any. The Program consists of 14 models: 7 tax-sensitive and 7 non-tax-sensitive. Includes 3 or more managers per model. Account Rebalancing: Automatic upon 10% variance in portfolio for 30 consecutive days. The minimum, initial investment is $250,000 Advisory Choice Portfolio – Client/Advisor Directed Advisory Choice Portfolio may include mutual funds, securities, bonds, and Exchange Traded Funds (ETFs). The Client maintains discretionary investment authority of the Account. The Avisen Advisors Advisor has limited discretionary investment authority within the parameters of the Investment Policy Statement which is created at the time the Account is opened. Envestnet shall retain discretionary authority to debit the Account for fees. The investment recommendations for the Account shall be subject to the limitations described in the Client’s responses to the Profile or other suitability analysis. The Client shall retain the ability to modify responses to the Profile at any time. All transactions are initiated by the Avisen Advisors Advisor and custodied through the Clearing firm (Pershing LLC). The Avisen Advisors Advisor serves as a Consultant to the Client. The Client signs an Investment Advisory Agreement that outlines the program features, fees, and expenses, if any. Account Rebalancing: Avisen Advisors Advisor is alerted upon 10% variance in portfolio for 30 consecutive days. The minimum, initial investment is $50,000 / Minimum Annual Fee is $1,000 (whichever is greater) Accounts Under Third Party Advisors. Third Party Advisors provide various services described in their marketing materials and contracts. The Avisen Advisors’ Advisor may recommend a Third Party Advisor and/or may recommend a particular investment objective or category. Sub-Advisory Agreement. Pursuant to its discretionary authority set forth in the Investment Advisory Agreement, Avisen Advisors, relative to those clients that prefer investment strategies other than those offered by Avisen Advisors, may engage sub-advisers to assist it with the management of certain client accounts, whereby investment decisions for the account may be made by the sub-adviser in accordance with the terms and conditions of a sub-advisory agreement between Avisen Advisors and the sub-adviser. The fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to, Avisen Advisors ongoing investment advisory fee. Factors, which Avisen Advisors shall consider in engaging sub-advisers, include the client’s stated investment objective(s), and the sub-adviser’s management style, performance, reputation, financial strength, reporting, pricing, and research. Avisen Advisors currently has arrangements with various sub-advisers, each of which has a specific investment discipline, which the adviser shall match with the client’s designated investment objectives. Certain of these advisors may employ various risk hedging techniques, including short selling and option strategies. Avisen Advisors clients are advised to inform Avisen Advisors, in writing, if they object to the use of any such risk hedging techniques for their investment portfolios. The client acknowledges that the investment management fee payable for these sub-advisory engagements is generally higher than that set forth in the fee schedules referenced in Item 5. Independent Managers. Avisen Advisors may allocate (and/or recommend that the client allocate) a portion of a client’s investment assets among unaffiliated independent investment managers in accordance with the client’s designated investment objective(s). In such situations, the Independent Manager[s] shall have day-to-day responsibility for the active discretionary management of the allocated assets. Avisen Advisors shall continue to render investment advisory services to the client relative to the ongoing monitoring and review of account performance, asset allocation and client investment objectives. Factors which Avisen Advisors shall consider in recommending Independent Manager[s] include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Manager[s], together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to, Avisen Advisors ongoing investment advisory fee. Termination of Investment Management Agreements. Clients sign a written investment advisory agreement with Avisen Advisors. The agreement provides that it shall be continuous until one party to the agreement terminates it and that the client may terminate the agreement within five business days of its effective date without paying any fees or penalties to Avisen Advisors. The agreement also provides that once the initial five-day period has passed, either party to the agreement may terminate the agreement at any time by providing notice to the other party. If the agreement is terminated partway through a calendar quarter, unearned fees collected in advance for that quarter will be refunded to the client pro-rate, based on the number of days remaining in the quarter. Financial Planning Services. Avisen Advisors offers financial planning services dependent on the client’s goals, objectives and financial situation. Financial plans and financial planning may include but are not limited to cash flow and debt management, risk management, college funding, life and career changes, asset allocation, retirement planning, tax planning, and estate planning. These services are offered on an hourly consulting fee basis, on a project-based fixed fee basis, or may be included as part of the fee paid for investment management services (refer to Item 5.A. for a schedule of fees). Termination of Financial Planning Agreements Either party may terminate the financial planning or on-going service agreement upon written notice to the other party. If terminated within five business days of signing the Agreement, no penalties will be assessed and all prepaid fees will be returned promptly to the Client. Should the client terminate the financial planning agreement after this date, the Client will be responsible and invoiced for any work done prior to termination. C. Avisen Advisors shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment advisor representative will discuss with each client, their particular investment objective(s). Avisen Advisors shall allocate each client’s investment assets consistent with their designated investment objective(s). Clients may, at anytime, impose restrictions, in writing, on the Adviser’s services. D. Wrap Fee Programs Avisen Advisors does not administer wrap fee accounts, however as indicated previously, Avisen Advisors offers its Clients a variety of Wrap Fee Programs to choose from which are administered by Third Party Vendors. Typically, such wrap fee programs offer investment management services under a single fee structure covering various charges, which can include investment management, brokerage, custodial service, recordkeeping and reporting. The wrap fee program sponsors and the wrap fee program clients are primarily responsible for ensuring that the services provided by the program and each investment manager or sub-adviser are suitable for each wrap fee program client’s needs. The selection decision is generally based upon the compatibility of the investment manager’s or sub-adviser’s investment style and investment management performance record with the investment objectives and level of risk tolerance of the wrap fee program client. As necessary and applicable, Avisen Advisors relies on the wrap fee program sponsors’ questionnaires or other documents or information provided, completed and/or updated by clients, to determine a client’s suitability for the strategies offered by it and as recommended to clients by the wrap fee program sponsors. For most wrap fee programs, Avisen Advisors is retained as an investment consultant by the client and recommends manager(s) within the wrap fee program, client transactions are executed by the manager without commissions, and monitors its performance. The wrap fee program sponsors may also act as custodian, or provide some combination of these or other services, all for a single fee. A portion of the total fee paid by the client is retained by Avisen Advisors for investment services rendered including investment advisory services, fees paid to the manager(s), program sponsor platform fees, reporting and bookkeeping fees. E. Client Assets Managed As of 12/31/23, Avisen Advisors had reported regulatory AUM of approximately $305,430,968 on its Form ADV Part 1, $303,851,969 of which was discretionary and $1,579,017 was non-discretionary.