A. Firm Information International Assets Investment Management, LLC (“IAIM”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”) with its principal place of business in Orlando, Florida. IAIM began conducting business in 2007 and is owned by Pecunia Management, LLC (“Pecunia”), Pecunia is owned by IAA Investment Holdings, LLC. The majority owner of IAA Investment Holdings, LLC is RIA Holding Company, LLC which is owned by the Richard Desich Revocable Trust FBO Jeffrey Desich and Richard Desich. IAIM has an expense sharing agreement with International Assets Advisory, LLC (“IAA”), a registered broker-dealer, Member FINRA/SIPC and IAA Shared Services, LLC (“ISS”), to provide various administrative and support services, facilities, personnel, equipment, etc. As part of the expense sharing agreement, IAIM pays IAA and ISS for such services. IAA, ISS and IAIM are affiliated under common ownership by Pecunia. IAIM offers services through our network of independent investment advisor representatives (“IARs”). IARs may have their own legal business entities whose trade names and logos are used for marketing purposes and may appear on marketing materials or Client statements. These business names have been adopted by IAIM as d/b/a names under which we provide advisory services. The Client should understand that the businesses are legal entities of the IAR and not of IAIM. The IARs are under the supervision of IAIM, and the advisory services of the IAR are provided through IAIM. IAIM provides notice of all of its d/b/a names online at the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with our name or our CRD# 144426. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by IAIM. IAIM and its IARs serve as a fiduciary to Clients, as defined under applicable laws and regulations. When we provide investment advice regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. As a fiduciary, IAIM and its IARs uphold a duty of loyalty, fairness and good faith toward each Client and seek to mitigate potential conflicts of interest. Our fiduciary commitment is further described in our Code of Ethics. For more information regarding our Code of Ethics, please see “Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading.” B. Advisory Services Offered IAIM generally provides investment advisory services to individuals, high net worth individuals, pensions and profit plans, charitable organizations, corporations, and other business entities (referred to individually as a “Client” and collectively as “Clients”). These services generally fall into three categories – Investment Management Services, Referrals to Third Party Wrap Fee Programs and Financial Planning and Consulting. Investment Management Services IAIM provides customized wealth management solutions for its Clients, through continuous personal Client contact and interaction while providing discretionary and non-discretionary investment management and related advisory services. IAIM works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create an investment strategy. IAIM will implement the investment strategy with its internal management and/or the use of affiliated and unaffiliated money managers or investment platforms (as described below). IAIM’s services are provided through independent IARs. This structure means that IARs are free to implement investment strategies and plans on their own accord. This structure is distinguished from some Page 2 other registered investment advisors that mandate the Clients invest only in company-sponsored investment programs. IAIM believes strongly in the flexibility it provides to its independent IARs. To the extent that independent IARs employ IAIM-sponsored investment programs in Client accounts, it is because the independent IAR deems the investment program to be suitable for the Client and not because of any requirement to do so from IAIM. IAIM provides investment advisory services and portfolio management services. It does not provide securities custodial services. At no time will IAIM accept or maintain custody of a Client’s funds or securities, except for authorized deduction of IAIM’s fees or as a result of a Client’s implementation of a standing letter of authorization. All Client assets will be managed within their designated account(s) at the Custodian, pursuant to the IAIM investment advisory agreement. Please see Item 12 – Brokerage Practices. It is important to note that none of the advisory services described herein are intended as, or meant to be a substitute for, legal, accounting, actuarial, or tax advice. Clients should coordinate and discuss the impact of the financial advice they receive from the IAR with their attorney, accountant, and other professionals. Neither IAIM nor its IARs (unless they have the appropriate independent qualifications) are qualified to provide legal or accounting advice, and do not claim to tender such advice. Below is a description of the various investment management services provided by IAIM. Internal Investment Management IAIM customizes its investment management services for its Clients. Portfolios are primarily constructed using mutual funds, exchange-traded funds (“ETFs”), individual stocks and fixed income securities. The IARs may also utilize other types of investments, as appropriate, to meet the needs of each particular Client. IAIM generally employs a long-term investment approach for Clients, but may buy, sell or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to market conditions. IARs construct, implement and monitor each Client’s portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by IAIM and IAR. The specific advisory program selected by the Client will cost the Client more or less than purchasing program services separately. Factors that bear upon the cost of a particular advisory program in relation to the cost of the same services purchased separately include, but may not be limited to, the type and size of the account, the historical or expected size or number of trades for the account, the types of securities and strategies involved, and the number and range of supplementary advisory and Client-related services provided to the account. IAIM and/or its IARs may recommend, on occasion, redistributing investment allocations to diversify the portfolio. IAIM and/or IARs may recommend specific positions to increase sector or asset class weightings. IARs may recommend employing cash positions as a possible hedge against market movement. IARs may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Promoter Based Third Party Asset Manager Programs For appropriate Clients, the IAR may recommend that all or a portion of a Client’s portfolio be implemented by utilizing one or more affiliated or unaffiliated money managers or investment platforms (“TPAMs”). The Client will be required to enter into one or more separate agreements with the TPAM(s) that provide for discretionary management by the TPAM(s) of the investment platform. Page 3 IAIM may act as a compensated promoter (“Promoter”) (formerly known as “solicitor”) capacity when making TPAM programs available to clients. When IAIM acts as a Promoter, IAIM serves as both a Promoter of accounts to the TPAM and as the Client’s primary advisor and relationship manager and will oversee the account to ensure the TPAM is managing consistent with the selected investment strategy or strategies. However, the TPAM will assume discretionary authority for the day-to-day investment management of those assets placed in their control. The IAR will assist and advise the Client in establishing investment objectives for their account, the selection of the TPAM, and defining any restrictions on the account. TPAM services generally begin with the IAR obtaining the necessary financial data from the Client to assist with setting an appropriate investment objective, determining the suitability of the program and in opening an account with the TPAM. Depending on the program, the IAR may also assist the Client with selecting a model portfolio of securities designed and managed by either the TPAM or a selected portfolio management firm available through the TPAM responsible for providing discretionary asset management services. The TPAM or other third-party investment advisor is granted authority in its Client agreement to purchase and sell securities on a discretionary basis pursuant to the investment objective chosen by the Client. In doing so, the TPAM or other third-party investment advisor typically constructs various model investment portfolios that are managed according to specific investment strategies associated with the respective models, and that are not generally customized for individual Clients (subject to the Client’s ability to request reasonable investment restrictions on investing in securities or other special accommodations that may be made). In addition to portfolio management services, the TPAM sponsor will also generally arrange for custody of Client assets, trade

execution, cashiering services, and such other services as outlined in the TPAM’s separate Client agreement and Disclosure Brochure. IAIM and your IAR are compensated for referring you to the TPAM. This compensation generally takes the form of the TPAM sharing with IAIM and your IAR a percentage of the advisory fee that you pay to the TPAM. When we act as Promoter for a TPAM, and prior to entering into an agreement with a TPAM, you will receive a Promoter disclosure statement (“Disclosure Statement”) describing the nature of our relationship with the TPAM and the terms of our compensation arrangement with the TPAM, including a description of the compensation that we will receive for referring you to the TPAM Program IAIM does not receive any compensation from these TPAMs or Investment Platforms, other than IAIM’s investment advisory fee (described in “Item 5 – Fees and Compensation”) The following paragraph contains important conflicts of interest to consider. Assets managed by a TPAM are not considered assets under management of IAIM. Many investment advisory firms are measured, in part, by the amount of assets under management as reported in this Disclosure Brochure. The fact that IAIM cannot count assets advised in a TPAM program as its assets under management creates a conflict of interest inasmuch as it acts as a barrier to recommending TPAM programs. The effect of this conflict is mitigated by the independence of IAIM’s IARs, who are not required to have Client account recommendations approved by IAIM. Sub-Adviser Based Third Party Asset Management Programs IAIM can enter into sub-advisory relationships in which it contracts with a TPAM to provide investment management services to a Client account. IAIM and the sub-adviser are jointly responsible for the ongoing management of the account. Your IAR is responsible for assisting you with completing the investor profile questionnaire or any account opening documentation. While each TPAM may have a different name for their questionnaire, your responses will assist your IAR with understanding your investment objectives, financial situation, risk tolerance, investment time horizon and other personal information. Based on the answers that you provide to your IAR, he/she will assist you in determining which TPAM model or portfolio strategy is appropriate for you. As part of establishing a new account, you will receive both our Disclosure Brochure as well as the TPAM’s Disclosure Brochure. Page 4 Since each TPAM is uniquely structured with different investment products, please ensure that you carefully review all documents provided to you on behalf of the TPAM. These documents include, but are not limited to:  The TPAM’s Form ADV Part 2A or Disclosure Brochure for specific program descriptions.  The TPAM’s Client Agreement as well as any other agreement entered into regarding a TPAM Program, for specific contractual terms (including fees, billing methods, administrative and other fees, etc.).  Any additional disclosure or offering documents provided by the TPAM in connection with investment products. The following paragraph contains important conflicts of interest to consider. Assets managed in a sub- advised account program are counted as assets under management of IAIM and the sub-adviser. Many investment advisory firms are measured, in part, by the amount assets under management as reported in this Disclosure Brochure. In a sub-advised investment program, both the sub-adviser and IAIM are responsible for the management of the invested assets, though in practice, investment management is vested almost entirely in the sub-adviser. This structure increases IAIM’s risk of Client complaints stemming from account management by the sub-adviser and prompts IAIM to engage in time consuming and costly oversight of sub-advisory relationships. IAIM’s Relationships with Other Investment Advisers IAIM may serve as a Promoters for or recommend clients to third-party investment advisers. IAIM is compensated for referring your advisory business to these third-party investment advisers. This compensation generally takes the form of the third-party investment adviser sharing with IAIM a portion of the advisory fee the third-party investment adviser charges you for providing investment management services. IAIM performs reasonable due diligence on these third-party investment advisers on an initial and ongoing basis. Clients who are referred to these third-party investment advisers will receive a Disclosure Statement that describes, among other things, the compensation that will be paid to IAIM and the IAR by the third-party investment adviser. The following paragraph contains important conflicts of interest to consider. IAIM has a conflict of interest to refer clients to those third-party investment advisers who pay referral fees to IAIM rather than those who do not. Additionally, IAIM has a conflict of interest to refer clients to those third-party investment advisers who pay higher referral fees over those who pay lower referral fees. Referrals to Wrap Fee Programs IARs may also use one or more third party Wrap Fee programs sponsored by an unaffiliated third-party broker dealers/investment advisors as listed below to manage your assets. Programs available include the following (as of the date of this Disclosure Brochure) and are available only on a fee-only basis:  RBC Advisor  RBC Unified Portfolio  RBC Consulting Services The above programs are sponsored by RBC Capital Markets (“RBC CM”), a securities broker-dealer registered with the SEC and FINRA. Please see the Part 2A, Brochure Supplement that you are provided for each of these programs (the Wrap Fee Disclosure Brochure). This Wrap Fee Disclosure Brochure identifies all relevant fees, expenses, and other charges (and how the program works) to you. Financial Planning and Consulting Services IAIM provides a variety of financial planning and consulting services to individuals and families, pursuant to a written financial planning and consulting agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. Financial planning is a Page 5 separate service from IAIM’s investment management services. Clients have full discretion as to how they choose to implement the recommendations discussed in the financial plan. Financial planning and consulting services will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. IAIM may also refer Clients to an accountant, attorney or other specialist as appropriate for their unique situation. For certain financial planning engagements, the IAR will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. An additional agreement will be required if the Client chooses to utilize the representative for further investment management services. The following paragraph contains important conflicts of interest to consider. Financial planning recommendations may pose a conflict between the interests of the IAR and the interests of the Client. For example, a recommendation to engage the IAR for investment management services or to increase the level of investment assets with the IAR would pose a conflict, as it would increase the advisory fees paid to the IAR. The effect of this conflict is mitigated by the independence of the Clients. Clients are not required to use IAIM or any of its IARs for investment services incorporated into a financial plan or consulting engagement. Retirement Plan Advisory Services IAIM provides plan advisory services to company retirement plans (each a “Plan”) and the sponsor of the Plan (herein the “Plan Sponsor”). Services are tailored to the size and complexity of the Plan and the needs of the Plan Sponsor and/or the participants in the Plan, pursuant to the terms of the retirement plan advisory agreement. IAIM may provide retirement plan advisory services on behalf of the Plan and Plan Sponsor as defined under ERISA 3(21). IARs do not act as investment managers and are not considered to be a Section 3(38) fiduciary. Client Role and Obligations Relative to IAIM’s Advisory Services IAIM relies on forthright communication from its Clients in order to provide them with investment services. It is imperative that Clients be direct, honest and fulsome with their investment criteria, investment knowledge, holdings, goals, time horizon and other important factors. Clients are obliged to report changes in their financial situation including the factors enumerated above, as soon as possible. C. Tailored Relationships IAIM, makes available through its IARs, advisory services to meet most individual Client needs and objectives. The IAR’s role is to meet with Clients and determine which option(s) are most suitable in assisting the Clients with meeting their investment needs. Certain programs available through IAIM may be utilized by multiple Clients that have similar time horizons, needs and objectives. IAIM offers Clients the ability to place restrictions on their advisory account(s). In general, the restrictions may include security type, specific securities, and cash balance requirement. Under certain situations, a restriction may prevent IAIM from providing investment choices to meet a Client’s needs. In the event a restriction does impair IAIM’s ability to manage a portfolio effectively, the Client engagement may be terminated under the terms of the contract. Page 6 D. Assets Under Management As of December 31, 2023, IAIM manages approximately $1,685,163,470 in assets, of which $1,432,689,261 are managed on a discretionary basis and $252,474,209 on a non-discretionary basis. Clients may request more current information at any time by contacting their IAR.