A. Harbour Capital Advisors, LLC (the “Registrant”) is a limited liability company formed on February 24, 2011 in the state of Delaware. The Registrant is owned by Harbour Lights Holding Company, Inc., Elizabeth S. Duff, and Thomas S. Kim. Neil M. Chur is the President of Harbour Lights Holding Company, Inc., as such; Mr. Chur shall direct Harbour Lights Holding Company, Inc.’s participation in relation to its ownership interest in the Registrant. Thomas S. Kim is the Registrant’s Managing Member. B. INVESTMENT MANAGEMENT The Registrant provides discretionary investment advisory services on a fee-only basis. The Registrant offers two levels of investment management services to its clients. The Registrant’s Limited Investment Management Services include only investment management services on a discretionary basis. Whereas clients with a minimum asset level of $10,000,000 will receive the Registrant’s Family Office Services which include administrative, planning and various other services detailed below, at no additional fee. The Registrant’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under the Registrant’s management between 0.40% and 1.15%. FAMILY OFFICE SERVICE The Registrant views the investment advisory process as an integral part of the financial foundation for a family’s lifestyle and legacy. Proper planning is the blueprint that allows clients to achieve their goals. The Registrant takes pride in being the family wealth guardian, trusted counselor and investment specialist. By working closely with family members, the Registrant begins by designing a customized investment plan to suit the unique needs of each client. When developing the investment strategy, the Registrant takes into account all objectives, constraints and risk tolerances that shape life's priorities. The Registrant’s goal is to provide substantial value to its clients’ lives in specific areas. Sound, comprehensive investment planning and management is at the core of the Registrant’s family office services. Investment Planning: At the center of the investing process is having clearly defined goals and strategies. A well‐defined Investment Policy Statement serves as the cornerstone of the Registrant’s investment approach, and is, perhaps, the most important single document to define and assist a family in identifying its designated goals and objectives. The Registrant will customize investment strategies and asset allocation plans to suit each family’s unique needs and circumstances. Then, continuous oversight and evaluation will allow us to adjust the plan as client’s priorities change or market conditions dictate. The main components to be agreed upon with each client family include:
• Investment Objective
• Risk Tolerance
• Time Horizon
• Liquidity Requirements
• Tax and Legal Constraints
• Unique Circumstances or Requirements
• Identification of Restricted Securities
• Recommended Asset Allocation
• Appropriate Benchmark Asset Allocation and Diversification: The Registrant believes asset allocation is one of the most important decisions it will help its clients make. Proper identification and execution of asset allocation is the most effective tool to target risk levels. The Registrant believes in the merit of diversification to mitigate risk as well as to provide opportunities to enhance portfolio returns. This would include utilization of traditional asset classes of stocks and bonds, and less traditional classes of hedge funds, venture capital, private equity and real estate. By allocating to the appropriate mix of investments across a diversified portfolio, the Registrant strives to limit losses and reduce the fluctuations of investment returns without sacrificing potential gains. The Registrant uses sophisticated software utilizing mean variance optimization techniques to generate forecasts of potential outcomes to help guide clients in the asset allocation decision. Asset Management: The Registrant offers a full range of investments across asset classes through a Core‐Satellite approach. The Registrant’s experienced portfolio managers will manage the core of domestic, large, liquid, publicly traded securities (stocks, bonds, exchange traded funds (“ETFs”), etc.) and will employ outside managers for the satellites (hedge funds, private equity, international, etc.). This model provides enhanced risk management, portfolio performance, liquidity and a fee structure that are not available in a purely outsourced model. Investment Reporting: The Registrant remains available to provide each client with comprehensive investment reporting that includes all assets and liabilities, including illiquid assets held outside of its investment management program. Reporting may be customized and will include holdings, transactions, income and expenses, gains and losses, and portfolio performance. ADMINISTRATION Families of substantial wealth have more complex balance sheets with potentially wide‐ ranging risk exposures. The Registrant’s clients will benefit from its analysis of each of these exposures. Financial Statements: The Registrant remains available to prepare balance sheets and income/expense statements for family office service clients. These will include a detailed analysis of related cash flows, risks and potential risk mitigation strategies. The Registrant will not sell insurance products. Instead, this review will include a conflict‐ free insurance analysis and discussion of insurance coverage with non‐related insurance providers. Legal Review: The Registrant will not engage in any activity deemed to be the practice of law; however, the Registrant will assist client families with legal reviews related to their investments, business interests, and professional and charitable activities. This process will include educating clients regarding their rights, obligations and potential risks, as well as assisting them in engaging appropriate outside legal counsel. Liquidity Management: The Registrant remains available to advise clients on their daily and monthly cash management requirements, ensuring that liquidity is maintained to support outflows. Reconciliation of cash accounts may be offered to clients with significant cash management systems involving multiple providers. Bill Payment: The Registrant may recommend the services of a third party bill payment service to minimize each client’s administrative burden. WEALTH MAINTENANCE AND TRANSFER, TRUST AND ESTATE, AND TAX PLANNING SERVICES Many wealthy clients are still in the process of accumulating substantial wealth from various sources. The Registrant anticipates that clients are eager to know whether the wealth that they have already accumulated or expect to acquire is adequate to comfortably achieve their family’s key goals. Through rigorous and iterative analysis, the Registrant will help guide clients to reliable conclusions for managing the complex interplay of:
• Family cash flows (income and expense management)
• Appropriate investment returns and risks
• Balance sheet management
• Employment continuation and/or retirement
• Family and philanthropic wealth transfer
• Family business capital investments, distributions, and dissolutions The Registrant is skilled in:
• Wealth transfer, estate, and incapacity planning
• Charitable planning
• Business succession planning
• Proper utilization and ownership of life insurance and annuities
• Stock option strategies
• Restricted stock
• Lifestyle needs and cash flow analysis
• Financial planning
• Pre‐liquidity event, merger and acquisition, and other exit strategy planning The Registrant has aligned itself with external providers for trusteeship and other fiduciary services. The Registrant works with clients’ attorneys, accountants, and other key advisors to design and implement comprehensive tax minimization plans, often incorporating, among other things, the following planning strategies and techniques:
• Installment Sales to Defective Grantor Trusts and Grantor Retainer Annuity Trusts
• Charitable Remainder Unitrusts and Annuity Trusts (including Net Income Make‐up Charitable Remainder Unitrusts), Gift Annuities, Pooled Income Funds, and Charitable Lead Annuity and Unitrusts
• Dynasty, Perpetuity, and Asset‐protection GST and Reverse‐QTIP Trusts
• Private Trust Companies and Family Banks
• Donor‐advised Funds, Supporting Organizations, Community Foundations, and Private Foundations
• Remainder Interest Sales, Reverse Split Purchases, and Qualified Personal Residence Trusts
• Qualified Conservation Easements and Land Preservation and Historic Rehabilitation Tax Credits
• Qualified Terminable Interest Property Trusts, General Power Of Appointment Trusts, Qualified Domestic Trusts, Crummey Trusts, and Life Insurance Trusts
• Limited Partnership Limited Liability Company, S Corporation, Delaware Business Trust, and C Corp Formations and Recapitalizations
• Employee Stock Ownership Plans
• Intra‐family Loans and Graegin Loans
• 1031 Exchanges, Exchange Funds, Cashless Collars, and Variable Prepaid Forward Contracts
• Options Exercise, Transfer, Monetization, Diversification, and Tax Liability Deferral Strategies The Registrant also offers a full suite of income tax projection and planning services to individuals, trusts, charitable entities, and private, closely‐held business entities. The Registrant has aligned itself with trusted external service providers (Certified Public Accountants and accountants) for tax compliance services for its clients. PHILANTHROPY & FOUNDATION ADVISORY SERVICES In addition to advising families as to philanthropic wealth transfer and/or charitable planning strategies, the Registrant will provide Foundation Advisory Services to ensure that its clients' charitable goals and visions are carried out through meaningful community impact. Fees are detailed below in Item 5. Foundation Advisory Services include: Foundation management and administration:
• Provide advice on foundation mission, governance, fiduciary and administrative issues
• Monitor cash flow to ensure timely grant‐making
• Process grant distributions and report on grants paid
• Serve as address of record for grant inquiries, foundation correspondence and regulatory purposes
• Attend foundation meetings and record foundation minutes
• Engage next generation through educational sessions and workshops on philanthropy Grants management and administration:
• Develop and/or review foundation guidelines, special funding initiatives, grant‐ making priorities and application procedures, as needed
• Act as point of contact with grant‐seeking organizations and the community
• Initiate outreach to organizations that meet funding priorities
• Review and evaluate grant proposals
• Prepare grant transmittal letters and grant contracts
• Manage grant portfolio and generate grantee reports on use of funds
• Conduct foundation governance and compliance reviews FAMILY GOVERNANCE The Registrant’s professional team has decades of experience advising wealthy families. The Registrant’s team brings this expertise to the design and implementation of a family governance system. The Registrant’s services will include:
• Assist in drafting a Family Constitution to govern wealth management philosophies and transfer strategies
• Facilitate multi‐generational Family Meetings
• Offer financial Education, Training & Mentoring for younger generations to ensure age appropriate understanding of financial literacy and wealth management issues
• Provide objective counsel in matters requiring Conflict Resolution ADDITIONAL SERVICES The Registrant remains available to provide additional services which will generally include additional fees beyond the asset‐based fees described in Item 5 below. These services will vary in complexity depending on client needs and objectives. These services are generally not available from competing firms, but are available to the Registrant’s clients because of the depth and breadth of experience of the Registrant’s professional team. This could include services such as:
• Family Business Oversight: Analyze performance of family businesses and identify opportunities to enhance value through a sale or merger transaction
• Private Aviation Analysis: Evaluate optimal funding to include financing and lease structures, fractional ownership and charter
• Debt Advising & Arranging: Review capital needs, advise on optimal funding structure and arrange funding through external service providers
• Foreign Currency Advising & Arranging: Ensure availability of FX currency, as appropriate LIMITED INVESTMENT MANAGEMENT SERVICES As described above, the Registrant’s Limited Investment Management Services include only the discretionary investment management of client assets. Clients who engage the Registrant to provide Limited Investment Management Services will not receive administrative, planning and/or the various other services detailed above under the Family Office Service heading. FINANCIAL PLANNING AND CONSULTING SERVICES The Registrant may provide financial planning and/or consulting services (including investment and non-investment related matters, including estate planning, insurance planning, etc.) on a stand-alone separate fee basis. Registrant’s planning and consulting services are offered on a fixed fee basis. The Registrant may also be engaged by a client to complete a project separate and apart from the Registrant’s core services. Prior to engaging the Registrant to provide planning or consulting services, clients are generally required to enter into a Financial Planning and Consulting Agreement with Registrant setting forth the terms and conditions of the engagement (including termination), describing the scope of the services to be provided, and the portion of the fee that is due from the client prior to Registrant commencing services. If requested by the client, Registrant may recommend the services of other professionals for implementation purposes. The client is under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from the Registrant. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible for the quality and competency of the services provided. It remains the client’s responsibility to promptly notify the Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Registrant’s previous recommendations and/or services. IMPORTANT DISCLOSURES Limitations of Financial Planning and Non-Investment Consulting/Implementation Services. To the extent requested by a client, Registrant may provide financial planning and related consulting services regarding non-investment related matters, such as estate planning, tax planning, insurance, etc. The Registrant does not serve as a law firm, accounting firm, or insurance agency, and no portion of Registrant’s services should be construed as legal, accounting, or insurance implementation services. Accordingly, Registrant does not prepare estate planning documents, tax returns or sell insurance products. To the extent requested by a client, Registrant may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorneys, accountants, insurance agents, etc.). Clients are reminded that they are under no obligation to engage the services of any such recommended professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation made by Registrant or its representatives. If the client engages any recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional[s] (i.e., attorney, accountant, insurance agent, etc.), and not the Registrant, shall be responsible for the quality and competency of the services provided. Structured Notes. Registrant may purchase Structured Notes for client accounts. A Structured Note is a financial instrument that combines two elements, a debt security and exposure to an underlying asset or assets. It is essentially a note, carrying counter party risk of the issuer. However, the return on the note is linked to the return of an underlying asset or assets (such as the S&P 500 Index or commodities). It is this latter feature that makes structured products unique, as the payout can be used to provide some degree of principal protection, leveraged returns (but usually with some cap on

the maximum return), and be tailored to a specific market or economic view. Structured Notes will generally be subject to liquidity constraints, such that the sale thereof before maturity will be limited, and any sale before the maturity date could result in a substantial loss. There can be no assurance that the Structured Notes investment will be profitable, equal any historical performance level(s), or prove successful. If the issuer of the Structured Note defaults, the entire value of the investment could be lost. Retirement Rollovers-Potential for Conflict of Interest: A client or prospective client leaving an employer typically has four options regarding an existing retirement plan (and may engage in a combination of these options): (i) leave the money in the former employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value (which could, depending upon the client’s age, result in adverse tax consequences). If Registrant recommends that a client roll over their retirement plan assets into an account to be managed by Registrant, such a recommendation creates a conflict of interest if Registrant will earn new (or increase its current) compensation as a result of the rollover. If Registrant provides a recommendation as to whether a client should engage in a rollover or not (whether it is from an employer’s plan or an existing IRA), Registrant is acting as a fiduciary 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. No client is under any obligation to roll over retirement plan assets to an account managed by Registrant, whether it is from an employer’s plan or an existing IRA. Private Funds. The Registrant is affiliated with the HCA-CP6, LP, and HCA-CP7, LP, private equity funds (the “affiliated funds”). The complete description of the terms, conditions, risks and fees associated with investing in the affiliated funds are set forth in the affiliated funds’ offering documents). The Registrant, on a non-discretionary basis, may recommend that qualified clients consider allocating a portion of their investment assets to the affiliated funds. The terms and conditions for participation in the affiliated funds, including management fees, conflicts of interest, and risk factors, are set forth in each fund’s offering documents. Registrant may also provide investment advice regarding unaffiliated private investment funds. The Registrant’s role relative to the private investment funds shall be limited to its initial and ongoing due diligence and investment monitoring services. If a client determines to become a private fund investor, the amount of assets invested in the fund(s) shall be included as part of “assets under management” for purposes of Registrant calculating its investment advisory fee. Registrant’s clients are under absolutely no obligation to consider or make an investment in a private investment fund(s). Risks: Private investment funds generally involve various risk factors, including, but not limited to, potential for complete loss of principal, liquidity constraints and lack of transparency, a complete discussion of which is set forth in each fund’s offering documents, which will be provided to each client for review and consideration. Unlike liquid investments that a client may own, private investment funds do not provide daily liquidity or pricing. Each prospective client investor will be required to complete a Subscription Agreement, pursuant to which the client shall establish that he/she is qualified for investment in the fund, and acknowledges and accepts the various risk factors that are associated with such an investment. Valuation: In the event that the Registrant references private investment funds owned by the client on any supplemental account reports prepared by the Registrant, the value(s) for all private investment funds owned by the client shall reflect the most recent valuation provided by the fund sponsor. The current value(s) (to the extent ascertainable) could be significantly more or less than the original purchase price. The client’s advisory fee shall be based upon such reflected fund value(s). Conflict of Interest. Because the Registrant and/or its affiliates can earn compensation from the affiliated private funds that may exceed the fee that the Registrant would earn under its standard asset based fee schedule referenced in Item 5 below, the recommendation that a client become a Fund investor presents a conflict of interest. No client is under any obligation to become a Fund investor. Cross Transactions. In limited circumstances, when determined to be in the best interest of its clients, Registrant may engage in a cross-transaction pursuant to which Registrant may effect transactions between two of its managed client accounts (i.e., arranging for the clients’ securities trades by “crossing” these trades when Registrant believes that such transactions [generally, thinly traded bonds] are beneficial to its clients). For all such transactions, neither Registrant nor any affiliate will be acting as a broker. Registrant will not receive any commission or transaction-based compensation, although Registrant has an interest in the price at which the cross trades are conducted since Registrant’s asset- based fees will be negatively impacted by lower bond values. This may present a conflict of interest. These transactions will be generally effected through Fidelity, the account custodian, or a prime broker. The client may revoke Registrant’s cross-transaction authority at any time upon written notice to Registrant. Independent Managers. The Registrant 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 Managers shall have day-to-day responsibility for the active discretionary management of the allocated assets. The Registrant 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 the Registrant shall consider in recommending Independent Managers include the client’s designated investment objective(s), management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fee charged by the Independent Manager(s) is separate from, and in addition to, the Registrant’s investment advisory fee as set forth in Item 5. Socially Responsible (ESG) Investing Limitations. Socially Responsible Investing involves the incorporation of Environmental, Social and Governance (“ESG”) considerations into the investment due diligence process. ESG investing incorporates a set of criteria/factors used in evaluating potential investments: Environmental (i.e., considers how a company safeguards the environment); Social (i.e., the manner in which a company manages relationships with its employees, customers, and the communities in which it operates); and Governance (i.e., company management considerations). The number of companies that meet an acceptable ESG mandate can be limited when compared to those that do not and could underperform broad market indices. Investors must accept these limitations, including potential for underperformance. Correspondingly, the number of ESG mutual funds and exchange-traded funds are limited when compared to those that do not maintain such a mandate. As with any type of investment (including any investment and/or investment strategies recommended and/or undertaken by Registrant), there can be no assurance that investment in ESG securities or funds will be profitable or prove successful. Registrant does not maintain or advocate an ESG investment strategy but will seek to employ ESG if directed by a client to do so. If implemented, Registrant shall rely upon the assessments undertaken by the unaffiliated mutual fund, exchange traded fund or separate account portfolio manager to determine that the fund’s or portfolio’s underlying company securities meet a socially responsible mandate. Comprehensive Reporting. The Registrant, in conjunction with the services provided by other professionals and/or services, may also provide periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by the Registrant (the “Excluded Assets”). The client and/or their other advisors that maintain trading authority, and not the Registrant, shall be exclusively responsible for the investment performance of the Excluded Assets. The Registrant’s service relative to the Excluded Assets is limited to reporting and non-discretionary consulting services only, which does not include investment implementation. The Registrant does not have trading authority for the Excluded Assets. As such, to the extent applicable to the nature of the Excluded Assets (assets over which the client maintains trading authority vs. trading authority designated to another investment professional), the client (and/or the other investment professional), and not the Registrant, shall be exclusively responsible for directly implementing any recommendations relative to the Excluded Assets. The Registrant shall not be responsible for any implementation error (timing, trading, etc.) relative to the Excluded Assets. In the event the client desires that the Registrant provide non-discretionary investment management services (whereby the Registrant would have trading authority) with respect to the Excluded Assets, the client may engage the Registrant to do so pursuant to the terms and conditions of the Investment Advisory Agreement between the Registrant and the client. Harbour Lights Holding Company, Inc. The Registrant is affiliated with Harbour Lights Holding Company, Inc., a domestic for-profit corporation organized in the state of Florida (“HLHC”). HLHC is an advisory client of Registrant. Registrant is also the sole tenant of space owned by HLHC at 9010 Strada Stell Court, Suite 206, Naples, Florida 34109. HLHC is a Family Office investment adviser firm. HLHC provides advisory services to a single family client, as such, the Registrant shall not recommend the services of HLHC, nor shall the services of HLHC be made available to any client of the Registrant. Client Obligations. In performing its services, Registrant shall not be required to verify any information received from the client or from the client’s other professionals, and is expressly authorized to rely thereon. Moreover, each client is advised that it remains their responsibility to promptly notify the Registrant if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating or revising Registrant’s previous recommendations and/or services. Cash Positions. Registrant continues to treat cash as an asset class. As such, unless determined to the contrary by Registrant, all cash positions (money markets, etc.) shall continue to be included as part of assets under management for purposes of calculating Registrant’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), Registrant may maintain cash positions for defensive purposes. In addition, while assets are maintained in cash, such amounts could miss market advances. Depending upon current yields, at any point in time, Registrant’s advisory fee could exceed the interest paid by the client’s money market fund. Cash Sweep Accounts. Certain account custodians can require that cash proceeds from account transactions or new deposits, be swept to and/or initially maintained in a specific custodian designated sweep account. The yield on the sweep account will generally be lower than those available for other money market accounts. When this occurs, to help mitigate the corresponding yield dispersion Registrant shall (usually within 30 days thereafter) generally (with exceptions) purchase a higher yielding money market fund (or other type security) available on the custodian’s platform, unless Registrant reasonably anticipates that it will utilize the cash proceeds during the subsequent 30-day period to purchase additional investments for the client’s account. Exceptions and/or modifications can and will occur with respect to all or a portion of the cash balances for various reasons, including, but not limited to the amount of dispersion between the sweep account and a money market fund, the size of the cash balance, an indication from the client of an imminent need for such cash, or the client has a demonstrated history of writing checks from the account. The above does not apply to the cash component maintained within a Registrant actively managed investment strategy (the cash balances for which shall generally remain in the custodian designated cash sweep account), an indication from the client of a need for access to such cash, assets allocated to an unaffiliated investment manager and cash balances maintained for fee billing purposes. The client shall remain exclusively responsible for yield dispersion/cash balance decisions and corresponding transactions for cash balances maintained in any Registrant unmanaged accounts. Cryptocurrency: For clients who want exposure to cryptocurrencies, including Bitcoin, the Registrant, will advise the client to consider a potential investment in corresponding exchange traded securities, or an allocation to separate account managers and/or private funds that provide cryptocurrency exposure. Crypto is a digital currency that can be used to buy goods and services but uses an online ledger with strong cryptography (i.e., a method of protecting information and communications through the use of codes) to secure online transactions. Unlike conventional currencies issued by a monetary authority, cryptocurrencies are generally not controlled or regulated and their price is determined by the supply and demand of their market. Because cryptocurrency is currently considered to be a speculative investment, the Registrant will not exercise discretionary authority to purchase a cryptocurrency investment for client accounts. Rather, a client must expressly authorize the purchase of the cryptocurrency investment. The Registrant does not recommend or advocate the purchase of, or investment in, cryptocurrencies. The Registrant considers such an investment to be speculative. Clients who authorize the purchase of a cryptocurrency investment must be prepared for the potential for liquidity constraints, extreme price volatility and complete loss of principal. Cybersecurity Risk. The information technology systems and networks that Registrant and its third-party service providers use to provide services to Registrant’s clients employ various controls, which are designed to prevent cybersecurity incidents stemming from intentional or unintentional actions that could cause significant interruptions in Registrant’s operations and result in the unauthorized acquisition or use of clients’ confidential or non-public personal information. Clients and Registrant are nonetheless subject to the risk of cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damage to respond to regulatory obligations, other costs associated with corrective measures, and loss from damage or interruption to systems. Although Registrant has established procedures to reduce the risk of cybersecurity incidents, there is no guarantee that these efforts will always be successful, especially considering that Registrant does not directly control the cybersecurity measures and policies employed by third-party service providers. Clients could incur similar adverse consequences resulting from cybersecurity incidents that more directly affect issuers of securities in which those clients invest, broker-dealers, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Disclosure Statement. A copy of the Registrant’s written Brochure and Client Relationship Summary, as set forth on Part 2 of Form ADV and Form CRS respectively, shall be provided to each client prior to, or contemporaneously with, the execution of the Investment Advisory Agreement or Financial Planning and Consulting Agreement. C. The Registrant shall provide investment advisory services specific to the needs of each client. Prior to providing investment advisory services, an investment adviser representative will ascertain each client’s investment objective(s). Thereafter, the Registrant shall allocate and/or recommend that the client allocate investment assets consistent with the designated investment objective(s). The client may, at any time, impose reasonable restrictions, in writing, on the Registrant’s services. D. The Registrant does not participate in a wrap fee program. E. As of December 31, 2023, the Registrant had $579,736,993 in assets under management on a discretionary basis.