A. Description of the Advisory Firm Loyola was established on October 24, 2006. Loyola registered as an Investment Adviser on August 19, 2010, and the principal owner is Alvaro R. Castillo. Investment Supervisory Services Loyola offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Loyola creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan (the Investment Policy Statement) to aid in the selection of a portfolio that matches each client’s specific situation. Investment Supervisory Services include, but are not limited to, the following:
• Investment strategy • Personal investment policy
• Asset allocation • Asset selection
• Risk tolerance • Regular portfolio monitoring Loyola evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Loyola will request discretionary authority from clients in order to select securities and execute transactions without obtaining the clients consent prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Selection of Other Advisors Currently, Loyola does not use third party managers. Financial Planning Financial plans and financial planning may include, but are not limited to investment planning, life insurance, cash flow analysis, financial modeling, opinion of value, tax concerns, retirement planning, college planning, and debt/credit planning. These services are based on a percentage of assets fees or hourly fees and the final fee structure is documented in Exhibit II of the Financial Planning Agreement. Adviser to an offshore Mutual Fund Loyola acts

as an Investment Manager to the Frank SPC Plus Ultra SP Fund Class L (USD), formerly Frank Fund SPC La Armonia Segregated Portfolio (“The Fund”) an offshore Mutual Fund registered in the Cayman Islands. The Fund is registered with the Cayman Islands Monetary Authority as a Mutual Fund under section 4(3) of the mutual funds law (2013 revision) of the Cayman Islands. This investment is only available to non-US citizens. Services Limited to Specific Types of Investments Loyola’s investment advice and/or money management includes but is not limited to mutual funds, equities, bonds, fixed income/debt securities, ETFs, real estate, hedge funds, third party money managers, REITs, private placements, and government securities. Loyola may use other securities as well to help diversify a portfolio when applicable. B. Client Tailored Services and Client Imposed Restrictions Loyola offers the same suite of services to all of its clients. However, specific investment strategies and their implementation are dependent upon the client’s current financial situation (income, tax levels, and risk tolerance levels). This information is used to construct a client specific portfolio that matches restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Loyola from properly servicing the client account, or if the restrictions would require Loyola to deviate from its standard suite of services, Loyola reserves the right to end the relationship. C. Wrap Fee Programs Loyola does not currently participate in any Wrap Fee Programs. D. Amounts Under Management As of December 31, 2023, Loyola has regulatory assets under management of $203,764,566, of which $52,862,215 are discretionary assets and $150,902,351 are non-discretionary.