General. Puente is a limited liability company organized in the State of Florida and registered to conduct business as a Registered Investment Adviser. Puente is wholly owned by Puente Holdings Limited, and indirectly owned by Cross Capital S.A. and Puente Partners SA. Cross Capital S.A. owns 100% of the voting rights of Puente Partners SA, and Federico Tomsevich owns 100% of Cross Capital S.A. Description of Advisory Services Puente provides asset/portfolio management and financial advice to individuals, institutions and corporations. Puente’s investment advisory services are provided through various types of discretionary and non-discretionary accounts (the “Accounts”) in accordance with each client’s investment objectives and pursuant to the terms outlined in Puente’s investment advisory agreement. The Adviser’s discretionary and non-discretionary investment management services include the design, structure, and implementation of various personalized investment strategies for managed Accounts. Investment activities focus on investments in various kinds of assets and securities in a variety of markets that are intended to fit within the client’s objectives, strategies and risk profile as described by each client. The overall advisory services offered by Puente fall within the following categories: ➢ Customized Discretionary Portfolios Adviser offers discretionary separately managed Accounts that are customized to each client. Managed Accounts may focus on investments in specified and limited kinds of assets and securities, in limited markets, or they may be broad-based across many asset classes and markets. Such accounts are intended to fit within the investor’s objectives, strategies and risk profile as described by each client. The strategies utilized for these customized accounts may be similar to or may vary widely from the core strategies typically utilized by the Adviser, as further described in Item No. 8 or

customized for each client based upon varying factors. Clients may place targets on these accounts and may restrict the types of investments made in such accounts. Puente tailors investment advisory services to the individual needs of the client. The goals and objectives for each client are documented via new account documentation. Client profiles are created that reflect the stated goals and objective. Puente’s clients are allowed to impose restrictions on the investments in their account. All limitations and restrictions placed on accounts must be presented to Puente in writing. ➢ Other Non-Discretionary Advisory Services Adviser provides non-discretionary advisory services to all types of clients in accordance with a non- discretionary advisory agreement between Adviser and the client. Each agreement typically defines the services to be provided and if a fee is charged, the fees will also be agreed to in the advisory agreement. Adviser also provides recommendations and research regarding the investment of securities and cash in a client’s account. These services are individually tailored to each client’s needs and such advice may be provided to accounts with assets maintained at various third parties. ➢ Other Services Adviser may provide additional services for clients from time to time as agreed between the client and the Adviser. P a g e | 5 Additional General Information Other professionals (e.g., lawyers, accountants, insurance agents, etc.) may be recommended to clients or engaged directly by the client on an as-needed basis. Conflicts of interest related to recommendations of other professionals will be disclosed to the client in the event they should occur. Puente investment advisory agreements may not be assigned without client consent. Puente does not currently participate in any Wrap Fee Programs. Assets Under Management As of the date of this Brochure, Puente does not maintain any assets under management.