A3 CAPITAL ADVISORS

A3 Capital Advisors Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of A3 Capital Advisors. If you have any questions about the contents of this brochure, please contact us at (713) 447-5856 or by email at: drew@a3capitaltx.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about A3 Capital Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov. A3 Capital Advisors’ CRD number is: 338956. 5020 Montrose, Suite 500 Houston, TX 77006 (713) 447-5856 drew@a3capitaltx.com https://www.a3capitaladvisors.com/ Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 04/30/2026 i  Item 2: Material Changes A3 Capital Advisors has the following material changes to report. Material changes relate to A3 Capital Advisors’ policies, practices or conflicts of interest. • A3 Capital Advisors has added Performance-Based fees. (Items 5 and 6) • A3 Capital Advisors has updated its Assets Under Management. (Item 4) • A3 Capital Advisors has updated its primary address. (Cover Page) • A3 Capital Advisors has added Consulting services and fees. (Items 4 and 5) • A3 Capital Advisors has updated its Fee Schedule and minimum account size. (Items 5 and 7) • A3 Capital Advisors has disclosed custody due to Standing Letters of Authorization. (Item 15) • A3 Capital Advisors has updated Voting Client Securities (Proxy Voting). (Item 17) • A3 Capital Advisors has disclosed its website address. (Cover page) ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................4 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................6 Item 7: Types of Clients ..........................................................................................................................................6 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................6 Item 9: Disciplinary Information ...........................................................................................................................9 Item 10: Other Financial Industry Activities and Affiliations ...........................................................................9 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............10 Item 12: Brokerage Practices ................................................................................................................................11 Item 13: Review of Accounts ................................................................................................................................12 Item 14: Client Referrals and Other Compensation ..........................................................................................13 Item 15: Custody ....................................................................................................................................................14 Item 16: Investment Discretion ............................................................................................................................14 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................15 Item 18: Financial Information .............................................................................................................................15 iii  Item 4: Advisory Business A. Description of the Advisory Firm A3 Capital Advisors (hereinafter “A3CA”) is a Limited Liability Company organized in the State of Texas. The firm was formed in July 2025, and the principal owner is Andrew Thomas Anton. B. Types of Advisory Services Portfolio Management Services A3CA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. A3CA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring A3CA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. A3CA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. A3CA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of A3CA’s economic, investment or other financial interests. To meet its fiduciary obligations, A3CA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, A3CA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is A3CA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Consulting Services A3CA provides consulting services based on the specific needs of the client. Services typically involve periodic review of existing investments held away from A3CA, and recommendations based on that review. A3CA has no investment, trading, brokerage, or custodial authority over consulting client’s investments. The terms of the client-consultant 2  relationship and services to be provided are defined in A3CA’s Investment Consulting Agreement. Services Limited to Specific Types of Investments A3CA generally limits its investment advice to mutual funds, fixed income securities, equities and ETFs. A3CA may use other securities as well to help diversify a portfolio when applicable. Written Acknowledgement of Fiduciary Status When we provide investment advice to you 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. We also have a fiduciary duty under the Investment Advisers Act of 1940 with respect to all client 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. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions A3CA offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). 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 A3CA from properly servicing the client account, or if the restrictions would require A3CA to deviate from its standard suite of services, A3CA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. A3CA does not participate in wrap fee programs. 3  E. Assets Under Management A3CA has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $227,130,000 $0 January 2026 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $1,000,000 - AND UP 1.00% A3CA uses the value of the account as of the last business day of the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. These fees are generally negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of A3CA's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Performance-Based Portfolio Management Fees Total Assets Annual Management Fee (on all assets managed) Annual Performance Fee (on capital appreciation) TBD 0.70% 15% Some Qualified Clients may opt to pay an annual fee of 0.70% of assets under management along with a 15% performance fee based on capital appreciation. If the portfolio rises in value, then the client will pay 15% on that increase in value, but if the portfolio drops in value, then the client will not incur a new performance fee until the portfolio reaches the last highest value, adjusted for withdrawals and deposits, which is generally known as a “high water mark.” In general, a “Qualified Client” is: 1) a natural person or company who at the time of entering into such agreement has at least $1,100,000 under the management of the investment adviser; 4  2) a natural person or company who the adviser reasonably believes at the time of entering into the contract: (A) has a net worth of jointly with his or her spouse of more than $2,200,000 excluding the value of the client’s primary residence; or (B) is a qualified purchaser as defined in the Investment Company Act of 1940, §2(a)(51)(A) (15 U.S.C. 80a-2(51)(A)); or 3) a natural person who at the time of entering into the contract is: (A) An executive officer, director, trustee, general partner, or person serving in similar capacity of the investment adviser; or (B) An employee of the investment adviser (other than an employee performing solely clerical, secretarial, or administrative functions with regard to the investment adviser), who, in connection with his or her regular functions or duties, participates in the investment activities of such investment adviser, provided that such employee has been performing such functions and duties for or on behalf of the investment adviser, or substantially similar function or duties for or on behalf of another company for at least 12 months. Consulting Service Fees A3CA advisory consulting fees are based on a fixed rate amount for a specific period (i.e., annual, quarterly). Consulting rates are determined based on the scope of the services to be provided. The consulting fee rate and structure are mutually agreed upon and identified in the written Investment Consulting Agreement between A3CA and the client. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in arrears. Payment of Performance-Based Fees Performance-based fees are withdrawn directly from the client’s accounts with client’s written authorization. Fees are paid annually in arrears. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by A3CA. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees A3CA collects its fees in arrears. It does not collect fees in advance. 5  E. Outside Compensation For the Sale of Securities to Clients Neither A3CA nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management A3CA manages accounts that are billed on performance-based fees (a share of capital gains on or capital appreciation of the assets of a client) as well as accounts that are NOT billed on performance-based fees. Managing both kinds of accounts at the same time presents a conflict of interest because A3CA or its supervised persons have an incentive to favor accounts for which A3CA and its supervised persons receive a performance-based fee. A3CA addresses the conflicts by ensuring that clients are not systematically advantaged or disadvantaged due to the presence or absence of performance-based fees. A3CA seeks best execution and upholds its fiduciary duty for all clients. Clients that are paying a performance-based fee should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes.. Item 7: Types of Clients A3CA generally provides advisory services to High-Net-Worth Individuals. There is an account minimum of $1,000,000, which may be waived by A3CA in its discretion. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis A3CA’s methods of analysis include Fundamental analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Investment Strategies 6  A3CA uses long term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market 7  is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 8  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither A3CA nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither A3CA nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither A3CA nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections A3CA does not utilize nor select third-party investment advisers. 9  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics A3CA has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. A3CA's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests A3CA does not recommend that clients buy or sell any security in which a related person to A3CA or A3CA has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of A3CA may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of A3CA to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. A3CA will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of A3CA may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of A3CA to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, A3CA will never engage in trading that operates to the client’s disadvantage if representatives of A3CA buy or sell securities at or around the same time as clients. 10  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on A3CA’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and A3CA may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in A3CA's research efforts. A3CA will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. A3CA will require clients to use Schwab Institutional, a division of Charles Schwab & Co., Inc.. 1. Research and Other Soft-Dollar Benefits While A3CA has no formal soft dollars program in which soft dollars are used to pay for third party services, A3CA may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). A3CA may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and A3CA does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. A3CA benefits by not having to produce or pay for the research, products or services, and A3CA will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that A3CA’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals A3CA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use A3CA will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. 11  B. Aggregating (Block) Trading for Multiple Client Accounts If A3CA buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, A3CA would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. A3CA would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for A3CA's advisory services provided on an ongoing basis are reviewed at least quarterly by Andrew Thomas Anton, Managing Member and Chief Compliance Officer, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at A3CA are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of A3CA's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. A3CA will also provide at least quarterly a separate written statement to the client. 12  Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Other than soft dollar benefits as described in Item 12 above and below, A3CA does not receive any economic benefit, directly or indirectly from any third party for advice rendered to A3CA's clients. With respect to Schwab, A3CA receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For A3CA client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to A3CA other products and services that benefit A3CA but may not benefit its clients’ accounts. These benefits may include national, regional or A3CA specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of A3CA by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist A3CA in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of A3CA’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of A3CA’s accounts. Schwab Advisor Services also makes available to A3CA other services intended to help A3CA manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to A3CA by independent third parties. Schwab Advisor Services may 13  discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to A3CA. A3CA is independently owned and operated and not affiliated with Schwab. B. Compensation to Non – Advisory Personnel for Client Referrals A3CA does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, A3CA will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Standing Letters of Authorization (SLOA): A3CA is deemed to have constructive custody if a client has established a SLOA in their account held with Schwab. Constructive custody is defined by the SEC as access to client funds or securities without physical possession. The SLOA gives A3CA authority to transfer funds (to and/or from) the client account to another account, these instructions may or may not be in the client’s identical name. SLOA arrangements require that: • The client reaches out to A3CA and instruct movement of funds. The client then verifies the instructions in the SLOA already on file. A3 then directs Schwab to send the funds requested. • The client can terminate or alter the SLOA instructions to Schwab at any time • A3CA has no authority or ability to alter the SLOA instructions, only specify the amount • Schwab is responsible for confirming the SLOA instructions with the client when initially established and reconfirm the instructions annually. Consulting Services: A3CA does not have actual or constructive custody for clients with consulting services. A3CA serves in an advisory capacity only with no direct access or discretion of the client’s custodial/brokerage accounts. Item 16: Investment Discretion A3CA provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. 14  Where investment discretion has been granted, A3CA generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Item 17: Voting Client Securities (Proxy Voting) A3CA votes proxies for clients; however, clients have the right to vote their account proxies. Clients can instruct A3CA in writing to not vote proxies in their account or contact their custodian/broker and arrange to vote their account proxies. A3CA will vote proxies in the best interests of clients. A3CA will retain all proxy voting books and records for the required period including: a copy of each proxy statement received, a record of each vote cast, and any documentation deemed material to deciding on how to vote proxies. Clients may contact A3CA to obtain a copy of proxy voting policies and procedures. Clients may also request information on how their specific shares were voted. A3CA does not vote proxies for consulting clients. A3CA. Item 18: Financial Information A. Balance Sheet A3CA neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither A3CA nor its management has any financial condition that is likely to reasonably impair A3CA’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years A3CA has not been the subject of a bankruptcy petition in the last ten years. 15