BBVA GLOBAL WEALTH ADVISORS, INC.

ITEM 1: Cover Page ____________________________________________________________________________________________________ BBVA Global Wealth Advisors, Inc. Form ADV Part 2A - Firm Brochure (CRD # 327326) 501 Brickell Key Drive, Suite 601 Miami, FL 33131 Telephone: 305-205-7752 www.bbvaglobalwealthadvisors.com October 31st, 2025 This Form ADV Part 2A Disclosure Brochure provides information about the qualifications and business practices of BBVA Global Wealth Advisors, Inc., an investment advisory firm registered with the United States Securities and Exchange Commission. If you have questions about this Brochure's contents, please contact us at 305-205-7752 or email our Chief Compliance Officer at gwacompliance.group@bbva.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser’s services. This Brochure is on file with the appropriate regulatory authorities, as federal and state regulations require. The advisory services described in this Brochure are not insured or otherwise protected by the U.S. Government, Federal Deposit Insurance Corporation ("FDIC"), Federal Reserve Board, or any other government agency. Any money or securities deposited to participate in any BBVA Global Wealth Advisors, Inc. investment program is not a deposit or other obligation of Banco Bilbao Vizcaya Argentaria, S.A. ("BBVA S.A."), the parent company of BBVA Global Wealth Advisors, Inc., and is not guaranteed by the FDIC, BBVA S.A. or any of its affiliates. All investments involve risk, including the possible loss of the principal amount invested. Additional information about BBVA Global Wealth Advisors, Inc. is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in BBVA Global Wealth Advisors, Inc. or CRD # 327326. Results will provide you with all firm disclosure brochures.) 1  ITEM 2: Material Changes ____________________________________________________________________________________________________ BBVA Global Wealth Advisors, Inc. ("GWA” or the “Adviser”) reviews its Form ADV Part 2A Brochure at least annually to confirm it remains current. In this item, we are required to summarize only those material changes made to our Brochure since our last Annual Updating Amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last Annual Updating Amendment on March 21, 2025, we have the following material changes to report: Item 2: Material Changes  On May 27, 2025, we updated our Texas branch office address to 1980 Post Oak Boulevard, 10th Floor, Houston, TX 77056 (T: 305-205-7752).  In October, 2025, we established a custodial relationship with Bulltick, LLC (“BT”), CRD#: 104005 / SEC#: 8- 52493, a registered broker-dealer and member of FINRA, SIPC, and NFA, to provide custodial and execution services under applicable regulatory oversight. This arrangement was initiated to support client accounts that our current custodian, Pershing Advisor Solutions LLC (“PAS”), is unable to accommodate. BT is not affiliated with GWA or its parent company, BBVA S.A. The addition of BT introduces new material conflicts of interest, which are described in Items 10: Other Financial Industry Activities & Affiliations, Item 12: Brokerage Practices, and Item 14: Client Referrals & Other Compensation of this Brochure. These conflicts include personal relationships between BT’s management and certain GWA personnel and affiliates. GWA has adopted policies and procedures designed to identify, mitigate, and monitor these conflicts, and will provide additional disclosures as required under applicable SEC and state regulations.  Since the last annual update, GWA has expanded its advisory services to include discretionary portfolio management. Under this arrangement, clients authorize GWA to make investment decisions on their behalf, consistent with their stated objectives and without prior consultation for each transaction. This change is further described in Items 4: Advisory Business and 16: Investment Discretion of this Brochure. Item 4: Advisory Business Assets Under Management As of October 31st, 2025, our assets under management (“AUM”) total $ 1,208,850,630. The following represents client assets under management by account type: Type of Account Assets Under Management Discretionary Non-Discretionary Total $ 1,208,850,630 $ 0 $ 1,208,850,630 Full Brochure Availability At any time, we may amend this document to reflect material changes in our business practices, policies, procedures, or updates as mandated by securities regulators. Annually, within 120 days of the close of our fiscal year-end of December 31st, and as necessary due to material changes, we will provide clients either by electronic means or hard copy with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this document for future reference, as it contains essential information concerning our advisory services and business. You may view our current disclosure documents on the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either by our Firm name, BBVA Global Wealth Advisors, Inc. or CRD # 327326. 2  The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment Adviser Representative of the Firm. You may also request a copy free of charge by contacting us directly at 305-205-7752 or via email at gwacompliance.group@bbva.com. 3  ITEM 3: Table of Contents ____________________________________________________________________________________________________ ITEM 1: Cover Page.......................................................................................................................................................1 ITEM 2: Material Changes..............................................................................................................................................2 ITEM 3: Table of Contents..............................................................................................................................................4 ITEM 4: Advisory Business.............................................................................................................................................5 ITEM 5: Fees & Compensation.....................................................................................................................................10 ITEM 6: Performance-Based Fees & Side-By-Side Management................................................................................14 ITEM 7: Types of Clients...............................................................................................................................................14 ITEM 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss.......................15 ITEM 9: Disciplinary Information...................................................................................................................................20 ITEM 10: Other Financial Industry Activities & Affiliations............................................................................................21 ITEM 11: Code of Ethics, Participation Or Interest In Client Transactions & Personal Trading...................................23 ITEM 12: Brokerage Practices......................................................................................................................................25 ITEM 13: Reviews of Accounts.....................................................................................................................................29 ITEM 14: Client Referrals & Other Compensation........................................................................................................30 ITEM 15: Custody.........................................................................................................................................................31 ITEM 16: Investment Discretion...................................................................................................................................32 ITEM 17: Voting Client Securities................................................................................................................................33 ITEM 18: Financial Information....................................................................................................................................33 4  ITEM 4: Advisory Business ____________________________________________________________________________________________________ Overview BBVA Global Wealth Advisors, Inc. (“GWA” or “the Adviser”) was founded in February 2024 and incorporated in the state of Delaware. The Firm’s principal office and place of business is located at 501 Brickell Key Drive, Suite 601, Miami, Florida. GWA has been registered with the U.S. Securities and Exchange Commission as an investment adviser under the Investment Advisers Act of 1940, as amended (“Advisers Act”), since February 26, 2024. Principal Owners GWA is a non-bank wholly owned subsidiary of Banco Bilbao Vizcaya Argentaria, S.A. (“BBVA S.A.”), a publicly held global financial services institution and financial holding company, founded in Spain in 1857 and traded on the New York Stock Exchange (ticker: BBVA). BBVA S.A., one of the largest banks in Spain, owns the largest financial institution in Mexico and leading financial services franchises in South America. BBVA S.A. is also the leading shareholder in Garanti BBVA, a financial services company in Turkey, and has investment, transaction, and capital markets banking businesses in the U.S. The following paragraphs describe GWA's business practices, services, and fees. Conflicts of interest arising from the Adviser or its Associates are disclosed herein. Advisory Business As used in this Brochure, the words "we," "our," or "us" refer to GWA and the words "you," "your," and "client" refer to you as either a client or prospective client of our Firm. The term Associates refers to GWA's Supervised Persons - the Firm's Officers and Directors ("Control Persons"), employees, and the Investment Adviser Representatives of GWA ("Financial Advisors"), who are licensed as necessary for their roles and client base, supervised, and approved by GWA to provide investment advice or advisory services on behalf of the Adviser. GWA owes a fiduciary duty to clients, as defined under the applicable laws and regulations. As a fiduciary, GWA upholds a duty of loyalty, care, fairness, and good faith towards each client and seeks to mitigate potential conflicts of interest. In providing investment advice to clients, GWA strives to act with a high degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use. GWA's advisory services are made available to clients primarily through its Financial Advisors. Each advisory relationship at GWA is managed by one or more Financial Advisors registered with the Firm, who serve as the primary point of contact between GWA and the client. Financial Advisors collect financial profile and suitability information from clients and recommend specific advisory services or programs deemed appropriate after assessing the client’s situation, financial circumstances, goals, objectives and investor risk profile, amongst other considerations. Financial Advisors are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Financial Advisor can or can not recommend certain services, investments, or models depending on the licenses or training obtained and can transact business or respond to inquiries only in the state(s) and locations in which they are appropriately qualified. For more information about the Financial Advisor providing advisory services, clients should refer to their Financial Advisor's Form ADV 2B Brochure Supplement, a separate disclosure document offered to the client, along with this Brochure, before or at the time of relationship inception. (If the client did not receive a Form ADV 2B Brochure Supplement, they should contact their Financial Advisor or GWA directly.) GWA's advisory services are designed and aimed to complement clients’ needs, as described within its written services contracts (the "Investment Advisory Agreement," or "IAA") that disclose, in substance, the scope of service, contract term, advisory fee, formula for computing the fee, and type of authority granted to GWA. Final advisory fee structures are documented within the written IAA. Financial Advisors are restricted to providing the services and fees specified within each IAA, subject to the client's listed objectives, limitations, and restrictions. IAAs must be completed and executed to engage in GWA's advisory services. Clients can engage GWA for additional services at any time. (Please refer to Item 5: Fees & Compensation and Item 16: Investment Discretion for further details on advisory services fees and account management style.) Once established, no Investment Advisory Agreement can be assigned - within the meaning of the Advisers Act - by the Adviser without the client's consent as set forth in the Investment Advisory Agreement. (Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Advisers Act shall not be considered an assignment.) 5  Non-Exclusive Relationship GWA's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client's specific financial situation. Accordingly, since investment strategies and advice are custom-tailored based on each client's specific financial situation, the advice we provide to one client can differ or conflict with that provided for the same security or investment for another. (See Item 8: Methods of Analysis, Investment Strategies & Risk of Loss for additional information.) Other Professional Service Provider Recommendations GWA can recommend the services of other professionals for implementation purposes. These professionals, who can be lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. We do not receive referral fees for such recommendations, and clients are under no obligation to engage in any recommended professional services. Clients wishing to engage in such services will execute a separate agreement between the client and their selected referred professional(s). Unless disclosed otherwise, GWA is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any referred GWA client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider's separate contract, including fees and charges and for those charges when assessed, should they choose to engage the referred professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from GWA. If conflicts of interest related to recommendations of other professionals arise in the future, we will disclose them to you. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities GWA's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fulfill its fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills its responsibilities under its IAA. Financial Advisors will rely upon the accuracy of information furnished by the client or on their behalf without further investigation. GWA will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify GWA in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if earlier disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their IAA or our authority thereunder. GWA reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. The following is a summary description of advisory services covered by this Brochure. Clients should consult with their Financial Advisor and the applicable IAA and Fee Schedules for additional information regarding each service. Description of Advisory Services GWA is an investment advisory firm; it does not sell securities on a commission basis. Our Financial Advisors emphasize client contact and interaction in providing the following individually tailored investment advice and advisory services:  Portfolio Management Services  Wrap Fee Program Services* *The BBVA Global Wealth Advisors, Inc. Wrap Fee Program is offered to prospective and existing advisory clients with the option to make investment advisory services and transaction/commission costs available via a single fee in conjunction with GWA as Wrap Fee Program Manager and Sponsor for this Program. Please see GWA's Form ADV Part 2A Appendix 1 - Wrap Fee Brochure for complete details. 6  Portfolio Management Services With GWA's Portfolio Management Services, Financial Advisors will collect financial profile information from clients at the onset of the advisory relationship through personal discussions and the use of diagnostic questionnaires designed to help the Financial Advisor assess the client's objectives and determine their risk tolerance to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with agreed-upon, realistic and measurable goals set based on the disclosed information. According to the selected service(s), the client's written IAA will document the details of the advisory relationship and final advisory fee structure. GWA’s advisory services include recommending and analyzing investments, discussing market trends, and providing guidance with respect to investment product alternatives. Clients can evaluate specific trade ideas with their Financial Advisor and trade individual stocks, ETFs, structured notes, bonds, and funds, among others, with the assistance of GWA’s Investment Team. Investment advice is provided on a non-discretionary basis, meaning the client retains the final decision-making authority for each trade or investment decision in the account. Clients retain the unrestricted right to decline any advice provided by GWA on a non-discretionary basis. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss, and Item 16: Investment Discretion for additional details.) In connection with determining investments suited to a client's risk profile, GWA's Investment Team leverages investment analysis conducted by BBVA S.A.'s fund research team and reviews Investment Guides ("BBVA Investment Guides") developed by BBVA S.A.'s Global Wealth Investment Committee ("GWIC"), of which our Chief Investment Officer is a member. GWIC uses well-established investment principles and investment methodologies to develop the BBVA Investment Guides, which establish asset allocation target ranges for general client risk profiles. Typically drawing from the BBVA Investment Guides recommended by GWIC and/or other third-party information, our Investment Team develops asset allocation recommendations for our clients ("GWA Investment Guides"). (See “Types of Investments” below for additional information on the investment products used in client portfolios.) GWA does not provide advice with respect to the use of margin or securities lending. However, our advisory services are non- discretionary, and our clients can independently decide to enter into agreements with their Custodians related to using margin (i.e., leverage) in their accounts. In such cases, the Financial Advisor can facilitate the client's interaction with the Custodian for the purposes of margin investing. GWA’s Financial Advisors are not legal, estate planning or tax accounting professionals; neither GWA nor any of its Financial Advisors provides legal, estate planning, or tax advice. Clients should consult their own legal, estate planning, tax accounting and other professional advisers before implementing any investment strategy their Financial Advisor recommends. Investor Profile Through a collaborative process with each client, GWA will create an Investor Risk Profile (“IRP” or “Profile”), which will be used to determine the appropriate investment mix for the client. Financial Advisors will confer with the client periodically to review the client's investment objectives and investment mix and make a reasonable effort to confirm or update the written client information to keep the data current, no less than annually. The IRP is created using a combination of the client's responses to a questionnaire designed to help determine investment goals, financial market expertise, liquidity needs, time horizon, risk tolerance and other relevant information gathered through personal client discussions and the overall client relationship. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. The information clients supply will become the basis for a strategic asset allocation plan designed to assist the client in striving to meet their expressed personal short and long-term financial goals and objectives. Based on the data gathered, the client's questionnaire replies, and the set of guidelines established by GWA, the client will be classified into one of the following four Profiles: 1. Conservative Risk Profile – Investor with a low-risk tolerance looking for capital preservation at the end of a defined investment period. 2. Moderate Risk Profile – Investor with a moderate risk tolerance, looking to grow capital above the inflation rate in the long term. Willing to invest a moderate percentage of assets in US and non-US equities and accept a moderate amount of volatility. 7  3. Moderately Aggressive Risk Profile – Investor with a higher risk tolerance, willing to invest a higher percentage of assets in US and non-US equities and riskier securities. Looking to enhance returns and willing to accept a higher level of volatility. Even though the foundation of the portfolio construction process for Moderately Aggressive investors generally takes a long-term approach, shorter-term goals might have a higher priority in this portfolio. 4. Aggressive Risk Profile – Investor with a very high-risk tolerance, willing to invest an even higher percentage of assets in US and non-US equities and riskier securities. Looking to maximize returns and willing to accept a significantly higher level of volatility. Even though the foundation of the portfolio construction process for Aggressive investors generally takes a long-term approach, shorter-term goals might have an even higher priority in this portfolio. Portfolio Construction Each client IRP typically maps to a GWA Investment Guide, which represents the recommended asset allocation for the respective IRP. The GWA Investment Guides incorporate strategic (long-term) and tactical (short-term) components. The overarching principles of the GWA Investment Guide development process are as follows:  Asset selection, liquidity, and risk tolerance are key considerations when constructing asset allocation guidelines for a given IRP.  Diversification is necessary and fundamental to navigate and reduce volatility; concentration could increase risk and volatility.  Valuations are important in assessing the intrinsic value of an asset, determining whether it is overvalued or undervalued, and informing the decision to buy, sell, or hold the asset based on its fair value versus its market price. and  A disciplined allocation process can steer an investor away from making decisions based on emotional biases. When determining the Investment Solution for a particular client risk profile, as previously noted, GWA analyzes various products before recommending to its clients a customized portfolio appropriate for each client's IRP and in accordance with the client's risk tolerances and investment objectives. Client portfolios are reviewed through an ongoing process of assessing client objectives, developing an appropriate asset allocation that seeks to achieve those objectives, and modifying that allocation as necessary to address risks and opportunities. Client Tailored Services GWA offers the same suite of services to all its clients. However, some clients will require only limited services due to the nature of their investments. Limited services are discounted at GWA’s discretion, as detailed herein and defined in each client's written IAA. (For more information, see Item 5: Fees & Compensation.) Client Imposed Restrictions Clients can, at any time, impose restrictions on investing in particular securities or security types according to their preferences, values, or beliefs. Such restrictions must be submitted to GWA in writing. Clients can also amend/change such limitations by once again providing written instructions. Reasonable efforts are made to comply with client investment guidelines, including any client's reasonable limits, by standard industry practices. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similar account without restrictions. It is important to note that client-imposed restrictions within their account and variations could result in positive or negative performance differences for the account compared to accounts without such restrictions. The restrictions can also potentially prevent achieving a client's specific goals. Upon receiving a client's written restrictions, GWA will discuss the restriction request's feasibility to confirm expectations are met and verify the client's acknowledgment and understanding of the imposed restriction's possible outcomes. GWA reserves the right to either reject client-imposed restrictions or end the client relationship. Client-imposed restrictions will not be effective unless accepted by GWA in writing. In no event, regardless of the advisory service provided, is GWA obligated to make any investment or enter into any transaction it believes in good faith would violate any federal or state law or regulation. 8  Wrap Fee Program Services Under our Wrap Fee Program Services, GWA is the Sponsor and investment adviser of the GWA Portfolio Adviser Program (the "Wrap Fee Program" or “Program”), which differs from a regular advisory services account in that clients receive both investment advisory services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee" or "Wrap Fee") regardless of the number of trades completed by a client. The assets in each Wrap Fee Program are regularly monitored, with investment strategy purchase and sale transactions based on the client's specific needs and investment goals. Wrap Fee Program clients will undergo the same collection of client profile information and analysis as indicated in the preceding section and enter into a separate IAA to participate in the Program that sets forth the terms and conditions of the engagement, describes the scope of the services to be provided, fees to be paid, and the type of authority granted to GWA. Final advisory fee structures are documented within the written IAA. Clients will then invest in the Wrap Fee Program by establishing one or more accounts with the Wrap Fee Program's Qualified Custodian. Generally, clients participating in this type of Program will pay the Wrap Fee to the Program Sponsor quarterly in arrears, based on a percentage of assets under management. With the client’s written permission, the Custodian will debit this payment from the client’s account. GWA passes on a portion of the Wrap Fee to the Broker-Dealer partner of the program for its services (e.g., execution of securities brokerage transactions) and retains a portion of the Wrap Fee for the advisory services it provides. The overall costs clients will incur if they participate in our Wrap Fee Programs can be higher or lower than they could incur by separately purchasing the types of securities available in the Program. Clients should be aware that a conflict of interest exists whenever GWA recommends participating in its Wrap Fee Program. Because the Wrap Fee Program has a higher fee, Financial Advisors have a slight incentive to offer it over a non-wrap fee program, so they could be financially incentivized to recommend such a service. The SEC rules require that a Wrap Fee Brochure be provided to clients before or when entering a Wrap Fee Program Agreement. GWA has prepared a Wrap Fee Brochure that provides clients with important information about our Program, including further information about the services and fees participating clients will pay. (Please see GWA's Form ADV Part 2A Appendix 1 - Wrap Fee Program Brochure for complete details on this advisory service offering.) Types of Investments GWA's investment advisory services are designed to accommodate a wide range of investment philosophies and objectives. We primarily offer advice on the products selected by the GWA Investment Team after careful analysis - specific mutual funds, exchange-traded funds ("ETFs"), equities, fixed-income investments, structured products (including structured notes), pooled investment vehicles, including but not limited to funds established in accordance with the European Union's Undertaking for Collective Investment in Transferable Securities Directive ("UCITS"), and alternative investments (collectively, the "Investment Solutions") that can be recommended to our clients. The GWA Investment Team uses proprietary research as well as research prepared by BBVA S.A. and third parties when selecting our Investment Solutions. The GWA Investment Guide for a client, together with the Investment Solutions recommended to and approved by the client, is collectively referred to as the client's Investment Portfolio. (See Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss for additional information.) Although GWA provides advice predominantly on the products listed above, the Adviser reserves the right to offer advice on any investment product deemed suitable for a client's specific circumstances, needs, individual goals, and objectives and can use other securities to help diversify a portfolio when appropriate. Before acting on any analysis, advice, or recommendation, GWA recommends prospective investors consult with their legal counsel, tax, and other financial investment professionals, as necessary, to aid in due diligence as proper for their situation and determine the suitability of the risk associated with any investment. (For additional information on investment considerations, see Item 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss.) Conflicts of Interest Clients should be aware that the specific advisory services selected and the compensation to GWA and their Financial Advisor will differ according to the exact service chosen. The compensation we receive can be greater than the amounts otherwise received had the client participated in another service or paid separately for investment advice, brokerage, or other relevant services. 9  Due to the differences in fee schedules among the various advisory programs and services offered by GWA and the client’s Financial Advisor, a conflict of interest exists when there is a financial incentive to recommend a particular service over others. Factors that bear upon the cost of a specific advisory program in relation to the cost of the same services purchased separately include, but are not limited to, the type and size of the account, the historical and expected size or number of trades for the account, and the number and range of supplementary advisory and client-related services provided to the account. Clients are under no obligation to act upon any recommendations or purchase any products or services offered. If they elect to act on any recommendation received, they are not obligated to place the transaction through GWA or any recommended third party. The client can act on recommendations received by placing their business and securities transactions with any brokerage of their choice. GWA does not represent that the products or services offered are at the lowest available cost - clients could be able to obtain the same or similar products or services at a lower price from other providers. GWA has adopted and implemented compliance policies and procedures and a Code of Ethics (“Code”) to mitigate conflicts of interest. GWA’s Code is available for review free of charge to any client or prospective client upon request. Assets Under Management As of October 31st, 2025, our assets under management total approximately $ 1,208,850,630. The following represents client assets under management by account type: Type of Account Assets Under Management Discretionary Non-Discretionary Total $ $ 0 $ ITEM 5: Fees & Compensation ____________________________________________________________________________________________________ Advisory Services Fees & Compensation GWA’s advisory clients agree to pay an asset-based advisory fee calculated according to the schedules indicated herein. (Note: Wrap Fee Program clients should review GWA's Form ADV Part 2A Appendix 1 - Wrap Fee Brochure for information about the fees associated with that advisory service.) Fee Negotiation Availability Advisory fees are negotiable up to the maximum annual rates listed herein, subject to certain limitations and approval by GWA. The Adviser, in its sole discretion, can charge lesser fees or choose to reduce or waive minimum fees for services based upon specific criteria such as pre-existing client relationships, the number of related investment accounts, inception date, total account assets under management, expected additional assets, anticipated future earning capacity, account composition, and client negotiations, among others. At GWA’s discretion, certain employee accounts or those for members of a client's family or otherwise can be assessed fees based on the total balance of all accounts. While GWA seeks to facilitate advantageous agreements for clients, to the extent fees are negotiable, some clients can pay higher (more) or lower (less) fees than other clients for services than if they had contracted directly with another provider. According to the selected advisory services, the final fee structures will be reflected in each client's written IAA. Lower fees for comparable services can sometimes be available from other sources. In all cases, clients are responsible for any tax liabilities that result from any transactions. Regardless of fee negotiation availability, under no circumstances will a client be required to pre-pay a GWA advisory fee more than six months in advance, in excess of $1,200. Portfolio Management Services Fees Schedule of Fees GWA’s Portfolio Management Services fees are generally assessed using a tiered annual fee calculation. The schedule of fees below identifies rates for various account value ranges based on the account size (i.e., the “assets under management”): 10  Schedule of Fees Total Assets Under Management $500,000 - $1,000,000 $1,000,001 - $7,500,000 $7,500,001 + Annual Fees 2.00% 1.50% 0.90% *Note: We will charge 2.00% if any Advisory Service account's average daily balance for the quarter is between $250,001-$499,999. We charge a minimum annual fee of $5,000 for Advisory Services accounts that fall below $250,000 (in terms of average daily balance in a quarter). Lower fees for comparable services can sometimes be available from other sources. Fee Calculation Except as otherwise described in this section, advisory fees are calculated on the average daily balance of your account and billed quarterly in arrears, based on the net asset value of each account during the billing period, including assets invested in cash and cash equivalents, accrued interest, and dividends, but excluding the amount of outstanding margin balances. If an IAA is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro-rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Assets under management include all U.S. securities, non-U.S. securities, cash and other instruments in a client's account advised by GWA. GWA considers cash to be an asset class. Depending on market conditions, investment advisory strategies often involve moving to cash positions for varying periods. As a result, cash balances are included in the value of the assets under our management that are the basis for charging our advisory fee unless otherwise noted in the IAA (i.e., outstanding margin balances). The advisory fee billed to the cash portion of client accounts will exceed money market yields when rates for such money market funds are lower than the advisory fees charged to the account. To calculate an account's net asset balance, we deduct the amount of any outstanding margin balances from the account's total gross asset balance, but do not deduct the amount of any outstanding non-purpose loan balances. Securities without a readily available market price are valued at fair value, as determined in good faith by the Custodian. With respect to client account assets in alternative investments, alternative investment managers and underlying vehicles are responsible for providing the Custodian with an asset's valuation in accordance with applicable laws. Fee Billing GWA's policy is to deduct its advisory fee directly from client accounts through the Custodian holding your funds and securities as authorized in the IAA. No other method of fee payment is accepted. Advisory fee deduction will occur only when the following requirements are met: 1. Clients must authorize GWA in writing to directly deduct advisory fees due from their Custodial account and provide the Custodian with authorization to deduct such fees and instructions to remit them directly to GWA. 2. The account Custodian agrees to send the client a statement, at least quarterly, indicating all amounts disbursed from their account, including the amount of the advisory fee paid directly to GWA. GWA’s account advisory fee will be payable first from free credit balances, money market funds, or cash equivalents, if any, and second from liquidating a portion of the client’s securities holdings. Please note that ongoing fees reduce the value of an investment portfolio over time. When our advisory fee is debited from the portfolio's assets, clients have less money invested to generate a return. Clients are encouraged to discuss the impact of fees with their Financial Advisor. When authorized by the client to debit advisory fees from client accounts, GWA is deemed to have custody of client assets to the extent the adviser is permitted to instruct Custodians to deduct the fees. We urge clients to compare their Custodial account statements with any portfolio report or data they may receive from us promptly upon receipt to ensure the accuracy of account transactions. Information obtained from us can vary based on accounting procedures, reporting dates, or valuation methodologies. If you find any inconsistent information between our invoice and the statement(s) you receive from your Custodian, contact us directly at 305-205-7752. If a client is not receiving statements directly from their Custodian, in addition to promptly advising their Financial Advisor, GWA also recommends that they contact their Custodian directly. 11  Account Additions, Withdrawals & Terminations Clients can make additions to their GWA accounts in cash or securities at any time. GWA reserves the right to liquidate any transferred securities or decline to accept particular securities into the client's account, according to the type of authority granted to GWA. If GWA liquidates transferred securities, clients can be subject to additional fees such as transaction fees, other fees assessed at the mutual fund level, such as contingent deferred sales charges, and tax ramifications. Clients can make withdrawals from their GWA accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures and costs. Additionally, if the client transfers their account to another firm, they can pay an outgoing account transfer fee to the Custodian. Generally, account terminations can be made to a GWA services IAA by written notice without penalty within five (5) business days after the Agreement execution date. After that, the IAA between GWA and the client will continue in effect until either party terminates the IAA following the terms of the Agreement, which states the IAA can be terminated by either party upon at least ten (10) days written notice to the other party. (Note: A "business day" shall be any day when the New York Stock Exchange is open for trading.) Terminations become effective on receipt of such notice and will not affect: the validity of any action previously taken by the Adviser under the Agreement, liabilities or obligations of the parties from transactions initiated before termination of the Agreement, or the client's obligation to pay management and other fees due, prorated through the termination date.    Upon receiving the termination notice of the agreement, GWA will take steps to deliver cash/and/or securities as per the client's instructions. If securities are liquidated, clients can incur liquidation fees or contingent deferred sales charges. Depending on market conditions, a liquidation can result in a loss. In addition, the Custodian or Broker-Dealer liquidating the security positions can impose additional fees. If the client holds certain alternative investments and/or illiquid securities, they may have to wait for specific redemption schedules. GWA bills the client in arrears for services that have already been rendered. Therefore, there is no need to refund any unearned advisory fees at account termination. If the client is a natural person, the client's death, disability, or incompetency will not terminate or change the terms of an Agreement. Instead, the Agreement shall immediately terminate upon the Adviser’s receipt of proof of the client's death and a duly authorized representative’s written instruction to terminate the Agreement. The disability or incompetency of the client will also not terminate or change the terms of the Agreement; however, the client’s duly authorized representative can terminate the Agreement by giving written notice to GWA. Before termination, all directions given or actions taken or omitted by GWA before the effective Agreement termination shall be binding upon the client and any successor or legal representative. The Adviser will no longer be entitled to receive fees from the termination date and has no obligation to recommend or act concerning an account's securities, cash, or other investments under the terminated Agreement. Wrap Fee Program Services Fees GWA’s Wrap Fee Program Services fees for the GWA Portfolio Adviser Program are asset-based fees that will include investment advisory services fees and the fees for most of the brokerage, custody, clearance, settlement, and other administrative services and transaction costs to the Broker-Dealer/Custodian with custody of the client’s assets and, therefore, are usually higher than a typical asset-based advisory fee. GWA will receive a portion of the Wrap Fee for its services. Wrap Fees are generally calculated on the average daily balance of your account and billed quarterly in arrears, based on the net asset value of each account during the billing period, including assets invested in cash and cash equivalents, accrued interest, and dividends, but excluding the amount of outstanding margin balances. (For complete details, refer to GWA’s Form ADV Part 2A – Appendix 1 Wrap Fee Brochure and the Wrap Fee Program IAA.) Other Fees & Expenses Mutual Funds, ETFs & Pooled Investment Vehicle Fees Mutual funds generally offer multiple share classes available for investment based on specific eligibility and/or purchase requirements. If such investments are selected for a client's account, the client and all other shareholders will pay the funds' investment managers an advisory fee. In addition to those underlying advisory fees, the client will bear a proportionate share of 12  the funds' expenses, which can include 12b-1 fees and shareholder sub-accounting and distribution expenses. Each offering prospectus will describe the offering’s complete fees and expenses, which can vary depending on the share class. Depending on the share class selected, fees and internal expenses charged can be higher or lower. Certain funds do not charge a transaction fee but have higher internal expenses. Selecting funds with higher fees and expenses can adversely impact an account's long-term performance. The appropriateness of a particular fund share class selection depends upon several considerations. Further, not all funds and share classes offered to the public are available through the Firm for which a client might otherwise be eligible to purchase. Clients should consider the fees these investments charge and our fees to fully understand the total amount paid when evaluating the advisory services provided. Prior to recommending this type of purchase, the Financial Advisor will undertake an analysis to determine whether the recommended share class of the fund is in the client's best interest. When recommending these investments, it is GWA's policy to consider all available share classes and select and recommend, whenever possible, that clients invest in the lowest cost share class available based on the client’s needs and various other factors, including but not limited to minimum investment requirements, trading restrictions, internal expense structure, transaction charges and availability, among others. Therefore, in most cases, GWA will recommend institutional or adviser share classes with these lowest expense ratios, which are less expensive than other share classes and are usually available to investors in qualified fee-based adviser programs or accounts that meet certain minimum investment requirements. When deemed appropriate for an investor's specific situation, Financial Advisors can, at times, also recommend selecting or holding a mutual fund share class that charges higher internal expenses than other available share classes for the same family. For share classes transferred in from other institutions, GWA’s Financial Advisors will, as soon as practicable upon receipt, evaluate whether more appropriate share classes may be available for the client to exchange at no cost and recommend that the client switches to a lower-cost share class, or can recommend liquidating the existing holdings, which could result in the client having to pay contingent deferred sales charges, or other redemption fees and tax implications. Regardless of such considerations, GWA clients should not assume they will be invested in the share class with the lowest possible expense ratio. Fees Charged by Other Financial Institutions In addition to the above, clients should also be aware that GWA's advisory fees are exclusive of bank, custodial or brokerage fees, commissions, trading and transactional costs, liquidation/transfer/termination fees, costs associated with certificate delivery or dealer profits, taxes, duties, and other governmental charges on brokerage accounts and securities transactions, wire and other transfer fees, mark-ups, mark-downs, regulatory fees, and other costs and expenses for the trades conducted in their Custodial accounts. Portfolios can also include transactions in foreign securities and execution on foreign stock exchanges that can result in foreign or other transaction expenses and costs associated with international exchange transactions. Additional securities fees and expenses can also be incurred and will vary considerably based on individual portfolio construction. For example, other customary fees and expenses clients can pay to other parties in connection with their portfolio accounts can include, but are not limited to: Margin Interest - the interest the client pays to a Broker-Dealer/Qualified Custodian on loans made to finance the purchase or sale of securities or securities in their investment account. The interest rate charged and other information about the loan, including how interest is calculated and other disclosures of risk and liability, will be described to the client in the separate margin agreement that the client executes with their Broker-Dealer/Qualified Custodian. Fees for advice and execution on these securities are based on the total asset value of the account, which includes the value of the securities purchased on margin. While a negative amount may be shown on a client's statement for the margined security due to a lower net market value, the fee amount GWA charges for our advisory services is based on the absolute market value of the client’s account. To calculate an account’s net asset balance, we deduct the amount of any outstanding margin balances from the account’s total gross asset balance, but do not deduct the amount of any outstanding non-purpose loan balances. This means if a client chooses to loan their securities, GWA will only charge the fee on the net value of the account (i.e., we will discount the net margin balance). Using margin can also result in interest charges and all other fees and expenses associated with the security involved. Securities Execution Transaction Fees – the fees charged by a clearing Broker-Dealer to an introducing Broker-Dealer and passed through to the client for payment relating to the purchase and sale of securities in their investment account. 13  A schedule of charges relating to the purchase and sales by type of security is provided to the client by each account’s Broker-Dealer/Qualified Custodian of record, as well as any changes or updates to such fee schedules. All fees paid to GWA for investment advisory services are separate and distinct from the asset-based management fees charged by managers of mutual funds, ETFs, and pooled investment vehicles in which a client invests, as well as those other additional fees discussed herein. GWA does not receive any portion of these fees, commissions, costs, or expenses; they are separate, distinct, exclusive of and in addition to GWA’s advisory services fees. To fully understand the total account costs they will pay, it is the client’s responsibility to read and understand not only this document and GWA’s IAA but also the offering documents, prospectus, disclosures, and other legal documentation that explain the difference in the fees, costs, expenses, commissions and other related information for securities purchased or sold in the client’s investment account as well as the disclosures made regarding all fees charged by GWA, the Broker-Dealer/Qualified Custodian, and others, as applicable for the type of account established. GWA does not represent that the products or services offered through our Firm are provided at the lowest cost. Clients could obtain the same or similar products or services at a lower price from other providers, and will choose whether to act on recommendations to purchase investment products. If clients decide to purchase a recommended investment product, they can buy the same or a similar one through any broker or agent, including those not affiliated with GWA. Please note that GWA expects to recommend certain funds managed by its affiliates. (See Item 8: Methods of Analysis, Investment Strategies & Risk of Loss, Item 10, Financial Industry Activities and Affiliations, and Item 12: Brokerage Practices for additional information and, for Wrap Fee Program clients, GWA’s Form ADV Part 2A - Appendix 1 for details about the fees associated with our advisory service offerings.) Before acting on GWA’s analysis, advice, or recommendation, clients should consult with their legal counsel, tax, or other investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the risk suitability of the investment under consideration. Investment products are not FDIC insured, insured by any federal government agency, or a deposit, other obligation of, or guaranteed by GWA. ITEM 6: Performance-Based Fees & Side-By-Side Management ____________________________________________________________________________________________________ Performance-based fees are based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. GWA does not accept performance-based fees nor participate in side-by-side management. ITEM 7: Types Of Clients ____________________________________________________________________________________________________ Types of Clients GWA generally provides advisory services to individuals, high-net-worth individuals, businesses, and family offices. Minimum Investment We generally require a minimum account size of $500,000 to open and maintain an account with us. We will charge 2% for Advisory Services accounts if any account's average daily balance for the quarter is between $250,001-$499,999. We charge a minimum annual fee of $5,000 for Advisory Services accounts that fall below $250,000 (in terms of the average daily balance in a quarter), but we reserve the right to reduce, increase, or waive the minimum account size, terminate accounts that fall below the minimum established requirements, require additional funds be deposited to bring a client account value up to the required minimum or waive advisory fees and account minimums for employee, employee-related, or affiliate employee accounts. Certain investment products can require annual minimum fees or minimum asset levels for participation. We can also waive account advisory fees or account minimums for employee, employee-related, and affiliate employee accounts. There are no ongoing contribution requirements for client accounts. Clients should thoroughly review disclosure materials or brochures and consult with their Financial Advisor about the implications of such minimum requirements before investing in such products. 14  ITEM 8: Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss ____________________________________________________________________________________________________ Methods of Analysis GWA uses various methods/techniques of analysis to inform the development of Investment Guides and recommendations of Investment Solutions for its clients, including: Fundamental Analysis - a method that measures intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the asset value, including macroeconomic factors (i.e., the overall economy and industry conditions) and company-specific factors (i.e., the general financial health of companies, quality of management, or competitive advantages). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the asset’s current price, with the aim of figuring out what sort of position to take with that asset(underpriced = buy, overpriced = sell or short). This method is considered the opposite of technical analysis. The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If asset prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Macroeconomic Analysis - focuses on the performance of economies and economic variables like inflation, interest, foreign exchange rates and growth, with risk that includes the uncertainty of projections. Modern Portfolio Theory - an investment theory that attempts to maximize a portfolio's expected return for a given amount of risk or, equivalently, minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset classes. GWA utilizes modern portfolio theory as a principle underlying its asset allocation processes. Quantitative Analysis - an analysis technique that deals with measurable factors (as distinguished from qualitative considerations) and seeks to understand behavior using complex mathematical and statistical modeling, measurement, and research, including, for example, the value of assets, the cost of capital, and diverse statistical measures. By assigning a numerical value to variables, quantitative analysts try to replicate reality mathematically. Some believe that it can also be used to predict real-world events, such as changes in a share price. Some risks of this type of analysis include the difficulty, time, and costs required to collect and conduct the data analysis. Technical Analysis (“Charting”) - a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that the performance of the stock, rather than the performance of the company itself, has more to do with the company’s future stock price. Some risks of this type of analysis include biased opinions or indicators that, while providing possible entry and exit points and information for consideration, can produce false or conflicting signals or not be 100% accurate in their forecasting. GWA may use this technique from time to time to generate tactical ideas for buying and/or selling a security. Investment Strategies Our investment strategies and advice will vary depending on each client's financial situation, as we determine investments and allocations based on the client’s predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors appropriately identified and included in the client’s best interest objective. Client restrictions and guidelines will also affect the composition of the client’s portfolio. The following are other items that can also be items for consideration when determining investment strategies and practices: Asset Allocation To construct client portfolios, GWA follows an asset allocation process incorporating both a strategic and a tactical component. GWA considers, as an input, the "Investment Guides" published by BBVA S.A.'s GWIC, which specify target exposure ranges for various asset classes for different client risk profiles. GWA then develops its own asset allocation recommendations, which are reviewed and adjusted periodically based on the evolution of macroeconomic factors, market performance and other quantitative and qualitative factors. Strategic Asset Allocation ("SAA" ) - SAA is part of GWA's asset allocation process. SAA analyzes the risk and return characteristics of asset classes over a longer time horizon. As part of this process, and recognizing that future 15  performance cannot be determined with any level of certainty, we aim to estimate the long-term expected risk and returns of various asset classes. These estimates are based primarily on a comprehensive analysis of various factors, including historical data, economic indicators, market trends, and fundamental analysis. Longer time horizons generally provide more confidence in estimates of asset class returns and risks. The long-term risk and return estimates of asset classes are reviewed periodically twice a year, as well as in extreme market situations, in order to assess how changes in macroeconomic conditions and recent market performance modify our estimates of asset returns. Tactical Asset Allocation ("TAA") - TAA is part of GWA's asset allocation process. TAA is an active management strategy based on macroeconomic, sentiment, and momentum factors aimed at managing portfolio risk and returns with an approximate time horizon of less than a year. At GWA, we attempt to identify and take advantage of inefficiencies, opportunities, and dislocations that can arise in the markets at specific times with shorter time horizons. For certain client risk profiles, especially those that tolerate a higher degree of risk, GWA can implement a tactical investment approach for such clients' portfolios. Tactical Investment Ideas - at GWA, we attempt to identify and take advantage of inefficiencies, opportunities, and dislocations that can arise in the markets at specific times with shorter time horizons. For certain client risk profiles, especially those that tolerate a higher degree of risk, GWA can implement a tactical investment approach for such clients’ portfolios. Funds, ETF & UCITS Selection Our Investment Team leverages investment analysis and research conducted by BBVA S.A.'s fund research team, including with respect to pooled investment vehicles ("funds") and ETFs. BBVA S.A.'s research analyzes a combination of quantitative and qualitative criteria, including various measures of returns and risks across different time horizons, and categorizes funds, ETFs, and UCITS into comparable groupings. The qualitative analysis complements and reinforces the results of the quantitative analysis. GWA can consider this fund, ETF, and UCITS research in developing its client recommendations. Based on its analysis of the various funds, ETFs, and UCITS, the GWA Investment Team selects and highlights the most appropriate alternatives within each asset class and each IRP.. While GWA’s Financial Advisors can provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. However, when balancing portfolios, GWA will consider only the account’s managed assets, not other investments the client may hold elsewhere. Cash Management In managing the cash maintained in your account, GWA will utilize only the cash vehicles (i.e., money market funds) made available by the client’s Custodian. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. There may be other cash management options away from the Custodian available to clients with higher yields or safer underlying investments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments could have unique and significant tax implications. However, tax efficiency will not be our primary consideration when managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and Broker-Dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately and alert the account Custodian of your individually selected accounting method. (Please note that all decisions regarding cost-based accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement.) Risks of Loss & Other Types of Risk Investing in securities involves a risk of loss that clients should be prepared to bear. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. GWA 16  cannot guarantee or promise that a client's financial goals and objectives will be met (including the investments and/or investment strategies recommended by GWA) or that investments will be profitable or achieve any specific level of performance. GWA does not represent or guarantee that the services provided or its analysis methods can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner or that your financial goals and objectives will be met. All investment programs have certain risks that the investor bears, and our investment approach keeps the risk of loss in mind. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including those listed below) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will achieve any particular result, tax, or legal consequence. An investment could lose money over short or even long periods. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Every method of analysis has its inherent risks. For example, GWA relies on historical, current, and new market information to perform market analysis. GWA has no control over the dissemination rate of market information; therefore, unbeknownst to us, certain analyses may be compiled with outdated market information, limiting the value of our analysis. In addition, an accurate market analysis can only produce a forecast of the direction of market values. There can be no assurance that a forecasted market value change will materialize into actionable or profitable investment opportunities. Each of GWA's primary investment strategies – Asset Allocation, Tactical Investment Ideas and Funds/ETF Selection – can have its own inherent risks and limitations. For example, longer-term investment strategies generally require a more extended investment period to allow for the strategy to potentially develop. Short-term investment strategies can incur higher transactional costs than a longer-term investment strategy. GWA's Investment Solutions allocates client investment assets primarily among various individual equity and fixed-income securities, mutual funds, UCITS, and/or ETFs in accordance with the client's designated investment objectives and risk tolerances. These securities have associated risks, as described below. The following risks for the various types of investments used by GWA in clients’ investment portfolios, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services. The common risks of loss described in this section are intended as a high-level overview. Clients should carefully review other disclosure documents for a complete discussion of the risks attributable to an individual investment, including, but not limited to, prospectuses, term sheets, pricing supplements, and structured note documentation. Note: Items are presented alphabetically for ease of reading, not in order of importance. Risks include, but are not limited to: Equities - Equity investment generally refers to buying shares of stocks in individual companies 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 environment. Exposure to equity securities may result in the following risks, among others: Emerging Market Stocks - Emerging market stocks may have higher political risk, as sometimes governments are less stable than in developed economies. Emerging market stocks can also be subject to more volatile economic environments that could lead to earnings fluctuations and currency risks that could lower the value of the investment. Growth Stocks - Growth stocks may be more sensitive to market movements because their prices tend to reflect future investor expectations rather than just current profits. Initial Public Offerings - Initial public offerings ("IPOs") are subject to high volatility and limited availability. 17  Small-Capitalization ("Small-Cap") Companies - Small-cap stocks may exhibit erratic earnings patterns, competitive conditions, limited earnings history, and a reliance on one or a limited number of products. Value Stocks - Value stocks may perform differently from the market as a whole and may be undervalued by the market for an extended period. ETFs - An ETF is a pooled investment fund, the shares of which trade on a stock exchange at market price in a manner similar to shares of stock issued by individual companies. Investors in ETFs are exposed to the risks associated with the ETF's underlying portfolio (i.e., equities or fixed-income risk, as described above). The market price of an ETF may not always reflect the value of the underlying portfolio, and ETFs may trade at a premium or a discount to the net asset value of the underlying portfolio. Fixed Income - 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 (or "junk") bonds, investment grade debt and structured products (including structured notes). In general, the fixed-income market is volatile, and fixed-income securities carry interest rate risk. Fixed-income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties (all as described below). Treasury inflation-protected/inflation-linked bonds are backed by the "full faith and credit" of the U.S. government and generally have negligible credit risk; however, they carry a potential risk of losing value. Risks of investing in foreign fixed-income securities also include the general risk of non-U.S. investing described below in the "Foreign Securities" section. Different types of fixed-income securities can have different characteristics and associated risks: Call Risk - Issuers of callable bonds have the option to redeem the bonds before maturity, which can leave investors with reinvestment risk if the bonds are called in a declining interest rate environment. Credit & Default Risks - Both issuers and counterparties of fixed-income securities carry credit risk, which pertains to the issuer's ability to meet its debt obligations. Default risk is the potential that the issuer might fail to make interest or principal payments. Corporate & Government Debt Securities - Corporate bonds offer the potential for higher yields compared to government bonds, but they also carry higher credit risk. Government bonds, particularly those issued by stable governments, are considered relatively safe, but they might offer lower yields. Both types of bonds can be influenced by changes in interest rates, potentially affecting their market value. Foreign Fixed Income Securities - Investing in fixed-income securities from foreign countries introduces additional risks, including currency exchange rate fluctuations, political instability, and different regulatory environments. High-Yield & Investment Grade Debt - High-yield debt, often referred to as junk bonds, carries higher default risk but can offer attractive returns. Investment-grade debt, on the other hand, includes bonds issued by more creditworthy entities, providing more stability but generally lower yields. Economic factors, interest rate changes, and market sentiment can impact both types of debt. Inflation Risk - Fixed-income investments can be vulnerable to inflation, eroding the purchasing power of future interest and principal payments. This risk is particularly relevant for longer-term bonds. Interest Rate Risk - Fixed-income securities are susceptible to interest rate risk. That is, as interest rates rise, bond prices usually fall, and vice versa. This effect is typically more pronounced for longer-term fixed-income securities. Liquidity Risk - Some fixed-income securities may have limited market liquidity, making it challenging to buy or sell them at favorable prices, especially in times of market stress. Structured Products & Structured Notes - Structured products are complex securities whose value is derived from their underlying assets. Typically, these are hybrid instruments consisting of a traditional security (e.g., a zero-coupon bond) and an embedded derivative (e.g., a call or put option). While they can offer customizable risk and return profiles, they can be less transparent and more difficult to value. Structured Products are 18  generally not listed on any exchanges, and there are generally no secondary markets where they can easily be liquidated. Structured products are typically not designed to be actively traded; thus, clients should be prepared to hold them until maturity. Their value may be influenced by factors specific to their underlying assets and the structure of the product. Structured notes – a specific type of structured product – are typically issued by banks or brokerage firms and have interest and/or principal payments that are linked to changes in the price level of certain assets or to the price performance of certain indices. The value of a structured note will be influenced by the complexity of the product, time to maturity, level of supply and demand for this type of note, interest rate, market volatility, liquidity, changes in the issuer's credit quality rating, and economic, legal, political, or other events. In addition, there may be a lag between a change in the value of the underlying reference asset and the value of the structured note. Structured notes may also be subject to counterparty risk. Treasury Inflation-Protected/Inflation-Linked Bonds - These bonds protect against inflation by adjusting their principal value with changes in the consumer price index. Although the risk of default is unlikely due to the backing of the "full faith and credit" of the U.S. government, Treasury inflation-protected/inflation-linked bonds can still experience minimal fluctuations in value. Foreign Securities - Investing in non-U.S. securities presents certain risks in addition to those outlined above, including: Currency Risks - Investments in international securities expose a portfolio to fluctuations in currency exchange rates, which may adversely affect the value of investments in international securities held in your portfolio. Similarly, investments denominated in an international currency are subject to the risk that the value of a particular currency will change in relation to one or more currencies. Emerging Markets - Securities traded in certain emerging markets may be subject to risks due to the inexperience of financial intermediaries, the lack of modern technology, the lack of a sufficient capital base to expand business operations, and the possibility of temporary or permanent termination of trading. Political and economic structures in many emerging markets may be undergoing significant evolution and rapid development, and emerging markets may lack the social, political and economic stability characteristics of more developed countries. Government Intervention & Market Disruptions - In recent years, the global financial markets have undergone fundamental disruptions that have led to extensive and unprecedented government intervention that could prove detrimental to the efficient functioning of the markets and could adversely impact your portfolio. Liquidity in Financial Markets - Global financial markets can experience wide fluctuations in liquidity and be subject to rapidly changing economic conditions, which could adversely impact portfolio asset value. Margin Transactions - A securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. Margin transactions carry risk because if the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the shares to maintain the margin requirements of the account. This is known as a "margin call." An investor's overall risk includes the amount of money invested plus the amount that was loaned to them. Mutual Funds - Investing in mutual funds carries the risk of capital loss, and thus, the client may lose money investing in mutual funds. All mutual funds incur costs that lower investment returns. Additionally, funds will be subject to risks based on the types of securities held by each fund. For example, fixed-income funds will primarily hold bonds and other fixed-income securities and be subject to the kinds of risks outlined below under "Fixed-Income," while equity funds will hold equity securities that are subject to the types of risks outlined below under "Equities." In addition, actively managed funds may be subject to the risk that fund management fails to meet a fund's objective or, in the case of a passive fund, will be subject to holding the securities that make up an underlying index and may not be able to divest itself of such holdings at a time or price that the fund's manager may otherwise think appropriate. A mutual fund may also make illiquid investments or may become less liquid in response to market developments or adverse investor perceptions. Illiquid investments may be more challenging to value. UCITS & Alternative UCITS - UCITS are open-ended pooled or collective investment undertakings established in accordance with the UCITS Directive adopted by European Union member states. Investing in UCITS carries similar 19  risks to those outlined under "Mutual Funds" above. Alternative UCITS are a type of UCITS that generally seek to take advantage of certain investment techniques permitted by the UCITS III Directive to pursue strategies more common in the alternative investment fund sector. Alternative UCITS typically seek to invest in a range of financial derivative instruments and use such instruments to create both long and synthetic short exposures, and some may also use a certain degree of leverage. Exposure to derivative instruments could effectively leverage the portfolio of the alternative UCITS. As a result, small price movements in the asset underlying a derivative contract held by the alternative UCITS can cause a significant difference in the value of the derivatives and result in large profits or losses (depending on the direction of the change) for the alternative UCITS. Investments in UCITS (including alternative UCITS) bear two layers of asset-based management fees and expenses (directly through GWA's advisory fees and indirectly at the UCITS level) and, in some instances, a single layer of incentive fees (at the UCITS level). Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or formulate the specific investment advice provided to clients. Our use of AI is primarily focused on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of clients or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality. Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach to adopting and implementing AI technologies. Moreover, the use of AI could lead to litigation and regulatory risk exposure. To mitigate these risks, our firm implements stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our Staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Risks of Specific Securities Utilized While GWA seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains; they should not invest unless they can bear these losses. Investing also risks missing out on more favorable returns that could be achieved by investing in alternative investments or commodities. Any of the above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax or legal consequence. Clients are encouraged to direct questions regarding risks, fees, and costs to their applicable Financial Advisor. ITEM 9: Disciplinary Information ____________________________________________________________________________________________________ Legal or Disciplinary Event Disclosure Registered investment advisers such as GWA must disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. Neither GWA nor any of its management persons has any criminal or civil actions, administrative proceedings, or self-regulatory organization proceedings to report that are material to a client’s evaluation of our advisory business, except for the following: 20  With respect to GWA’s parent company, BBVA S.A., on December 19, 2016, BBVA S.A. and its subsidiary, BBVA Securities Inc. ("BSI"), entered into a Consent Order of Assessment of a Civil Money Penalty (the "Consent Order") with the Board of Governors of the Federal Reserve System (the "Board"), under which the Board assessed a civil money penalty of $27 million against BBVA S.A. and BSI. BBVA S.A., a U.S. bank holding company, engages in limited securities underwriting and dealing activities through BSI, pursuant to authority granted by the Board under the Bank Holding Company Act ("BHC Act"), and subject to, among other things, restrictions on the amount of gross revenues derived from those activities and certain other conditions and requirements imposed by Board's order (the Operating Standards) or under Board regulations. The civil money penalty was assessed jointly and severally against BBVA S.A. and BSI. The Consent Order related to the following findings of the Board, which the Board determined resulted in unsafe and unsound practices, violations of Section 4 of the BHC Act, Section 5(c) of the BHC Act, Board Operating Standard 8 (and related provisions of the Federal Reserve Act), the Board's Regulation K and conditions and commitments applicable to BBVA S.A. under Board orders: (A)(1) during the period from July 1, 2008, and continuing through March 31, 2013, BBVA S.A. and BSI improperly classified certain types of revenues, resulting in violations of the applicable revenue limits on their securities underwriting and dealing activities under federal banking laws; (2) for the period including at least July 1, 2008, until June 30, 2012, BBVA and BSI filed inaccurate reports with the Board relating to its compliance with the revenue limits; (3) BSI received several extensions of credit from BBVA S.A.'s New York Branch during 2010 and 2011 that were not properly collateralized and BSI failed to pay intercompany fees on market terms; and (4) during the foregoing periods, BBVA S.A. and BSI failed to have adequate management oversight, corporate governance, risk management, and internal controls with respect to applicable revenue limits and the Board's Operating Standards; and (B) BBVA S.A. directly engaged in impermissible underwriting and dealing activities in the United States between July 2011 and October 2011 without the required regulatory approval of the Board. As noted in the Consent Order, BBVA S.A. and BSI took corrective action and restored compliance with the revenue limits and reporting requirements as of April 1, 2013. Clients can view our current disclosure documents at the SEC's IAPD website at www.adviserinfo.sec.gov by searching our firm name, BBVA Global Wealth Advisors, Inc. or CRD # 327326. The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment Adviser Representative of the firm, including their disclosure items (if any). Copies are also available by contacting us directly at 305-205-77528 or by email at gwacompliance.group@bbva.com. ITEM 10: Other Financial Industry Activities & Affiliations ____________________________________________________________________________________________________ GWA is an independent investment advisory firm that provides the investment advisory services indicated within this Form ADV 2A Disclosure Brochure. We do not engage in business activities or offer services other than those described herein. Broker-Dealer & Registered Representatives of a Broker-Dealer Neither GWA nor any of its Financial Advisors is registered as or has pending applications to become a broker-dealer or a registered representative of a broker-dealer. Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither GWA nor any management person is registered or intends to register as a futures commission merchant, commodity pool operator, commodity trading adviser, or an associated person of the preceding entities. BBVA Affiliated Entities BBVA, S.A. Group Banking Services – Parent Company GWA is wholly and directly owned by BBVA S.A., which owns other financial institutions throughout the world. Our advisory services are separate and distinct from the banking services of BBVA S.A. and those of its other subsidiaries. We do not provide recommendations regarding the banking services of BBVA S.A., its affiliates, or other banking entities. 21  BBVA Asset Management S.A. SGIIC From time to time, GWA can advise clients to invest in a fund or funds advised or managed by BBVA Asset Management S.A. SGIIC ("BBVA Asset Management"), another wholly owned subsidiary of BBVA S.A. Recommending funds managed by an affiliated entity presents a conflict of interest because investing in a fund managed by BBVA Asset Management would benefit not only that entity but ultimately BBVA S.A. (GWA's parent company), by generating additional revenues for both entities. GWA mitigates this conflict of interest by only advising on strategies and products that are in the client's best interest based on the client's financial goals, investment objectives and risk tolerance and by disclosing this conflict to you. GWA does not receive compensation directly or indirectly from BBVA Asset Management when it recommends investments in funds managed by BBVA Asset Management to GWA's clients. BBVA Insurance Sales & Services Certain subsidiaries of BBVA SA are insurance companies. While GWA does not recommend or sell insurance products, GWA and GWA Financial Advisors may refer clients or prospects for insurance to its US-based affiliate, BBVA Global Wealth Insurance Agency, Inc. Certain Financial Advisors are licensed insurance agents of BBVA Global Wealth Insurance Agency, Inc. BBVA Quality Funds BBVA Quality Funds is a division of BBVA S.A., specializing in the research and due diligence of mutual funds, ETFs, and pooled investment vehicles, among other investments. GWA has engaged BBVA Quality Funds to provide research and due diligence services that GWA can consider when formulating certain investment recommendations for clients. GWA does not receive any compensation directly or indirectly as a result of the recommendations we can make based on this research and due diligence, and clients are under no obligation to accept these recommendations. BBVA S.A. Corporate Banking - N.Y. Branch GWA has entered into a services agreement with a corporate banking branch of BBVA S.A. whereby BBVA S.A. provides GWA with certain support services, including insurance, human resources management, procurement, travel and expense services, third-party risk management, internal audit, finance and tax services. Such services are not utilized by or recommended to clients. BBVA Securities Inc. Certain subsidiaries of BBVA S.A. are engaged in financial services businesses, including BSI, an SEC-registered Broker- Dealer. GWA does not currently have any relationships or arrangements with BSI that are material to our business. BSI, however, serves as the underwriter for BBVA-issued or guaranteed Structured Notes, which GWA can recommend to clients. Other BBVA S.A. Financial Affiliates Although certain BBVA S.A. subsidiaries act as investment advisers in other jurisdictions, GWA does not currently have any relationships or arrangements with entities outside those disclosed in its ADV Part 1 that are material to GWA's business. Promoter Relationships GWA can enter into Promoter relationships with qualified individuals who are paid to refer clients to the Adviser, which can result in the provision of investment advisory services. GWA’s policy is to ensure that any Promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed Promoters can only provide impersonal investment advice by referring to our services and not commenting on using GWA’s services or portfolio construction. The terms of all unaffiliated Promoter arrangements are defined by a contract between the Promoter and GWA, which sets forth the terms of the Agreement and form of compensation to the Promoter, typically a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the Promoter's referral. Accordingly, GWA is generally required to ensure that the following information is disclosed to referred clients in writing: (1) whether a Promoter is a client or a non-client of GWA, (2) the material terms of any compensation arrangement for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. 22  Other Business Relationships Bulltick, LLC GWA has a relationship with Bulltick, LLC (“BT”), CRD#: 104005 / SEC#: 8-52493, a registered broker-dealer and member of FINRA, SIPC, and NFA, to provide custodial and execution services under applicable regulatory oversight. This arrangement was initiated to support client accounts that our current custodian, Pershing Advisor Solutions LLC (“PAS”), is unable to accommodate. BT is not affiliated with GWA or its parent company, BBVA S.A. The relationship with BT presents material conflicts of interest due to the personal relationships between BT’s management and certain GWA personnel and affiliates. Specifically, BT’s Miami, FL Managing Director and Minority Partner, Adolfo Lazaro, is the brother of Jaime Lazaro, BBVA S.A.’s Global Head of Global Wealth, who is also the supervisor of GWA’s CEO, Humberto Garcia de Alba Carrillo and an Executive Officer of the Adviser. Additionally, BT’s Principal, CFO, Operations Officer and FINOP, William (“Bill”) A. Herrera, is the spouse of GWA’s Chief Operating Officer and Operations Manager, Catalina M. Cadavid. These relationships can create material conflicts of interest, as they could influence GWA’s selection or recommendation of BT for client accounts. GWA addresses these conflicts by disclosing the relationships and potential conflicts to clients, implementing policies and procedures to ensure that all recommendations are made in the client’s best interest, consistent with its fiduciary duty, and conducting periodic reviews of best execution and due diligence for all broker-dealer relationships. GWA has adopted policies and procedures to identify, mitigate, and monitor these conflicts, and will provide additional disclosures as required under the Advisers Act, SEC rules, and applicable state regulations. Third-Party Resources GWA uses third-party resources to help run its business and provide services to its clients. In sourcing these service providers, GWA strives to act in a client’s best interest and find the highest value-added providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise - outside of the relationships disclosed herein, neither GWA nor its Associates receive compensation for such use or referrals. Conflicts of Interest Making clients aware of other financial activities, affiliations, relationships, and services presents a conflict of interest since GWA and its Associates can have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client needs (if any). GWA addresses other financial industry activities and affiliation conflicts of interest by requiring Associates to always act in each client's best interests. Clients are not obligated to act upon any recommendations or purchase additional products or services offered via GWA. Further, if they elect to act on any recommendation received, they are not obligated to place the transaction through GWA. The client can act on recommendations received by placing their business and securities transactions with any brokerage firm or third party of their choosing. GWA makes no assurances that another entity's products or services are at the lowest available cost. Clients could obtain the same products or services at a lower price from other providers. The ultimate decision to retain products or services remains at the client's sole discretion. Outside of the information referenced herein, neither the Adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. GWA has adopted and implemented compliance policies and procedures and its Code to mitigate conflicts of interest. GWA’s Code is available for review free of charge to any client or prospective client upon request. ITEM 11: Code of Ethics, Participation or Interest In Client Transactions & Personal Trading ____________________________________________________________________________________________________ Description of Our Code of Ethics Rule 204A-1 under the Advisers Act requires all investment advisers registered with the SEC to adopt a Code of Ethics that sets forth standards of conduct and requires the investment adviser’s Supervised Persons to comply with the federal securities laws. GWA takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the Supervised Persons who act on its behalf. The Adviser believes each of its advisory clients is owed the highest level of trust and fair dealing and holds Associates to a very high standard of business practices and integrity. To that end, GWA has adopted a Code of Ethics that sets forth the firm's conduct standards in keeping with its fiduciary obligation. GWA strives to comply with applicable laws and regulations governing our practices. GWA’s Code requires all Associates to exercise a fiduciary duty by acting in each client’s best interest while consistently placing the client's interests first and foremost. The Code applies to all Associates, including individuals registered with the Adviser as Financial Advisors or considered 23  'Supervised Persons' under the Advisers Act. The Code can also be applied to any other person the Chief Compliance Officer designates. GWA's Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. Associates are required to abide fully by all applicable industry regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. GWA's Code of Ethics is distributed to each Associate at the time of hire, annually, and periodically thereafter. Our Code requires an affirmative commitment by Associates that they will abide by all state and federal securities laws and provisions relating to client information confidentiality, a prohibition on insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Access Persons, among others. Associates are required to attest no less than annually to their compliance with and understanding of the above matters - including confirmation and acknowledgment by every Financial Advisor of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required of them. In addition, GWA provides annual training related to the Code of Ethics and monitors the activities of its Supervised Persons on an ongoing basis. Our Code of Ethics is available for review free of charge to any client or prospective client upon request. Buying & Selling for Client Accounts Securities in Which GWA or a Related Person has a Material Financial Interest In the event GWA recommends that clients buy or sell any security in which a related person of GWA has a material financial interest, or if a Supervised Person seeks to invest in the same securities that GWA recommends to its clients, we will manage conflicts of interest by adhering to BBVA S.A.'s "Conflicts of Interests" Policy in addition to GWA's own Code of Ethics and conflicts of interest policies and procedures. These policies establish the general principles and guidelines of action to identify, prevent, manage and, where appropriate, inform the client of conflicts of interest that may arise in the provision of investment and auxiliary services, with a view to complying with the regulations on the protection of the client. Our Code of Ethics is available for review free of charge to any client or prospective client upon request. (Please also see Item 10: Financial Industry Activities & Affiliations for a discussion of how GWA addresses conflicts of interest with respect to recommendations of funds managed by BBVA Asset Management.) Participation or Interest in Client Transactions & Personal Trading GWA neither participates nor has an interest in our client’s transactions. We allow Supervised Persons to, at times, invest in the same securities recommended to clients. As such, it is possible that an Access Person (1) could invest in the same securities (or related securities) that such person recommends to clients, or (2) could recommend securities to clients at or about the same time that such person buys or sells the same securities for their own account. This presents a potential conflict in that the Access Person might seek to benefit themselves from this type of trading activity in the same securities, either by trading for personal accounts in advance of client trading activity or otherwise. Accordingly, GWA monitors the personal trading of its Access Persons to ensure trades are consistent with the fiduciary obligations owed to our clients. GWA's Financial Advisors and other "Access Persons" must have written clearance for all personal securities transactions (subject to certain exceptions, such as, for example, shares of mutual funds) before completing the transactions. GWA can disapprove any proposed personal securities transaction by such persons, particularly if the transaction appears to pose a conflict of interest or otherwise appears improper. GWA does not permit insider trading and has implemented procedures to ensure that Associates are observing its policy regarding insider trading. Associates know the rules regarding material non-public information and insider trading and seek to ensure they do not benefit personally from the short-term market effects of their client recommendations. Associates can buy or sell specific securities for their accounts based on personal investment considerations, which the adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Agency Cross-Trades An agency cross-trade occurs when an investment adviser executes a trade between two or more of its advisory clients’ accounts. GWA does not currently engage in agency cross-trades. 24  Principal Trades A principal trade is one in which an investment adviser, acting as principal for its own account, buys securities from a client or sells securities to a client. GWA does not currently engage in principal trades. Trade Errors Even with the best efforts and controls, trade errors can happen. A "trade error" can include, among other things, the purchase or sale of an incorrect security, an incorrect amount of a security, or a failure to purchase or sell an intended security. GWA has internal controls in place to prevent trade errors from occurring. We endeavor to detect trade errors prior to settlement and correct or mitigate them expeditiously. If a trade is placed for a client's account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters, our policy is to restore the account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions can include canceling the trade, adjusting an allocation, and/or reimbursing the account. The goal of error correction is to make the client "whole." To the extent an error is caused by a counterparty, such as a broker, we will strive to recover any loss associated with such error from such counterparty. Generally, the client will be reimbursed for any loss incurred due to a GWA trade error. Any gains from GWA’s trade error will remain with the client. In cases where trade errors result from the Client's inaccurate instructions, the trading error will remain the client's financial responsibility. GWA maintains an accounting of each trade error within its books and records, including information about the trade and how such error was corrected. ITEM 12: Brokerage Practices ____________________________________________________________________________________________________ Preferred Custodians & Brokers-Dealers GWA does not maintain custody of the assets we manage on your behalf. Client assets must be held in an account at a "Qualified Custodian," generally a Broker-Dealer or bank. Clients will decide on their Custodian at the time of relationship inception during IAA execution and enter into a separate Broker-Dealer/Custodian client account agreement directly with the Custodian of their choice. Following appropriate due diligence and a thorough evaluation of the brokerage practices disclosed herein, Global Wealth Advisors (“GWA”) has entered into an agreement with Pershing Advisor Solutions LLC (“PAS”), an independent and unaffiliated broker-dealer registered with the SEC and a member of FINRA and SIPC. Under this arrangement, PAS will take custody of client assets, including cash, securities, and other holdings, and will execute securities transactions at GWA’s direction, as specified in each client’s IAA and the documentation executed to establish the custodial account, unless the client provides alternative instructions. PAS will serve as GWA’s preferred Qualified Custodian and introducing broker, offering designated brokerage and related services to GWA clients. Pershing LLC, an affiliate of PAS, also an SEC-registered broker-dealer and FINRA/SIPC member, will act as the clearing broker and custodian for such accounts. GWA anticipates recommending PAS and its affiliates for the majority of its clients’ brokerage transactions, subject to suitability and client-specific considerations. In certain instances where PAS is unable to support specific account structures or transaction types, GWA will recommend or select Bulltick, LLC (“BT”), an unaffiliated broker-dealer, member of FINRA, SIPC, and NFA, to facilitate such transactions. BT was selected based on its ability to meet client needs, with consideration given to execution quality, client service, and operational capabilities. As noted in Item 10: Other Financial Industry Activities & Affiliations, personal relationships between BT’s management and GWA personnel can present conflicts of interest. GWA mitigates these risks by disclosing all material relationships to clients, basing broker selection on objective criteria and the client’s best interest, and conducting regular best execution reviews. GWA does not receive soft dollar benefits or client referrals from BT. Should such arrangements arise, they will be promptly disclosed in this Brochure. It is important to note that not all investment advisers require clients to utilize a particular broker-dealer. Clients who elect to use PAS or BT will receive the applicable custodial account agreements and fee schedules at the time of account opening. Clients 25  will enter into custodial and/or brokerage agreements directly with each Qualified Custodian. GWA maintains no affiliation with PAS, Pershing LLC, or BT. Factors Used to Select & Recommend Custodians & Broker-Dealers GWA seeks to recommend a Qualified Custodian that can hold client assets and execute transactions on terms most favorable to the client, considering available providers and their services. While PAS is GWA’s designated Qualified Custodian and BT may be recommended when appropriate, GWA periodically reviews other Custodians to assess the competitiveness of charges. In selecting a Custodian, GWA makes a good-faith determination that commissions are reasonable in light of the value of brokerage and research services provided. The analysis will vary and can include a review of any combination of the following:  the combination of transaction execution services along with asset custody services - generally without a separate fee for custody, the capability to execute, clear, and settle trades - buy and sell securities for a client’s account,   ability to facilitate transfers and payments to and from accounts - wire transfers, check requests, bill payments, etc., competitive trading commission costs, reporting tools, including cost basis and 1099 reports, facilitating tax management strategies,    personal money management tools such as electronic fund transfer capabilities, dividend reinvestment programs,      and electronic communication delivery capabilities, financial stability to ensure individual accounts, including primary and backup account insurance, the breadth of investment products made available - stocks, bonds, mutual funds, ETFs, etc., the availability of investment research and tools that assist us in making investment decisions, customer service levels and quality of services, the competitiveness of the price of those services, such as commission rates, margin interest rates, other fees, etc., and the willingness to negotiate them, the reputation, financial strength, and stability of the provider, and   as discussed below, the availability of other products and services that benefit us. Custodial Support Services Custodians serve independent investment advisory firms, providing advisers and their clients access to institutional brokerage services – e.g., trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them. These various support services help an investment adviser manage or administer client accounts and grow the advisory business. The Adviser is offered these services at no charge if qualifying amounts of client account assets are maintained with the Custodian. (Please contact us directly for current qualifying amount numbers from our preferred Qualified Custodians.) The following is a description of some standard support services GWA can receive from our preferred Qualified Custodian(s): Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and custody of client assets. The investment products available include some that the Adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. The services available are subject to change at the discretion of each Custodian. Services That Will Not Always Directly Benefit You Custodians make other products and services available to GWA that benefit us but do not directly benefit our clients or their accounts. These products and services assist GWA with managing and administering client accounts. These can include software and other technology, both a Custodian’s own and that of third parties, which can be used to service all, some, or a substantial number of our client accounts and assist with the following: 26  facilitating trade execution and allocating aggregated trade orders for multiple client accounts,  providing access to client account data (such as duplicate trade confirmations and account statements),   pricing and other market data,  facilitating the payment of our fees from our client's accounts, and  assisting with back-office functions, recordkeeping, and client reporting. Services that Generally Benefit Only Us Custodians also offer other services to help us further manage and develop our business enterprise. These services can include: technology, compliance, legal, and business consulting, and  educational conferences and events,   publications and conferences on practice management and business succession. Custodians provide some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. Custody & Brokerage Costs Custodians generally do not charge advisory clients' Custodial accounts separately for their services. They are compensated by charging clients commissions or other fees on the trades they execute or settle in the Custodial accounts. Custodians will charge clients a percentage of the dollar amount of assets in the account for some custodial client accounts instead of commissions. Custodian commission rates and asset-based fees applicable to client accounts are negotiated based on an adviser’s commitment to maintaining client assets in Custodial accounts. This commitment benefits clients because clients' commission rates and asset-based fees are generally lower than if the investment adviser had not committed. In addition to commissions or asset-based fees, Custodians charge a flat dollar amount as a “trade away” fee for each trade the firm executes by a different Broker-Dealer, where the securities bought or the funds from the securities sold are deposited (settled) into a Custodial account. These fees are in addition to the commissions or compensation clients pay the executing Broker-Dealer. (For additional details, clients should refer to their Custodian’s specific “Fee Schedule.”) Research & Soft Dollar Benefits An investment adviser receives soft dollar benefits when obtaining research or other products and services in exchange for client securities transactions or maintaining account balances with a Custodian. GWA’s recommended Qualified Custodian will offer various brokerage services to us, as indicated previously, including the custody of client securities, effecting securities transactions and performing services incidental to it, platform systems access, duplicate client statements, the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds, and the use of overnight courier services. Receipt of these benefits creates a conflict of interest that could directly or indirectly influence GWA to recommend the Qualified Custodian to clients for custody and brokerage services because the Qualified Custodian will provide these products or services to GWA for no additional charge. Further, certain client accounts can benefit from the receipt of any research services received, for which they did not pay any commissions. GWA has no formal soft dollar program in which soft dollars are used to pay for third-party services. And, while the receipt of brokerage and research services from any broker executing transactions for GWA’s clients does not replace the Adviser’s customary and usual research activities, the receipt of such research can be deemed to be the receipt of an economic benefit. Although customary, this can create a conflict of interest between GWA and its clients since services received from the Qualified Custodian benefit GWA because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in the custody of the Qualified Custodian. This required minimum incentivizes GWA to recommend that clients maintain their accounts with the Qualified Custodian based on our interest in receiving services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. To address this conflict, GWA’s policy is that the Adviser will only participate in soft-dollar arrangements consistent with 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 arrangements, whether or not the client’s transactions pay for it. GWA does not seek to allocate benefits to client accounts proportional to any soft dollar credits generated by the accounts. Clients should be aware that GWA’s acceptance of soft dollar benefits can result in higher commissions charged to the client. 27  Beneficial Interest in Custodial Services Client transactions and the compensation charged by our recommended Qualified Custodian might not be the lowest compensation GWA might otherwise be able to negotiate; clients can pay commissions, markups, or markdowns higher than those of other Broker-Dealers in return for soft dollar benefits (also known as “paying-up”). Subject to Section 28(e) of the Securities Exchange Act of 1934, as amended, clients can pay a Broker-Dealer a brokerage commission more than another broker might have charged for effecting the same transaction. GWA chose PAS as its recommended Qualified Custodian, recognizing the value of the services PAS provides. We believe it is imperative for our advisory services to our clients to access the type of support provided by PAS. PAS’s services can be used in servicing any or all of our clients and can be used in connection with clients other than those making commissions to a Broker-Dealer, as permitted by Section 28(e). Custodial Statements The Qualified Custodian will send the client account statements, at least quarterly, itemizing activity and account transactions, specific investments held in the account, the portfolio's value, deposits, withdrawals and advisory fees that occurred during the period of the statement. These statements will be delivered by postal mail or electronically, as the client selects. GWA urges clients to promptly review any statements they receive directly from their Custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s’) investment performance against the appropriate benchmark applicable to the type of investments held in the account and any periodic information from us. GWA cannot guarantee the accuracy or completeness of any report or any other information provided to the client by the Custodian or another service provider. GWA encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received from their Custodian or us directly, or if they do not understand the information in any report, document or statement received, they should promptly and in all cases before the next statement cycle, report any items of concern to their Financial Advisor or GWA directly at 305-205-7752 or gwacompliance.group@bbva.com. Unless the client indicates otherwise, by promptly notifying GWA in writing of concerns regarding statements received, investments GWA makes at their direction and in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be reconfirmed in writing. If clients are not receiving statements, at least quarterly, from their Custodian, they should promptly inform their Custodian directly and their Financial Advisor. Best Execution GWA acts on its duty to seek “best execution.” As a matter of policy and practice, GWA conducts initial and ongoing due diligence policies, procedures, and practices regarding soft dollars, best execution, and directed brokerage. GWA seeks to ensure compliance with the client's written IAA and observe best practices. Still, a client can pay a higher commission than another Custodian might charge to effect the same transaction when it is determined, in good faith, that the commission is reasonable given the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest cost possible but whether the transaction represents the best qualitative execution, taking into consideration the complete range of services available, including, among others, the value of research provided, execution capability, financial strength, the commission rates, and responsiveness. While GWA will seek competitive rates, it may not necessarily obtain the lowest commission rates for client transactions. Directed Brokerage In most instances, clients will direct us to place their orders through PAS as the introducing/executing Broker-Dealer (transactions cleared through Pershing LLC). In more limited instances, clients can direct us to place their order or a portion of their brokerage orders through a specific Broker-Dealer of their choosing other than PAS ("Directed Brokerage"). In such cases, the client must submit such a request in writing, and GWA will review such requests but retain the right to approve or deny a client's request for Directed Brokerage. Subject to its duty of best execution, GWA can decline a client's request to direct brokerage if, at our discretion, such directed brokerage arrangements would result in additional operational difficulties. GWA must accept client requests for Directed Brokerage before they become effective. Upon GWA's acceptance of such Directed Brokerage, it is the client’s responsibility to negotiate the terms of the arrangement – including commission rates and other transaction costs for the account with the Directed Broker of their choice. GWA will not and is not obligated to seek better 28  execution services, better prices, or aggregate client transactions for execution through other Directed Brokers with orders for other accounts managed by the Adviser. By instructing us to execute transactions through the Directed Broker, the client may not necessarily obtain commission rates and execution as favorable as those that would be obtained if we were able to place transactions with PAS for execution through its trading venues (thus, Directed Brokerage may cost the client money) or otherwise impair GWA's ability to achieve best execution than might be the case if GWA were empowered to negotiate commission rates or select Broker-Dealers based on best execution. The client can also forgo benefits that we may be able to obtain for our other clients through, for example, negotiating volume discounts or block trades. In addition, Directed Brokerage can distract us from our normal trading process and represents a conflict of interest in our efforts to obtain best execution for all clients and obtain adequate research, to the extent we would otherwise obtain research by executing through another Broker-Dealer. In addition, if the Directed Broker played a role in introducing or referring the client to our Firm, we would face a conflict of interest that could be seen as reducing our incentive to obtain a lower commission. Brokerage for Client Referrals GWA receives no referrals from a Broker-Dealer or third party in exchange for using that Broker-Dealer or third party. Investment Allocation & Trade Aggregation Policy At our discretion, we can aggregate purchase and sale orders of investments held by client accounts with similar orders being made simultaneously for other client accounts. Aggregation can be done if, in GWA's reasonable judgment, such aggregation is reasonably likely to result in an overall economic benefit to clients such that they will obtain relatively better purchase or sale prices, lower commission expenses or beneficial timing of transactions, or a combination of these and other factors. In many instances, the purchase or sale of investments for clients will be effected simultaneously with the purchase or sale of like investments for other accounts or entities. Such transactions can be made at slightly different prices due to the volume of securities purchased or sold. In such an event, the average price of all securities purchased or sold in such transactions can be determined at GWA's sole discretion, and the client account can be charged or credited with the average transaction price. ITEM 13: Reviews of Accounts ____________________________________________________________________________________________________ Client Account Reviews Financial Advisors monitor and supervise all client accounts on an ongoing basis, using automated tools/systems, through periodic meetings with clients and internally at GWA. Accounts and account holdings are also reviewed for accuracy from an administrative, accounting and investment viewpoint. No less than annually, as indicated herein and within each client's executed IAA, client accounts are reviewed by the Financial Advisor responsible for the account, who will convene with clients to evaluate their accounts and discuss, at a minimum, the client's investment objectives, financial situation, suitability of investments, and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, changes in a client's investment objectives or guidelines, changes in a client's financial situation (such as retirement, termination of employment, physical move, or inheritance), or expected or unexpected material cash flow in an account. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. GWA determines the frequency, depth and nature of reviews based on the terms of each client's IAA and particular needs as they can be communicated to us by the client. We use technological tools (as noted above) to assist with our reviews on both an account- by-account basis and on a securities holdings basis, as well as performance exceptions and other bases. We conduct reviews to determine if an account's holdings are consistent with the investment objectives and restrictions imposed by the client. Financial Advisors typically manage and review portfolios based on individualized parameters. Clients should promptly communicate any changes in investment objectives, restrictions, and financial conditions to their Financial Advisor. Client Account Reporting GWA will not typically provide clients with regular reports on their accounts. The client’s selected Qualified Custodian will send the client written account statements, at least quarterly, itemizing activity and account transactions, specific investments held in 29  the account, the portfolio's value, deposits, withdrawals and advisory fees that occurred during the period of the statement. These statements will be delivered by postal mail or electronically, as the client selects. GWA urges clients to promptly review any statements they receive directly from their Custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s’) investment performance against the appropriate benchmark applicable to the type of investments held in the account and any periodic information from us. GWA cannot guarantee the accuracy or completeness of any report or any other information provided to the client by the Custodian or another service provider. GWA encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from their Custodian or us directly, or if they do not understand the information in any report, document or statement received, they should promptly and in all cases before the next statement cycle, report any items of concern to their Financial Advisor or GWA directly at 305-205-7752 or gwacompliance.group@bbva.com. Unless the client indicates otherwise, by promptly notifying GWA in writing of concerns regarding statements received, investments GWA makes at their direction and in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be reconfirmed in writing. If clients are not receiving statements, at least quarterly, from their Custodian, they should promptly inform their Custodian directly and their Financial Advisor. ITEM 14: Client Referrals & Other Compensation ____________________________________________________________________________________________________ Preferred Qualified Custodians As indicated in Item 12: Brokerage Practices, GWA receives an economic benefit from its recommended Qualified Custodian because it receives support products and services described above in connection with its arrangement to recommend that clients maintain accounts with the Qualified Custodians. GWA benefits from such arrangements because the cost of the support products and services it receives from the Qualified Custodian would otherwise be borne directly by GWA. GWA does not currently receive any economic benefit from Bulltick Advisory (“BT”) or its Supervised Persons in connection with client referrals or other compensation. If BT provides any such benefit in the future, GWA will disclose the nature of the arrangement, the resulting conflict of interest, and the steps taken to address the conflict, including policies and procedures to ensure recommendations are made in the client’s best interest. While clients do not pay more for assets maintained at any recommended Qualified Custodian, clients should consider these conflicts - the products and services provided by each Custodian, their benefits to us, and any related conflicts of interest described herein, when making a Custodian selection. (See Item 12: Brokerage Practices for disclosures on research and other benefits we may receive from our relationship with your account Custodian.) Promoter Relationships GWA does not presently have any arrangements with and does not compensate unaffiliated third parties to act as Promoters for our investment advice and management services, but reserves the right to do so in the future. In the event GWA enters into such an arrangement, we will disclose such relationship(s) to each client to the extent required by applicable law and comply with the requirements of Rule 206(4)-1 under the Advisers Act pertaining to compensated "endorsements." Upon request by a client, employees of certain affiliates of BBVA S.A. can refer that client to GWA. The incentive compensation paid by such BBVA S.A. affiliates to their local employees could incorporate such referrals as a component of discretionary bonus programs. However, no fees or compensation are payable or will be paid by GWA (directly or indirectly) to the referring employee or their employer, and there will be no impact on the advisory fee charged by GWA to the client. (See Item 10: Other Financial Industry Activities & Affiliations for additional details.) Conflicts of Interest Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an investment adviser receives an economic benefit, as the payment received could incentivize a referral. GWA mitigates this 30  conflict of interest by fully disclosing its referral practices and any compensation or benefit earned in this Brochure and only making recommendations believed to be in the client's best interests. Apart from the items disclosed herein, GWA does not receive any additional economic benefits for client referrals or compensation for this topic. GWA has adopted and implemented compliance policies and procedures and its Code to mitigate conflicts of interest. GWA’s Code is available for review free of charge to any client or prospective client upon request. ITEM 15: CUSTODY ____________________________________________________________________________________________________ Custodial Practices GWA does not have physical custody of client funds or securities other than the standard business practice of deducting advisory fees from client accounts. The Adviser prohibits the Firm or its Associates from obtaining, accepting, or maintaining custody of client funds, securities, or assets in any manner. Clients will keep all account cash, securities and other assets with a Qualified Custodian of their choosing, governed by a separate written brokerage and Custodial account agreement between the Qualified Custodian and the client. Account checks, funds, wire transfers, and securities will be delivered between the client and the Custodian of the record - GWA is not authorized to withdraw any money, securities, or other property from any client's Custodial account in the client's name or otherwise. As noted previously, GWA intends to enter into a Master Services Agreement with Pershing Group LLC ("Pershing") and its affiliates, including PAS, under which PAS or certain affiliates will provide services to the Firm and its clients pursuant to a Brokerage Services Schedule. GWA recommends that clients place their assets in the custody of Pershing, LLC, our recommended Qualified Custodian and a registered Broker-Dealer that is a wholly owned subsidiary of BNY Mellon. Typically, the independent Qualified Custodian will directly debit the client's account(s) to pay GWA's Advisory Fees. To authorize this, the client will directly provide written limited authorization instructions and request their Qualified Custodian provide a "transfer of funds" notice through the client’s preferred method of communication after each advisory fee payment transfer occurs. The client will provide these instructions separately on the Qualified Custodian's form. Although GWA does not have physical custody of client funds or securities, GWA is deemed to have limited custody over client funds, as defined by Rule 206(4)-2 under the Advisers Act, when the client has authorized us to deduct the advisory fee directly from the client's account. Wire Transfers, Check-Writing Authority & Standing Letters of Authorization GWA or persons associated with our Firm can effect wire transfers from client accounts to one or more third parties designated, in writing, by the client without obtaining written client consent for each separate, individual transaction, or we may have signatory and check-writing authority for client accounts if the client has provided us with written authorization to do so. Such written authorization is known as a "Standing Letter of Authorization" (or "SLOA"). An adviser with authority to conduct third-party wire transfers or sign checks on a client's behalf has access to the client's assets and, therefore, has custody of the client's assets in any related accounts. However, GWA is not required to obtain a surprise annual audit, as otherwise would be necessary by reason of having custody, as long as we meet the following criteria: 1. the client provides a written, signed instruction to the Qualified Custodian that includes the third party's name and address or account number at a Custodian, 2. the client authorizes us in writing to direct transfers to the third party either on a specified schedule or from time to time, 3. the Qualified Custodian verifies the client's authorization (i.e., signature review) and promptly provides a funds transfer notice to the client after each transfer, 4. the client can terminate or change the instruction, 5. GWA has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party, 6. we maintain records showing that the third party is not a related party to us or located at the same address, and 7. the client's Qualified Custodian sends them, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. 31  Custodial Statements The Qualified Custodian will send the client account statements, at least quarterly, itemizing activity and account transactions, specific investments held in the account, the portfolio's value, deposits, withdrawals and advisory fees that occurred during the period of the statement. These statements will be delivered by postal mail or electronically, as the client selects. GWA urges clients to promptly review any statements they receive directly from their Custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ' investment performance against the appropriate benchmark applicable to the type of investments held in the account and any periodic information from us. GWA cannot guarantee the accuracy or completeness of any report or any other information provided to the client by the Custodian or another service provider. GWA encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received from their Custodian, or if they do not understand the information in any report, document or statement received, they should promptly and in all cases before the next statement cycle, report any items of concern to their Financial Advisor or GWA directly at 305-205-7752 or gwacompliance.group@bbva.com. Unless the client indicates otherwise, by promptly notifying GWA in writing of concerns regarding statements received, investments GWA makes at their direction and in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be reconfirmed in writing. If clients are not receiving statements, at least quarterly, from their Custodian, they should promptly inform their Custodian directly and their Financial Advisor. ITEM 16: Investment Discretion ____________________________________________________________________________________________________ Account Management Style GWA's investment advisory services are offered to clients either on a discretionary or non-discretionary basis. Details of the relationship are disclosed fully before any advisory relationship commences, and additional information for account management style is reflected in each client's executed IAA. Discretionary Authority Under discretionary account management authority, GWA will execute securities transactions for clients without obtaining specific client consent before each transaction. Discretionary authority includes the ability to do the following without contacting the client:  Determine the security to buy or sell.  Determine the amount of security to buy or sell.  Determine the timing of when to buy or sell. For this type of management style, clients will provide discretionary management authority through written authorization in their executed IAA, granting GWA complete and exclusive discretion to manage all investments, reinvestments, and other transactions for their account as deemed appropriate by the Adviser, in accordance with the client's investment risk profile and IPS (as applicable for the type of account established). This authority may be subject to modifications agreed upon by the client and their Financial Advisor from time to time (collectively, the “Investment Guidelines”). (Note: Please note this authority excludes certain money movement transactions. GWA will not initiate wire transfers or transfers of funds to third parties without the client's explicit written approval.) Discretionary authority is limited to investments within a client's managed accounts. Clients will execute a “Limited Power of Attorney,” either as a standalone document or as part of the account opening documentation provided by their custodian. GWA is only required to obtain or maintain client consent for trades involving positions explicitly discussed during the introductory meeting (such as inherited stock the client wishes to retain for sentimental reasons) or as otherwise specified. In all instances, discretionary authority will be exercised in alignment with the client’s stated investment objectives. This authority will remain in effect until the client terminates it through written notice to the Adviser, even in the event of the client’s incapacity or disability. 32  Non-Discretionary Authority Non-discretionary account advisory authority requires clients to initiate or pre-approve investment transactions in their accounts before they occur. Clients can decide not to invest in securities or types of securities and refuse to approve securities transactions. Under this management style, GWA must receive approval from the client before placing any trades in the client's account. The discretion remains with the client. As a result, until GWA reaches the client, no transactions will be placed in the client's account(s). GWA will, however, facilitate transactions in its clients' accounts based on the investment decisions made by its clients. Clients will execute all documents required by GWA or their Custodian to establish this account trading authorization. GWA will recommend and direct the investment and reinvestment of securities, cash, and financial instruments held in the client's accounts as deemed appropriate in furtherance of the client's investment guidelines, with such changes as the client and their Financial Advisor can agree to from time to time. If clients object to any investment decision, a mutually agreed-upon decision will be made and documented if necessary. It is always preferred that the client and GWA engage in discussions to resolve any potential opinion differences. However, if the client repeatedly acts inconsistently with the jointly agreed-upon investment objectives, GWA reserves the right to cancel the client's IAA after written notice. Similarly, the client has the right to cancel their IAA with the Adviser according to the Agreement provisions if they so desire. ITEM 17: Voting Client Securities ____________________________________________________________________________________________________ Proxy Voting GWA will not ask for or accept voting authority for client securities and is not obligated to forward proxy notices to clients or their agents. GWA will direct the Custodian to forward all shareholder-related materials directly to the client's address on record. Clients are responsible for exercising their right to vote for proxies. While GWA can assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because it supplies client information about a particular proxy vote in any of the above situations. It is the client's obligation to vote their proxies. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies, Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, including those recommended by investment advisers to clients. GWA has no duty or obligation to evaluate a client's eligibility, advise, or submit claims to participate in the proceeds of securities class action settlements or other related legal actions, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in any manner concerning legal proceedings involving securities currently or previously held by the client's account or securities issuers. GWA does not provide legal or tax advice, engage in any activity that might be deemed to constitute the practice of law or accountancy, or act for the client in any manner concerning legal proceedings involving securities held or previously held by the client's account or the issuers of such securities. GWA is not obligated to forward copies of written or electronic notices of any legal actions, proceedings, or materials affecting such securities. It is the client's responsibility to respond to any legal actions or proceedings involving the securities purchased or held in their account and/or initiate litigation to recover damages if they may have been injured as a result of the actions, misconduct, or negligence by the corporate management of issuers of such securities. ITEM 18: Financial Information ____________________________________________________________________________________________________ Balance Sheet GWA 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. 33  Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients GWA has no financial conditions that will likely impair its ability to meet client contractual commitments. GWA has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years GWA has not been the subject of a bankruptcy petition in the last ten years. 34 

ITEM 1: Cover Page ____________________________________________________________________________________________________ BBVA Global Wealth Advisors, Inc. Form ADV Part 2A – Appendix 1 GWA PORTFOLIO ADVISER PROGRAM WRAP FEE BROCHURE (CRD # 327326) 501 Brickell Key Drive, Suite 601 Miami, FL 33131 Telephone: 305-205-7752 www.bbvaglobalwealthadvisors.com October 31st, 2025 the contents of This Wrap Fee Program brochure provides information about the qualifications and business practices of BBVA Global Wealth Advisors, Inc., a registered investment adviser with the United States Securities and Exchange Commission. If you have questions about this brochure, please contact us at 305-205-7752 or via email at gwacompliance.group@bbva.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; refer to the actual investment offering and related legal documentation for complete disclosures. Please note that registration as an investment adviser does not imply a certain level of skill or training. An adviser's written and oral communications provide information to determine whether to retain the adviser’s services. This Brochure is on file with the appropriate regulatory authorities, as federal and state regulations require. The advisory services described in this Brochure are not insured or otherwise protected by the U.S. Government, Federal Deposit Insurance Corporation ("FDIC"), Federal Reserve Board, or any other government agency. Any money or securities deposited to participate in any BBVA Global Wealth Advisors, Inc. investment program is not a deposit or other obligation of Banco Bilbao Vizcaya Argentaria, S.A. ("BBVA S.A."), the parent company of BBVA Global Wealth Advisors, Inc., and is not guaranteed by the FDIC, BBVA S.A. or any of its affiliates. All investments involve risk, including the possible loss of the principal amount invested. Additional information about BBVA Global Wealth Advisors, Inc. is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser- Firm," and type in BBVA Global Wealth Advisors, Inc. or CRD # 327326. Results will provide you with all firm disclosure brochures.) 1  ITEM 2: Material Changes ____________________________________________________________________________________________________ BBVA Global Wealth Advisors, Inc. ("GWA” or the “Adviser”) reviews its Form ADV 2A – Appendix 1 Wrap Fee Program Brochure at least annually to confirm it remains current. In this item, we are required to summarize only those material changes made to our Brochure since our last Annual Updating Amendment. If you are receiving this document for the first time, this section may not be relevant to you. Since our last Annual Updating Amendment on March 21, 2025, we have the following material changes to report: Item 2: Material Changes  On May 27, 2025, we updated our Texas branch office address to 1980 Post Oak Boulevard, 10th Floor, Houston, TX 77056 (T: 305-205-7752).  In October 2025, we established a custodial relationship with Bulltick, LLC (“BT”), CRD#: 104005 / SEC#: 8- 52493, a registered broker-dealer and member of FINRA, SIPC, and NFA, to provide custodial and execution services under applicable regulatory oversight. This arrangement was initiated to support client accounts that our current custodian, Pershing Advisor Solutions LLC (“PAS”), is unable to accommodate. BT is not affiliated with GWA or its parent company, BBVA S.A. The addition of BT introduces new material conflicts of interest, described in Items 4: Services, Fees & Compensation, Item 6: Portfolio Manager Selection & Evaluation and Item 9: Additional Information of this Wrap Fee Brochure, including personal relationships between BT’s management and certain GWA personnel. GWA has adopted policies and procedures designed to identify, mitigate, and monitor these conflicts, and will provide additional disclosures as required under applicable SEC and state regulations. Item 4: Services, Fees & Compensation Assets Under Management As of November 1, 2025, our assets under management (“AUM”) total $ 1,208,850,630. The following represents client assets under management by account type: Type of Account Assets Under Management Discretionary Non-Discretionary Total $1,208,850,630 $ 0 $ 1,208,850,630 Full Brochure Availability At any time, we may amend this document to reflect material changes in the Adviser's business practices, policies, procedures, or updates as mandated by securities regulators. Annually, within 120 days of the close of our fiscal year-end of December 31st, and as necessary due to material changes, we will provide clients either by electronic means or hard copy with a new Brochure or a summary of material changes from the document previously supplied, with an offer to deliver a full Brochure upon request. Please retain this document for future reference, as it contains essential information concerning our advisory services and business. You may view our current disclosure documents at the SEC's Investment Adviser Public Disclosure ("IAPD") website at http://www.adviserinfo.sec.gov by searching either by our Firm name, BBVA Global Wealth Advisors, Inc. or CRD # 327326. The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment Adviser Representative of the Firm. You may also request a copy free of charge by contacting us directly at 305-205-7752 or via email at gwacompliance.group@bbva.com. ITEM 3: Table of Contents ____________________________________________________________________________________________________ 2  ITEM 1: Cover Page.................................................................................................................................................... 1 ITEM 2: Material Changes.......................................................................................................................................... 2 ITEM 3: Table of Contents.......................................................................................................................................... 2 ITEM 4: Services, Fees & Compensation................................................................................................................... 4 ITEM 5: Account Requirements & Types of Clients..................................................................................................13 ITEM 6: Portfolio Manager Selection & Evaluation...................................................................................................13 ITEM 7: Client Information Provided To Portfolio Managers.....................................................................................21 ITEM 8: Client Contact With Portfolio Managers.......................................................................................................21 ITEM 9: Additional Information..................................................................................................................................21 3  ITEM 4: Services, Fees & Compensation ____________________________________________________________________________________________________ Overview BBVA Global Wealth Advisors, Inc. ("GWA" or "the Adviser") was founded in February 2024 and incorporated in Delaware. The Firm, whose principal office and place of business is located at 501 Brickell Key Drive, Suite 601, Miami, Florida, is a registered investment adviser with the U.S. Securities and Exchange Commission under the Investment Advisers Act of 1940, as amended ("Advisers Act"). Principal Owners GWA is a non-bank wholly owned subsidiary of Banco Bilbao Vizcaya Argentaria, S.A. ("BBVA S.A.”) a publicly held global financial services institution and financial holding company, founded in Spain in 1857 and traded on the New York Stock Exchange (ticker: BBVA). BBVA S.A., one of the largest banks in Spain, owns the largest financial institution in Mexico and leading financial services franchises in South America. BBVA S.A. is also the leading shareholder in Garanti BBVA, a financial services company in Turkey, and has investment, transaction and capital markets banking businesses in the U.S. The following paragraphs describe GWA's business practices, services, and fees. Conflicts of interest arising from the Adviser or its Associates are disclosed herein. Advisory Business As used in this brochure, the words "we," "our," or "us" refer to GWA and the words "you," "your," and "client" refer to you as either a client or prospective client of our Firm. The term Associated Persons (or "Associates") refers to GWA's Covered Persons and Supervised Persons - the Firm's Officers and Directors ("Control Persons"), employees, and the Investment Adviser Representatives of GWA ("Financial Advisors"), who are licensed as necessary for their roles and client base, supervised, and approved by GWA to provide investment advice or advisory services on behalf of the Adviser. GWA owes a fiduciary duty to clients, as defined under the applicable laws and regulations. As a fiduciary, GWA upholds a duty of loyalty, care, fairness, and good faith towards each client and seeks to mitigate potential conflicts of interest. In providing investment advice to clients, GWA strives to act with a high degree of care, skill, prudence and diligence under the circumstances that a prudent person acting in a fiduciary capacity would use. GWA's advisory services are made available to clients primarily through its Financial Advisors. Each advisory relationship at GWA is managed by one or more Financial Advisors registered with the Firm, who serve as the primary point of contact between GWA and the Client. Financial Advisors collect financial profile and suitability information from clients and recommend specific advisory services or programs deemed appropriate after an assessment of the client's situation, financial circumstances, goals, objectives and investor risk profile, amongst other considerations. Financial Advisors are required by applicable rules and policies to obtain licenses and complete training to recommend specific investment products and services. Clients should be aware that their Financial Advisor can or can not recommend certain services, investments, or models depending on the licenses or training obtained and can transact business or respond to inquiries only in the state(s) and locations in which they are appropriately qualified. For more information about the Financial Advisor providing advisory services, clients should refer to their Financial Advisor's Form ADV 2B Brochure Supplement, a separate disclosure document offered to the client, along with this brochure, before or at the time of relationship inception. (If the client did not receive a Form ADV 2B Brochure Supplement, they should contact their Financial Advisor or GWA directly.) GWA's advisory services are designed and aimed to complement clients’ needs, as described within its written services contracts (the "Investment Advisory Agreement," or "IAA") that disclose, in substance, the scope of service, contract term, advisory fee, formula for computing the fee, and type of authority granted to GWA. Final advisory fee structures are documented within the written IAA. Financial Advisors are restricted to providing the services and fees specified within each IAA, subject to the client's listed objectives, limitations, and restrictions. IAAs must be completed and executed to engage in GWA's advisory services. Clients can engage GWA for additional services at any time. Non-Exclusive Relationship GWA's relationship with each client is non-exclusive; in other words, we provide advisory services to multiple clients, with investment strategies and advice based on each client's specific financial situation. Accordingly, since investment strategies 4  and advice are custom-tailored based on each client's specific financial situation, the advice we provide to one client can differ or conflict with that provided for the same security or investment for another. Other Professional Service Provider Recommendations GWA can recommend the services of other professionals for implementation purposes. These professionals, who can be lawyers, accountants, insurance agents, etc., are engaged directly by the client on an as-needed basis. We do not receive referral fees for such recommendations, and clients are under no obligation to engage in any recommended professional services. Clients wishing to engage in such services will execute a separate agreement by and between the Client and their selected referred professional(s). Unless disclosed otherwise, GWA is not a party to the transaction and does not maintain the authority to accept any client on behalf of any referred professional. Each referred party has the right to reject any referred GWA client for any reason or no reason. In selecting a referred professional, the client is responsible for understanding the referred provider's separate contract, including fees and charges and for those charges when assessed, should they choose to engage the referred professional. The client retains absolute discretion over all such implementation decisions and is free to accept or reject any recommendation from GWA. If conflicts of interest related to recommendations of other professionals arise in the future, we will disclose them to you. (Note: If a client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional.) Client Responsibilities GWA's advisory services depend on and rely upon the information received from clients. The Adviser cannot adequately perform its obligations and fulfill its fiduciary duties to the client unless the client discloses an accurate and complete representation of their financial position and investment needs, timely remits requested data or paperwork, provides updates promptly upon changes, and otherwise fulfills its responsibilities under its Investment Advisory Agreement (“IAA”). Financial Advisors will rely upon the accuracy of information furnished by the client or on their behalf without further investigation. GWA will not be required to verify the information obtained from clients or other professional advisors, such as accountants or attorneys. Clients will acknowledge and agree to their obligation to promptly notify GWA in writing if any information material to the advisory services to be provided changes, information previously provided that might affect how their account should be managed occurs, or if earlier disclosed data becomes inaccurate. The client or their successor shall also promptly notify us in writing of the client's dissolution, termination, merger, or bankruptcy if the client is other than a natural person and of the occurrence of any other event that might affect the validity of their IAA or our authority thereunder. GWA reserves the right to terminate any client engagement where a client has willfully concealed or refused to provide pertinent information about details material to the advisory services to be provided or individual/financial situations when necessary and appropriate, in its judgment, to provide proper financial advice. The following paragraphs describe the business practices, services and fees of the BBVA Global Wealth Advisors' GWA Portfolio Adviser Program, a bundled asset-based fee program. Any conflicts of interest arising from the Adviser or its Associates are disclosed herein. Wrap Fee Program Services Under our Wrap Fee Program Services, GWA is the Sponsor and investment adviser of the GWA Portfolio Adviser Program (the "Wrap Fee Program" or “Program”), a bundled asset-based fee Program that differs from a regular advisory services account in that clients receive both investment advisory services and the execution of securities brokerage transactions, custody, reporting, and related services for a specified, bundled asset-based fee (the "Program Fee" or "Wrap Fee") regardless of the number of trades completed by a client. The assets in each Wrap Fee Program are regularly monitored, with investment strategy purchase and sale transactions based on the client's specific needs and investment goals. Financial Advisors will collect financial profile information from clients at the onset of the advisory relationship through personal discussions and the use of diagnostic questionnaires designed to help the Financial Advisor assess the client's objectives and determine their risk tolerance to create a customized investment plan for portfolio management. Multiple aspects of the client's financial affairs are reviewed, with agreed-upon, realistic and measurable goals set based on the disclosed information. The client's written IAA will document the details of the advisory relationship and the final advisory fee structure.GWA’s advisory 5  services include recommending and analyzing investments, discussing market trends, and providing guidance with respect to investment product alternatives. Clients can evaluate specific trade ideas with their Financial Advisor and may trade individual stocks, exchange-traded funds (“ETFs”), structured notes, bonds, and funds, among others, with the assistance of GWA’s Investment Team. Investment advice is provided on a non-discretionary basis, which means that the client retains the final decision-making authority for each trade or investment decision in the account. If a client elects to participate in GWA’s exclusively non-discretionary services, our Representatives must obtain client approval prior to executing any transactions on behalf of the client’s account. Clients retain the unrestricted right to decline any advice provided by GWA on a non-discretionary basis. (See Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss in Item 6 for additional details.) In connection with determining investments suited to a client's risk profile, GWA's Investment Team considers as input investment analysis conducted by BBVA S.A.'s fund research team and reviews Investment Guides ("BBVA Investment Guides") developed by BBVA S.A.'s Global Wealth Investment Committee ("GWIC"). GWIC uses well-established investment principles and investment methodologies to develop the BBVA Investment Guides, which establish asset allocation target ranges for general client risk profiles. Typically drawing from the BBVA Investment Guides recommended by GWIC and/or other third-party information, our Investment Team develops specific asset allocation recommendations for our clients ("GWA Investment Guides"). GWA does not provide advice with respect to the use of margin or securities lending. However, our advisory services are non- discretionary, and our clients can independently decide to enter into agreements with their custodians related to the use of margin (i.e., leverage) in their accounts. In such cases, the Financial Advisor can facilitate the client's interaction with the custodian for the purposes of margin investing. Wrap Fee Program clients will enter into a separate IAA to participate in the Program that sets forth the terms and conditions of the engagement, describes the scope of the services to be provided, fees to be paid, and the type of authority granted to GWA. Final advisory fee structures are documented within the written IAA. Clients will then invest in the Wrap Fee Program by establishing one or more accounts with the Wrap Fee Program's custodian. (Please refer to the Wrap Fee Program Custodial Account Establishment section on p. 8 for additional details on GWA’s Qualified Custodian or “Custodian.”) Generally, clients participating in this type of Program will pay the Wrap Fee to the Program sponsor quarterly in arrears, based on a percentage of assets under management. With the client’s written permission, this payment will be debited from the client’s account by the Custodian. GWA passes on a portion of the Wrap Fee to the Broker-Dealer partner of the program for its services (e.g., execution of securities brokerage transactions) and retains a portion of the Wrap Fee for the advisory services it provides. The overall costs clients will incur if they participate in our Wrap Fee Programs can be higher or lower than they could incur by separately purchasing the types of securities available in the Program. Clients should be aware that a conflict of interest exists whenever GWA recommends participating in its Wrap Fee Program. Because GWA earns a higher fee for managing a Wrap Fee account versus a non-wrap fee account, Financial Advisors have an incentive to recommend a Wrap Fee account instead of a non-wrap fee account. However, clients could benefit from a Wrap Fee account instead of a regular non-wrap fee account based on their individual circumstances, as discussed below. GWA's Wrap Fee Program is intended for investors who seek to establish strategic investment goals and receive ongoing investment advice but who wish to retain ultimate decision-making authority over the trading activity in their account. The Program is not intended for clients who maintain consistently high levels of cash, money market mutual funds or other short- term securities or those who engage in trading activity inconsistent with the investment advice provided through the Program. Wrap Fee Program clients must understand the following:  The benefits under the Wrap Fee Program depend, in part, upon the size of the account, the Program Fee charged, and the number of transactions likely to be generated in the account.  GWA and its Financial Advisors receive compensation due to the client's participation in our Wrap Fee Program. This compensation could be more than the amount GWA or its Investment Professionals would receive if a client paid separately for investment advice, brokerage, and other services.  To evaluate whether our Program is suitable, clients should compare our Wrap Fee and any other costs of the Program with the amounts that other advisers would charge broker-dealers and custodians for advisory fees, 6  brokerage, other execution costs, and custodial services comparable to those provided under this Program.  Participating in GWA's Wrap Fee Program can cost a client more or less than purchasing advisory, brokerage, and custodial services separately from other advisers or broker-dealers. Similar services may be obtainable at lower costs on an unbundled basis through different firms. GWA typically pays a portion of the Wrap Fee it receives from you to your Financial Advisor. The exact portion of the Wrap Fee paid by GWA to the Financial Advisor varies among Financial Advisors. It depends on factors such as each Financial Advisor’s overall annual revenue production. Because the amount received by your Financial Advisor as a result of your participation in the Program can be more than the Financial Advisor would receive if you participated in GWA’s standard, non-discretionary investment advisory services, brokerage and other services covered by the Wrap Fee, the Financial Advisor has a financial incentive to recommend the Program over these other services. Wrap Fee Program Enrollment GWA's advisory services are designed and aimed to complement each client's specific needs. Clients wishing to participate in the Wrap Fee Program will enter into a separate IAA that sets forth the terms and conditions of the engagement, describes the scope of the services to be provided, fees to be paid, and the type of authority granted to GWA. Final advisory fee structures are documented within the written IAA. Financial Advisors are restricted to providing the services and fees specified within each IAA, subject to the client's listed objectives, limitations, and restrictions. IAAs must be completed and executed to engage in GWA's advisory services. Appropriateness will be determined based solely on the Wrap Fee Program's cost-effectiveness to the client. Once established, no Investment Advisory Agreement can be assigned, within the meaning of the Investment Advisers Act of 1940, as amended, by the Adviser without the consent of the client as set forth in the Investment Advisory Agreement. Clients can engage GWA for additional services at any time. (Note: Transactions that do not result in a change of actual control or management of the Adviser within the meaning of the Investment Advisers Act of 1940, as amended, shall not be considered an assignment.) Investor Profile Through a collaborative process with each client, GWA will create an Investor Risk Profile (“IRP” or “Profile”), which will be used to determine the appropriate investment mix for the client. Financial Advisors will confer with the client periodically to review the client's investment objectives and investment mix and make a reasonable effort to confirm or update the written client information to keep the data current, no less than annually. The IRP is created using a combination of the client's responses to a questionnaire designed to help determine investment goals, financial market expertise, liquidity needs, time horizon, risk tolerance and other relevant information gathered through personal client discussions and the overall client relationship, including but not limited to cash flow and liquidity requirements, risk management, and other factors significant to the client’s financial situation. Other financial areas of concern can also be discussed upon the client's request and as necessary. Existing investments will typically also be evaluated to determine whether they harmonize with the client’s financial objectives. Based on the data gathered, the client's questionnaire replies, and the set of guidelines established by GWA, the client will be classified into one of the following four Profiles: 1. Conservative Risk Profile – Investor with a low-risk tolerance looking for capital preservation at the end of a defined investment period. 2. Moderate Risk Profile – Investor with a moderate risk tolerance, looking to grow capital above the inflation rate in the long term. Willing to invest a moderate percentage of assets in US and non-US equities and accept a moderate amount of volatility. 3. Moderately Aggressive Risk Profile – Investor with a higher risk tolerance, willing to invest a higher percentage of assets in US and non-US equities and riskier securities. Looking to enhance returns and willing to accept a higher level of volatility. Even though the foundation of the portfolio construction process for Moderately Aggressive investors generally takes a long-term approach, shorter-term goals might have a higher priority in this portfolio. 4. Aggressive Risk Profile – Investor with a very high risk tolerance, willing to invest an even higher percentage of assets in US and non-US equities and riskier securities. Looking to maximize returns and willing to accept a 7  significantly higher level of volatility. Even though the foundation of the portfolio construction process for Aggressive investors generally takes a long-term approach, shorter-term goals might have an even higher priority in this portfolio. Client Imposed Restrictions Clients can, at any time, impose restrictions on investing in particular securities or security types according to their preferences, values, or beliefs. Such restrictions must be submitted to GWA in writing. Clients can also amend/change such limitations by once again providing written instructions. Reasonable efforts are made to comply with client investment guidelines, including any client's reasonable limits, by standard industry practices. In imposing restrictions, it is essential to note that such conditions can affect a client's account performance and result in variations from a similar Program account without restrictions. It is important to note that client-imposed restrictions within their account and variations could result in positive or negative performance differences for the account compared to accounts without such limits. The restrictions can also potentially prevent achieving a client's specific goals. Upon receiving a client's written restrictions, GWA will discuss the restriction request's feasibility to confirm expectations are met and verify the client's acknowledgment and understanding of the imposed restriction's possible outcomes. GWA reserves the right to either reject client-imposed restrictions or end the client relationship. Client-imposed restrictions will not be effective unless accepted by GWA in writing. In no event, regardless of the advisory service provided, is GWA obligated to make any investment or enter any transaction it believes in good faith would violate any federal or state law or regulation. Portfolio Construction Each client IRP typically maps to an Investment Guide, which represents the recommended asset allocation for the respective IRP. The GWA Investment Guides incorporate Strategic (long-term) and Tactical (short-term) components. The overarching principles of the Investment Guide development process are as follows:  Asset selection, liquidity, and risk tolerance are key considerations when constructing asset allocation guidelines for a given IRP.  Diversification is necessary and fundamental to navigate and reduce volatility; concentration could increase risk and volatility.  Valuations are important in assessing the intrinsic value of an asset, determining whether it is overvalued or undervalued, and informing the decision to buy, sell, or hold the asset based on its fair value versus its market price.  A disciplined allocation process can steer an investor away from making decisions based on emotional biases. When determining the Investment Solution for a particular client risk profile, as previously noted, GWA analyzes various products before recommending to its clients a customized portfolio appropriate for each client's IRP and in accordance with the client's risk tolerances and investment objectives. Client portfolios are reviewed through an ongoing process of assessing client objectives, developing an appropriate asset allocation that seeks to achieve those objectives, and modifying that allocation as necessary to address risks and opportunities. The Client's portfolio will then be supervised and regularly monitored, with investment strategy purchase and sale transactions based on the client's specific needs and investment goals. Each account's investments are directed and subject to the objectives, limitations, and restrictions listed in the client's documentation. Program clients remain the owners of all securities in their Program account and have all ownership rights to such securities, including the right to vote securities in their account and withdraw securities. Wrap Fee Program Custodial Account Establishment Clients will invest in the Program by establishing one or more accounts with the Program's custodian (the “Custodian”). Clients will agree to the execution of brokerage securities transactions related to the management of their Program account through Pershing Advisor Solutions LLC ("PAS"), an independent and separate SEC-registered Broker-Dealer, member of the Financial Industry Regulatory Authority, Inc. ("FINRA") and the Securities Investor Protection Corporation ("SIPC"), who will take possession of the cash, securities, and other assets within their portfolio and buy and sell securities upon our instructions, as indicated in each client's written IAA and the documents they execute with PAS to establish their Custodial account unless the 8  client directs otherwise. PAS will act as the Client's Custodian and introducing broker to provide specific brokerage and certain other services for the Program account, and Pershing LLC, an affiliate of PAS (also an SEC-registered Broker-Dealer and member of FINRA and SIPC), will act as the clearing Broker-Dealer/Custodian for such accounts. Pershing LLC will also maintain custody of the Program account assets. In addition to Pershing Advisor Solutions LLC, GWA may recommend or select Bulltick, LLC (“BT”) as Broker-Dealer for certain client transactions when Pershing cannot support specific account structures. BT is a registered Broker-Dealer and member of FINRA, SIPC & NFA. The selection of BT is based on its ability to accommodate client needs not supported by Pershing. In keeping with the bundled nature of the Program, PAS and/or Pershing LLC and BT will typically provide the following services for Program accounts: transaction execution, clearing and settlement services, custody and processing, and the maintenance of securities in good possession and control locations. To fulfill its duty to seek best execution of transactions for client accounts, GWA will periodically review the execution performance of our Broker Dealer partners. Additionally, we can be expected to maintain a minimum amount of client assets at Pershing LLC, and if we do not meet that minimum, PAS can charge us an annual platform fee. This arrangement presents a conflict of interest because it incentivizes us to increase and maintain the amount of Program assets held by Pershing LLC. The Custodian will send the client account statements, at least quarterly, itemizing activity and account transactions, specific investments held in the account, the value of the portfolio, deposits, withdrawals, and advisory fees that occurred during the period of the statement. These statements will be delivered by postal mail or electronically, as selected by the client. GWA urges clients to promptly review any statements they receive directly from the Custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ’ investment performance against the appropriate benchmark applicable to the type of investments held in the account and any periodic information from us. GWA cannot guarantee the accuracy or completeness of any report or any other information provided to the client by the Custodian or another service provider to the client. GWA encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received from the Custodian or us directly, or if they do not understand the information in any report, document or statement received, they should promptly and in all cases before the next statement cycle, report any items of concern to their Financial Advisor or GWA directly at 305-205-7752 or gwacompliance.group@bbva.com. Unless the client indicates otherwise, by promptly notifying GWA in writing of concerns regarding statements received, investments GWA makes at their direction and in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be reconfirmed in writing. If clients are not receiving statements, at least quarterly, from the Custodian, they should promptly inform the Custodian directly, as well as their Financial Advisor. Financial Advisors will contact clients periodically to review their Program account and confirm the account remains consistent with the client's investment objective and risk tolerance within appropriate asset allocation parameters. Clients will retain final decision-making authority and responsibility for the selection of, and any changes to, the investment objective, risk tolerance, the target and/or actual asset allocation, and the particular securities and other assets held in the Program account. Nonetheless, it is essential that clients promptly notify their Financial Advisor of any inaccuracies in, or material changes to, the information provided to GWA and/or the Financial Advisor throughout the duration of the Program account. Financial Advisors will also contact clients at least annually to determine if there are any changes to their investment objectives, risk tolerance, and financial goals and whether asset allocation changes should be made in the Program account. 9  Wrap Fee Program Fees & Compensation GWA's Wrap Fee Program advisory clients agree to pay an asset-based advisory fee calculated according to the schedules indicated herein. Fee Negotiation Availability Advisory Wrap Fees are negotiable up to the maximum annual rates listed herein, subject to certain limitations and approval by GWA. The Adviser, in its sole discretion, can charge lesser fees or choose to reduce or waive minimum fees for services based upon specific criteria such as pre-existing client relationships, the number of related investment accounts, inception date, total account assets under management, expected additional assets, anticipated future earning capacity, account composition, and client negotiations, among others. At GWA's discretion, certain employee accounts or those for members of a client's family or otherwise can be assessed fees based on the total balance of all accounts. While GWA seeks to facilitate advantageous agreements for clients, to the extent fees are negotiable, some clients can pay higher (more) or lower fees (less) than other clients for services that they would pay if their account were a non-wrap account and incurred transaction costs separately. Whether a client would pay more for the Program versus a non-wrap account (i.e., paying for advisory services and transaction costs separately) depends on several factors, including the level of trading activity in the account, the price of the services provided by third parties, or commissions charged for each transaction. Our Wrap Fee may also be higher or lower than fees charged by other sponsors of comparable investment advisory Wrap Fee programs. Lower fees for comparable services can sometimes be available from other sources. According to the selected advisory services, the final fee structures will be reflected in each client's written IAA. In all cases, clients are responsible for any tax liabilities that result from any transactions. Regardless of Wrap Fee negotiation availability, under no circumstances will a client be required to pre-pay a GWA advisory fee more than six months in advance, in excess of $1,200. Schedule of Fees GWA's Wrap Fee Program Services fees are generally assessed using a tiered annual fee calculation. The Schedule of Fees below identifies rates for various account value ranges based on the account size (i.e., the "assets under management"): Schedule of Fees Total Assets Under Management Annual Fees $500,000 - $1,000,000 $1,000,001 - $7,500,000 $7,500,001 + 2.2% 1.7% 1.1% *Note: We charge 2.20% if any Wrap Fee Program account's average daily balance for the quarter is between $250,001-$499,999. We charge a minimum annual fee of $5,500 for Wrap Fee Program accounts that fall below $250,000 (in terms of average daily balance in a quarter). Lower fees for comparable services can sometimes be available from other sources. Fee Calculation Except as otherwise described in this section, the Wrap Fees are calculated on the average daily balance of your account and billed quarterly in arrears, based on the net asset value of each account during the billing period - including assets invested in cash and cash equivalents, accrued interest, and dividends, but excluding the amount of outstanding margin balances. If an IAA is executed at any time other than the first day of a calendar quarter, our fees will apply on a pro-rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Assets under management include all U.S. securities, non-U.S. securities, cash and other instruments in a client's account advised by GWA. GWA considers cash to be an asset class. Depending on market conditions, investment management strategies often involve moving to cash positions for varying periods. As a result, cash balances are included in the value of the 10  assets under our management that are the basis for charging our advisory fee unless otherwise noted in the IAA (i.e., outstanding margin balances). The advisory fee billed to the cash portion of client accounts will exceed money market yields when rates for such money market funds are lower than the advisory fees charged to the account. To calculate an account's net asset balance, we deduct the amount of any outstanding margin balances from the account's total gross asset balance, but do not deduct the amount of any outstanding non-purpose loan balances. Securities without a readily available market price are valued at fair value, as determined in good faith by the Custodian. With respect to client account assets in alternative investments, alternative investment managers and underlying vehicles are responsible for providing the Custodian with an asset's valuation in accordance with applicable laws. Clients should be aware that ongoing fees reduce the value of an investment portfolio over time. When the Wrap Fee is debited from a portfolio's assets, there is less money invested to generate a return. Clients are encouraged to discuss the impact of fees with their Financial Advisor. GWA reserves the right, in its discretion and subject to the maximum fees described above, to amend the Schedule of Fees upon prior written notice to clients. Fee Billing GWA's policy is to deduct its advisory fee directly from client accounts through the Custodian holding your funds and securities upon your permission. No other method of fee payment is accepted. Advisory fee deduction will occur only when the following requirements are met: 1. Clients must authorize GWA in writing to directly deduct advisory fees due from their Custodial account and provide the Custodian with authorization to deduct such fees and instructions to remit them directly to GWA. 2. The account Custodian agrees to send the client a statement, at least quarterly, indicating all amounts disbursed from their account, including the amount of the advisory fee paid directly to GWA. GWA's Program Fees will be payable first from free credit balances, money market funds, or cash equivalents, if any, and second from the liquidation of a portion of the client's securities holdings. Please note that ongoing fees reduce the value of an investment portfolio over time - when our advisory fee is debited from the portfolio's assets, clients have less money invested to generate a return. Clients are encouraged to discuss the impact of fees with their Financial Advisor. When authorized by the client to debit advisory fees from client accounts, GWA is deemed to have custody of client assets to the extent the Adviser is permitted to instruct the Custodian to deduct the fees. We urge clients to compare the Custodial account statements with any periodic portfolio report or data they may receive from us promptly upon receipt to ensure the accuracy of account transactions. Information obtained from us can vary based on accounting procedures, reporting dates, or valuation methodologies. If you find any inconsistent information between our invoice and the statement(s) you receive from the Custodian, contact us directly at 305-205-7752. If a client is not receiving statements directly from the Custodian, in addition to promptly advising their Financial Advisor, GWA also recommends that the client contact the Custodian directly. Program Account Additions, Withdrawals & Terminations Clients can make additions to their GWA Program accounts in cash or securities at any time. GWA reserves the right to decline to accept particular securities into the client's account. If GWA liquidates transferred securities, clients can be subject to additional fees such as transaction fees, other fees assessed at the mutual fund level, such as contingent deferred sales charges, and tax ramifications. Clients can make withdrawals from their GWA accounts at any time in cash or securities. Withdrawals are subject to the usual and customary securities settlement procedures and costs. Additionally, if the client transfers their account to another firm, they can pay an outgoing account transfer fee to the Custodian. Generally, account terminations can be made to an IAA by written notice without penalty within five (5) business days after the Agreement execution date. After that, the IAA between GWA and the Client will continue in effect until either party terminates the IAA following the terms of the Agreement, which states the IAA can be terminated by either party upon at least ten (10) days written notice to the other party. (Note: A "business day" shall be any day when the New York Stock Exchange is open for trading.) 11  Terminations become effective on receipt of such notice and will not affect:  The validity of any action previously taken by the Adviser under the Agreement.  Liabilities or obligations of the parties from transactions initiated before termination of the Agreement.  The client's obligation to pay management and other fees due, prorated through the termination date. Upon receiving the termination notice of the agreement, GWA will take steps to deliver cash/and or securities as per the client's instructions. If securities are liquidated, clients may incur liquidation fees or contingent deferred sales charges. Depending on market conditions, a liquidation can result in a loss. In addition, the Custodian or Broker-Dealer liquidating the security positions can impose additional fees. If the client holds certain alternative investments and/or illiquid securities, they may have to wait for specific redemption schedules. GWA bills the client in arrears for services that have already been rendered. Therefore, there is no need for the refund of any unearned advisory fees at the time of account termination. If the client is a natural person, the client's death, disability, or incompetency will not terminate or change the terms of an Agreement. Instead, the Agreement shall immediately terminate upon the Adviser’s receipt of proof of the client's death and a duly authorized representative’s written instruction to terminate the Agreement. The disability or incompetency of the client will also not terminate or change the terms of the Agreement; however, the client’s duly authorized representative can terminate the Agreement by giving written notice to GWA. Before termination, all directions given or actions taken or omitted by GWA before the effective Agreement termination shall be binding upon the client and any successor or legal representative. The Adviser will no longer be entitled to receive fees from the termination date and has no obligation to recommend or act concerning an account's securities, cash, or other investments under the terminated Agreement. Additional Fees & Expenses Clients who participate in the Program will not pay separate transaction or trading fees with respect to U.S. equities, ETFs, fixed-income securities, options, and mutual funds, except as noted below. However, the Wrap Fee does not include certain charges and administrative fees charged by PAS or other third parties (such as broker-dealers, custodians, trust companies, banks and other financial institutions), including, but not limited to:  Transaction charges (including mark-ups and mark-downs) resulting from trades effected through or with a broker- dealer other than PAS ("trading away"), wire transfer fees, account transfer fees, termination fees, paper subscription fees, tax document subscription fees, short-term redemption fees, bond concessions, international transfer fees, settlement fees, custodial fees, reporting charges, and loads.  Transfer taxes, odd lot differentials, exchange or auction fees, interest charges, American Depository Receipt agency processing fees, and any charges, taxes or other fees mandated by any federal, state or other applicable law or otherwise agreed to with regard to client accounts.  Costs relating to trading in foreign securities (including UCITS), fees attributable to alternative investments and structured products.  Asset-based management and other fees charged by pooled investment vehicles (such as mutual funds, ETFs, and UCITS) in which a client invests and the managers of such vehicles (including custodian fees, brokerage commissions, and legal and accounting fees). GWA encourages clients to promptly review all account statements received from their Custodians to understand the fees charged to their accounts. While GWA does not anticipate trading away, as noted above, client Wrap Fees do not include trading costs if client orders are placed with broker-dealers other than PAS. Compensation for Client Participation Neither GWA nor any of its Financial Advisors receives additional compensation beyond the Wrap Fees disclosed herein for a client's participation in the Program. 12  ITEM 5: Account Requirements & Types Of Clients ____________________________________________________________________________________________________ Types of Clients GWA generally provides advisory services to individuals, high-net-worth individuals, businesses, and family businesses. Minimum Investment We generally require a minimum account size of $500,000 to open and maintain an account with us. For Wrap Fee Program accounts, we will charge 2.20% if any account's average daily balance for the quarter is between $250,001-$499,999. We charge a minimum annual fee of $5,500 for Wrap Fee Program accounts that fall below $250,000 (in terms of average daily balance in a quarter), but we reserve the right to reduce, increase, or waive the minimum account size, terminate accounts that fall below the minimum established requirements, require additional funds be deposited to bring a client account value up to the required minimum or waive advisory fees and account minimums for employee, employee-related, or affiliate employee accounts. Certain investment products can require annual minimum fees or minimum asset levels for participation. There are no ongoing contribution requirements for client accounts. Clients should thoroughly review disclosure materials or brochures and consult with their Financial Advisor about the implications of such minimum requirements before investing in such products. ITEM 6: Portfolio Manager Selection & Evaluation ____________________________________________________________________________________________________ Selection & Review of Portfolio Managers, Securities & Funds for the Program Because the Program is a non-discretionary advisory program, the Program does not entail the recommendation, selection, evaluation or use of “Portfolio Managers.” GWA now offers both discretionary and non-discretionary portfolio management services under the Wrap Fee Program. Clients may authorize GWA to make investment decisions without prior consultation for each transaction (discretionary), or may retain final decision-making authority and pre-approve each transaction (non-discretionary). Details of the relationship are disclosed fully before any advisory relationship commences, and the selected management style is documented in the client’s Investment Advisory Agreement (“IAA”). For clients who elect discretionary investment management authority, GWA will execute transactions in accordance with the agreed-upon strategy without prior client approval for each trade. Non-discretionary investment management authority requires clients to initiate or pre-approve account investment transactions before they occur. Clients can decide not to invest in securities or types of securities and refuse to approve securities transactions. Under this management style, GWA must receive approval from the client before placing any trades in the client's account. The discretion remains with the client. As a result, until GWA reaches the client, no transactions will be placed in the client's account(s). GWA will, however, facilitate transactions in its clients' accounts based on the investment decisions made by its clients. GWA does not affirmatively seek to identify Financial Advisors to participate in the Program. In general, Financial Advisors themselves express an interest in advising client accounts in the Program, either in connection with their transition to GWA from other firms where they might have advised client accounts in similar investment advisory programs or arising out of their existing advisory client relationships at GWA. Accordingly, GWA ordinarily does not recommend or select Financial Advisors in the Program for particular clients. GWA's Commercial Head maintains primary responsibility for the supervision of each Financial Advisor's advisory activities and the Program accounts they advise. This ongoing oversight typically also includes the review of each Program account for (1) the transactions effected in them, (2) those holding a significant amount of assets in cash, money market mutual funds and other short-term securities, (3) those presenting a certain risk level, (4) unsolicited trading, (5) little or no trading activity, (6) accounts holding a small number of securities, (7) accounts with excess extended deviation from specified asset allocation targets, and (8) accounts that have not recently been the subject of a portfolio review by the Financial Advisor and the client. 13  Custodial Relationships & Conflicts of Interest In addition to Pershing Advisor Solutions LLC (“PAS”), GWA may recommend or select Bulltick, LLC (“BT”), a registered broker- dealer and member of FINRA, SIPC, and NFA, to provide custodial and execution services for certain client accounts that PAS cannot accommodate. BT is not affiliated with GWA or its parent company, BBVA S.A. This arrangement introduces material conflicts of interest, including personal relationships between BT’s management and certain GWA personnel. These conflicts are disclosed in Form ADV 2A - Item 10: Other Financial Industry Activities & Affiliations, Item 12: Brokerage Practices, and Item 14: Client Referrals & Other Compensation, and this Wrap Brochure under Item 4: Services, Fees & Compensation and Item 6: Portfolio Manager Selection & Evaluation. GWA has adopted policies and procedures to identify, monitor, and mitigate these conflicts, and provides disclosures as required under applicable SEC and state regulations. Conflicts of Interest Conflicts of interest will arise whenever GWA has an actual or perceived economic or other incentive in its management of clients' portfolios to act in a way that benefits GWA. GWA has various conflicts of interest in managing and sponsoring the Program, as described below. Affiliate-Managed Products - GWA is a non-bank, wholly-owned subsidiary of BBVA S.A., an international financial holding company listed on the NYSE. From time to time, GWA can advise clients to invest in fund(s) advised or managed by BBVA Asset Management S.A. SGIIC ("BBVA Asset Management"), another wholly-owned subsidiary of BBVA S.A. Recommending funds managed by an affiliated entity presents a conflict of interest because investing in a fund managed by BBVA Asset Management would benefit not only that entity but ultimately BBVA S.A. (GWA's parent company), by generating additional revenues for both entities. GWA mitigates this conflict of interest by only advising on strategies and products that it believes to be in the best interest of the client based on the client's financial goals, investment objectives and risk tolerance, and by disclosing this conflict to the client. If, in the future, GWA recommends funds advised by any of GWA's other affiliates, GWA will disclose this affiliation and the resulting conflicts of interest related to these recommendations prior to the client's decision to invest in such funds. GWA does not receive compensation directly or indirectly from BBVA Asset Management when it recommends investments in funds managed by BBVA Asset Management to GWA's clients. Dissimilar Advice, Actions, Compensation & Activity - GWA and its affiliates can provide different advice, take different actions, receive more or less compensation and/or hold or deal in different securities for any other party, client, or account (including their own accounts or those of affiliates) from the advice given, actions taken, compensation received, or securities held or dealt for client accounts. Other Programs - clients may be able to obtain similar advice at a lower price via other programs, either from us or other parties that are not part of a wrap fee program. Trade Allocations - GWA can aggregate the securities to buy or sell for more than one client to obtain favorable execution to the extent permitted by law. When doing so, we are responsible for allocating the trade in a manner that is equitable and consistent with our fiduciary duty to our clients (which could include, e.g., pro-rata allocation, random allocation, or rotation allocation). For block trade orders executed by GWA, the price to each client is the average price for the aggregate order. GWA has adopted and implemented compliance policies and procedures and a Code of Ethics (“Code”) to mitigate conflicts of interest. GWA’s Code is available for review free of charge to any client or prospective client upon request. Performance-Based Fees & Side-By-Side Management Performance-based fees are fees based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. GWA does not accept performance-based fees nor participate in side-by-side management. Methods of Analysis, Investment Strategies, Type of Investments & Risk of Investment Loss Methods of Analysis GWA uses various methods/techniques of analysis to inform the development of the GWA Investment Guides and recommendations of Investment Solutions for its clients, including: 14  Fundamental Analysis - a method that measures intrinsic value by examining related economic, financial, and other qualitative and quantitative factors. Fundamental analysts attempt to study everything that can affect the asset value, including macroeconomic factors (i.e., the overall economy and industry conditions) and company-specific factors (i.e., the general financial health of companies, quality of management, or competitive advantages). The end goal of performing fundamental analysis is to produce a value that an investor can compare with the asset’s current price, with the aim of figuring out what sort of position to take with that asset (underpriced = buy, overpriced = sell or short). This method is considered the opposite of technical analysis. The risk of fundamental analysis is that information obtained may be incorrect, and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If asset prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Macroeconomic Analysis - focuses on the performance of economies and economic variables like inflation, interest, foreign exchange rates and growth, with risk that includes the uncertainty of projections. Modern Portfolio Theory - an investment theory that attempts to maximize a portfolio's expected return for a given amount of risk or, equivalently, minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset classes. GWA utilizes modern portfolio theory as a principle underlying its asset allocation processes. Quantitative Analysis - an analysis technique that deals with measurable factors (as distinguished from qualitative considerations) and seeks to understand behavior using complex mathematical and statistical modeling, measurement, and research, including, for example, the value of assets, the cost of capital, and diverse statistical measures. By assigning a numerical value to variables, quantitative analysts try to replicate reality mathematically. Some believe that it can also be used to predict real-world events, such as changes in a share price. Some risks of this type of analysis include the difficulty, time, and costs required to collect and conduct the data analysis. Technical Analysis (“Charting”) - a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volume. Technical analysts do not attempt to measure a security’s intrinsic value. Instead, they use charts and other tools to identify patterns that can suggest future activity. When looking at individual equities, a person using technical analysis generally believes that the performance of the stock, rather than the performance of the company itself, has more to do with the company’s future stock price. Some risks of this type of analysis include biased opinions or indicators that, while providing possible entry and exit points and information for consideration, can produce false or conflicting signals or not be 100% accurate in their forecasting. GWA might use this technique from time to time to generate tactical ideas for buying and/or selling a security. Investment Strategies Our investment strategies and advice will vary depending on each client's financial situation, as we determine investments and allocations based on the client’s predefined objectives, risk tolerance, time horizon, financial information, liquidity needs, and other suitability factors appropriately identified and included in the client's best interest objective. Client restrictions and guidelines will also affect the composition of the client’s portfolio. The following are other items that can also be items for consideration when determining investment strategies and practices: Asset Allocation In order to construct client portfolios, GWA follows an asset allocation process that incorporates both a strategic and a tactical component. GWA considers, as an input, the "Investment Guides" published by BBVA S.A.'s GWIC, which specify target exposure ranges for various asset classes for different client risk profiles. GWA then develops its own asset allocation recommendations, which are reviewed and adjusted periodically based on the evolution of macroeconomic factors, market performance and other quantitative and qualitative factors. Strategic Asset Allocation ("SAA") - SAA is part of GWA's asset allocation process. SAA analyzes the risk and return characteristics of asset classes over a longer time horizon. As part of this process and recognizing that future performance cannot be determined with any level of certainty, we aim to estimate the long-term expected risk and returns of various asset classes. These estimates are based primarily on a comprehensive analysis of various factors, including historical data, economic indicators, market trends, and fundamental analysis. Longer time horizons generally provide more confidence in estimates of asset class returns and risks. The long-term risk and return estimates of asset classes are reviewed periodically twice a year, as well as in extreme market situations, to assess how changes in macroeconomic conditions and recent market performance modify our estimates of asset returns. 15  Tactical Asset Allocation ("TAA") - TAA is part of GWA's asset allocation process. TAA is an active management strategy based on macroeconomic, sentiment, and momentum factors aimed at managing portfolio risk and returns with an approximate time horizon of less than a year. At GWA, we attempt to identify and take advantage of inefficiencies, opportunities, and dislocations that may arise in the markets at specific times with shorter time horizons. For certain client risk profiles, especially those that tolerate a higher degree of risk, GWA may implement a tactical investment approach for such clients' portfolios. Tactical Investment Ideas - at GWA, we attempt to identify and take advantage of inefficiencies, opportunities, and dislocations that may arise in the markets at specific times with shorter time horizons. For certain client risk profiles, especially those that tolerate a higher degree of risk, GWA may implement a tactical investment approach for such clients’ portfolios. Funds, ETF & UCITS Selection Our Investment Team leverages investment analysis and research conducted by BBVA S.A.'s fund research team, including with respect to pooled investment vehicles ("funds") and ETFs. BBVA S.A.'s research analyzes a combination of quantitative and qualitative criteria, including various measures of returns and risks across different time horizons. It categorizes funds, ETFs, and UCITS into comparable groupings. The qualitative analysis complements and reinforces the results of the quantitative analysis. GWA may consider this fund, ETF, and UCITS research in developing its recommendations to clients. Based on its analysis of the various funds, ETFs, and UCITS, the GWA Investment Team selects and highlights the most appropriate alternatives within each asset class and for each client risk profile. While GWA’s Financial Advisors may provide advice on any investment held in a client's portfolio at the inception of the advisory relationship and explore other investment options at the client's request, they reserve the right to advise clients on any other type of investment deemed suitable based on the client's stated goals and objectives. However, when balancing portfolios, GWA will consider only the account’s managed assets, not other investments the client may hold elsewhere. Cash Management In managing the cash maintained in your account, GWA will utilize only the cash vehicles (i.e., money market funds) made available by the client’s Custodian. In most cases, at least a partial cash balance will be maintained to allow for the debit of advisory fees or anticipated cash distributions to clients. There may be other cash management options away from the Custodian available to clients with higher yields or safer underlying investments. (Note: Investment products are usually not FDIC insured, insured by any federal government agency, a deposit, other obligation, or guaranteed by the Adviser.) Tax Considerations Our strategies and investments may have unique and significant tax implications. However, tax efficiency will not be our primary consideration when managing your assets. Regardless of account size or other factors, we strongly recommend that clients consult with a tax professional regarding investing their assets. Custodians and broker-dealers must report the cost basis of equities acquired in client accounts. Custodians will typically default to the First-In-First-Out ("FIFO") accounting method for calculating your investments’ cost basis. Clients are responsible for contacting their tax advisor to determine if this accounting method is the right choice for them. If your tax advisor believes another accounting method is more advantageous, provide written notice to our firm immediately and alert the account Custodian of your individually selected accounting method. (Please note that all decisions regarding cost-based accounting are required before trade settlement, as the cost-basis method cannot be changed after settlement.) Risks of Loss & Other Types of Risk Investing in securities involves a risk of loss that clients should be prepared to bear. Over time, assets will fluctuate and be worth more or less than the initial invested amount. Depending on the investment type, differing risk levels will exist. GWA cannot guarantee or promise that a client's financial goals and objectives will be met (including the investments and/or investment strategies recommended by GWA) or that investments will be profitable or achieve any specific level of performance. When evaluating risk, financial loss may be viewed differently by each client and may depend on many distinct risks, each of which may affect the probability and magnitude of potential losses. GWA does not represent or guarantee that the services provided or its methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate investors from losses due to market corrections or declines. There is 16  no guarantee of client account future performance or any level of performance, the success of any investment decision or strategy used, overall account management, or that any investment mix or projected or actual performance shown will lead to expected results or perform in any predictable manner or that your financial goals and objectives will be met. All investment programs have certain risks that the investor bears, and our investment approach keeps the risk of loss in mind. Past performance is not indicative of future results. The investment decisions made for client accounts are subject to various market, currency, economic, political, and business risks (including the many listed below) and will not always be profitable. The outcome(s) described and any strategies or investments discussed may not be suitable for all investors. Further, there can be no assurance that advisory services will achieve any particular result, tax, or legal consequence. An investment could lose money over short or even long periods. Clients should expect their account value and returns to fluctuate within a wide range, like the overall stock and bond market fluctuations. Every method of analysis has its inherent risks. For example, to perform market analysis, GWA relies on historical, current, and new market information. GWA has no control over the dissemination rate of market information; therefore, unbeknownst to us, certain analyses may be compiled with outdated market information, limiting the value of our analysis. In addition, an accurate market analysis can only produce a forecast of the direction of market values. There can be no assurances that a forecasted change in market value will materialize into actionable or profitable investment opportunities. Each of GWA's primary investment strategies - Asset Allocation, Tactical Investment Ideas and Funds/ETF Selection – can have its own inherent risks and limitations. For example, longer-term investment strategies generally require a more extended investment period to allow for the strategy to potentially develop. Short-term investment strategies can incur higher transactional costs when compared to a longer-term investment strategy. GWA's Investment Solutions allocates client investment assets primarily among various individual equity and fixed-income securities, mutual funds, UCITs, and/or ETFs in accordance with the client's designated investment objectives and risk tolerances. These securities have associated risks, as described below. The following risks for the various types of investments used by GWA in clients’ investment portfolios, which are not all-inclusive, are provided for careful consideration by a prospective client before retaining our services. The common risks of loss described in this section are intended as a high-level overview. Clients should carefully review other disclosure documents for a complete discussion of the risks attributable to an individual investment, including, but not limited to, prospectuses, term sheets, pricing supplements, and structured note documentation. Note: Items are presented alphabetically for ease of reading, not in order of importance. Risks include, but are not limited to: Equities - equity investment generally refers to buying shares of stocks in individual companies 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 environment. Exposure to equity securities may result in the following risks, among others: Emerging Market Stocks - Emerging market stocks may have higher political risk, as sometimes governments are less stable than in developed economies. Emerging market stocks can also be subject to more volatile economic environments that could lead to earnings fluctuations and currency risks that could lower the value of the investment. Growth Stocks - Growth stocks may be more sensitive to market movements because their prices tend to reflect future investor expectations rather than just current profits. Initial Public Offerings - Initial public offerings ("IPOs") are subject to high volatility and limited availability. Small-Capitalization ("Small-Cap") Companies - Small-cap stocks may exhibit erratic earnings patterns, competitive conditions, limited earnings history, and a reliance on one or a limited number of products. Value Stocks - Value stocks may perform differently from the market as a whole and may be undervalued by the market for an extended period. 17  ETFs - An ETF is a pooled investment fund, the shares of which trade on a stock exchange at market price in a manner similar to shares of stock issued by individual companies. Investors in ETFs are exposed to the risks associated with the ETF's underlying portfolio (i.e., equities or fixed-income risk, as described above). The market price of an ETF may not always reflect the value of the underlying portfolio, and ETFs may trade at a premium or a discount to the net asset value of the underlying portfolio. Fixed Income - 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 (or "junk") bonds, investment grade debt and structured products (including structured notes). In general, the fixed-income market is volatile, and fixed-income securities carry interest rate risk. Fixed-income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties (all as described below). Treasury inflation-protected/inflation-linked bonds are backed by the "full faith and credit" of the U.S. government and generally have negligible credit risk; however, they carry a potential risk of losing value. Risks of investing in foreign fixed-income securities also include the general risk of non-U.S. investing described below in the "Foreign Securities" section. Different types of fixed-income securities can have different characteristics and associated risks: Call Risk - Issuers of callable bonds have the option to redeem the bonds before maturity, which can leave investors with reinvestment risk if the bonds are called in a declining interest rate environment. Credit & Default Risks - Both issuers and counterparties of fixed-income securities carry credit risk, which pertains to the issuer's ability to meet its debt obligations. Default risk is the potential that the issuer might fail to make interest or principal payments. Corporate & Government Debt Securities - Corporate bonds offer the potential for higher yields compared to government bonds, but they also carry higher credit risk. Government bonds, particularly those issued by stable governments, are considered relatively safe, but they might offer lower yields. Both types of bonds can be influenced by changes in interest rates, potentially affecting their market value. Foreign Fixed Income Securities - Investing in fixed-income securities from foreign countries introduces additional risks, including currency exchange rate fluctuations, political instability, and different regulatory environments. High-Yield & Investment Grade Debt - High-yield debt, often referred to as junk bonds, carries higher default risk but can offer attractive returns. Investment-grade debt, on the other hand, includes bonds issued by more creditworthy entities, providing more stability but generally lower yields. Economic factors, interest rate changes, and market sentiment can impact both types of debt. Inflation Risk - Fixed-income investments can be vulnerable to inflation, eroding the purchasing power of future interest and principal payments. This risk is particularly relevant for longer-term bonds. Interest Rate Risk - Fixed-income securities are susceptible to interest rate risk. That is, as interest rates rise, bond prices usually fall, and vice versa. This effect is typically more pronounced for longer-term fixed-income securities. Liquidity Risk - Some fixed-income securities may have limited market liquidity, making it challenging to buy or sell them at favorable prices, especially in times of market stress. Structured Products & Structured Notes - Structured products are complex securities whose value is derived from their underlying assets. Typically, these are hybrid instruments consisting of a traditional security (e.g., a zero-coupon bond) and an embedded derivative (e.g., a call or put option). While they can offer customizable risk and return profiles, they can be less transparent and more difficult to value. Structured Products are generally not listed on any exchanges, and there are generally no secondary markets where they can easily be liquidated. Structured products are typically not designed to be actively traded; thus, clients should be prepared to hold them until maturity. Their value may be influenced by factors specific to their underlying assets and the structure of the product. Structured notes – a particular type of structured product – are typically issued by banks or brokerage firms and have interest and/or principal payments that are linked to changes in the price level of certain assets or to the price performance of certain indices. The value of a structured note will be influenced by the complexity of the product, time to maturity, level of supply and demand 18  for this type of note, interest rate, market volatility, liquidity, changes in the issuer's credit quality rating, and economic, legal, political, or other events. In addition, there may be a lag between a change in the value of the underlying reference asset and the value of the structured note. Structured notes may also be subject to counterparty risk. Treasury Inflation-Protected/Inflation-Linked Bonds - These bonds protect against inflation by adjusting their principal value with changes in the consumer price index. Although the risk of default is unlikely due to the backing of the "full faith and credit" of the U.S. government, Treasury inflation-protected/inflation-linked bonds can still experience minimal fluctuations in value. Foreign Securities - Investing in non-U.S. securities presents certain risks in addition to those outlined above, including: Currency Risks - Investments in international securities expose a portfolio to fluctuations in currency exchange rates, which may adversely affect the value of investments in international securities held in your portfolio. Similarly, investments denominated in a global currency are subject to the risk that the value of a particular currency will change in relation to one or more currencies. Emerging Markets - Securities traded in certain emerging markets may be subject to risks due to the inexperience of financial intermediaries, the lack of modern technology, the lack of a sufficient capital base to expand business operations, and the possibility of temporary or permanent termination of trading. Political and economic structures in many emerging markets may be undergoing significant evolution and rapid development, and emerging markets may lack the social, political and economic stability characteristics of more developed countries. Government Intervention & Market Disruptions - In recent years, the global financial markets have undergone fundamental disruptions that have led to extensive and unprecedented government intervention that could prove detrimental to the efficient functioning of the markets and could adversely impact your portfolio. Liquidity in Financial Markets - Global financial markets can experience wide fluctuations in liquidity and be subject to rapidly changing economic conditions, which could adversely impact portfolio asset value. Margin Transactions - A securities transaction in which an investor borrows money to purchase a security, in which case the security serves as collateral on the loan. Margin transactions carry risk because if the value of the shares drops sufficiently, the investor will be required to either deposit more cash into the account or sell a portion of the shares to maintain the margin requirements of the account. This is known as a "margin call." An investor's overall risk includes the amount of money invested plus the amount that was loaned to them. Mutual Funds - Investing in mutual funds carries the risk of capital loss, and thus, the client may lose money investing in mutual funds. All mutual funds incur costs that lower investment returns. Additionally, funds will be subject to risks based on the types of securities held by each fund. For example, fixed-income funds will primarily hold bonds and other fixed-income securities and be subject to the kinds of risks outlined below under "Fixed-Income," while equity funds will hold equity securities that are subject to the types of risks outlined below under "Equities." In addition, actively managed funds may be subject to the risk that fund management fails to meet a fund's objective or, in the case of a passive fund, will be subject to holding the securities that make up an underlying index and may not be able to divest itself of such holdings at a time or price that the fund's manager may otherwise think appropriate. A mutual fund may also make illiquid investments or may become less liquid in response to market developments or adverse investor perceptions. Illiquid investments may be more challenging to value. UCITS & Alternative UCITS - UCITS are open-ended pooled or collective investment undertakings established in accordance with the UCITS Directive adopted by European Union member states. Investing in UCITS carries similar risks to those outlined under "Mutual Funds" above. Alternative UCITS are a type of UCITS that generally seek to take advantage of certain investment techniques permitted by the UCITS III Directive to pursue strategies more common in the alternative investment fund sector. Alternative UCITS typically seek to invest in a range of financial derivative instruments and use such instruments to create both long and synthetic short exposures, and some may also use a certain degree of leverage. Exposure to derivative instruments could effectively leverage the portfolio of the alternative UCITS. As a result, small price movements in the asset underlying a derivative contract held by the alternative UCITS can cause a significant difference in the value of the derivatives and result in large profits or losses (depending on the direction of the change) for the alternative UCITS. Investments in UCITS (including alternative UCITS) bear two layers of asset-based management fees and expenses (directly through GWA's advisory fees and indirectly at the UCITS 19  level) and, in some instances, a single layer of incentive fees (at the UCITS level). Artificial Intelligence Risk We may utilize artificial intelligence ("AI") in certain aspects of our business operations to enhance operational efficiency and support client services. However, we currently do not use AI in our investment selection process or formulate the specific investment advice provided to clients. Our use of AI is primarily focused on automating administrative and client service-related tasks, such as meeting preparation, meeting notes, CRM updates, task management, and meeting recap notes. We believe this technology helps reduce administrative time, streamline client engagement, and improve the overall client experience. It is important to note that AI models are highly complex, and their outputs may be incomplete, incorrect, or biased. While AI is intended to enhance our operations, its use presents risks, including potential inaccuracies, errors in decision-making, and the management challenges of implementing the technology effectively. Additionally, using AI could pose risks to the protection of clients or proprietary information. These risks include the potential exposure of confidential information to unauthorized recipients, violations of data privacy rights, or other data leakage events. For example, in the case of generative AI, confidential information—such as material non-public information or personally identifiable information—input into an AI application could become part of a dataset that is accessible to other users or AI applications, potentially compromising confidentiality. Further, the regulatory landscape surrounding AI is rapidly evolving, which may require adjustments to our approach to adopting and implementing AI technologies. Moreover, the use of AI could lead to litigation and regulatory risk exposure. To mitigate these risks, our firm implements stringent data protection protocols, including encryption and access controls, to safeguard client and proprietary information. We continually assess and monitor the performance of AI technologies, ensuring that they are used in a manner consistent with our fiduciary duties and regulatory requirements. Our Staff is trained to handle sensitive data responsibly, and we engage with trusted third-party vendors who adhere to industry best practices for data security and compliance. Risks of Specific Securities Utilized While GWA seeks investment strategies that do not involve significant or unusual risk beyond the general domestic and international equity markets, in some instances, methods that hold a higher risk of capital loss may be utilized. While all investing involves risk, using such strategies is a material risk of loss. Clients are advised that investing in securities involves the risk of losing the entire principal amount invested, including any gains; they should not invest unless they can bear these losses. Investing also risks missing out on more favorable returns that could be achieved by investing in alternative investments or commodities. Any of the above investment strategies may lead to a loss of investments, especially if the markets move against the client. Past performance is not indicative of future results. The outcomes described and any strategies or investments discussed may not suit all investors, and there can be no assurance that advisory services will result in any particular result, tax or legal consequence. Before acting on GWA’s analysis, advice, or recommendation, clients should consult with their legal counsel, tax, and other financial investment professionals, as necessary, to aid in due diligence as proper for their situation and decide the suitability of the risk associated with any investment. Clients are encouraged to direct questions regarding risks, fees, and costs to their applicable Financial Advisor. Voting Client Securities Proxy Voting GWA will not ask for or accept voting authority for client securities and is not obligated to forward proxy notices to clients or their agents. GWA will direct the Custodian to forward all shareholder-related materials directly to the client's address on record. Clients maintain the responsibility for exercising their right to vote for proxies. While GWA can assist a client with their proxy questions, it shall not be deemed to have proxy voting authority solely because of supplying client information about a particular proxy vote in any of the above situations. It is the client's obligation to vote for their proxies. Clients should contact the security issuer before making any final proxy voting decisions. Class Action Suits, Claims, Bankruptcies, Other Legal Actions & Proceedings A class action is a procedural device used in litigation to determine the rights and remedies for many people whose cases involve common questions of law and fact. Class action suits often arise against companies that publicly issue securities, 20  including those recommended by investment advisers to clients. GWA has no duty or obligation to evaluate a client's eligibility, advise, or submit claims to participate in the proceeds of securities class action settlements or other related legal actions, determine if securities held by the client are subject to a pending or resolved class-action lawsuit, or act for the client in any manner concerning legal proceedings involving securities currently or previously held by the client's account or securities issuers. GWA does not provide legal or tax advice, engage in any activity that might be deemed to constitute the practice of law or accountancy, or act for the client in any manner concerning legal proceedings involving securities held or previously held by the client's account or the issuers of such securities. GWA is not obligated to forward copies of written or electronic notices of any legal actions, proceedings, or materials affecting such securities. It is the client's responsibility to respond to any legal actions or proceedings involving the securities purchased or held in their account and/or initiate litigation to recover damages if they may have been injured as a result of the actions, misconduct, or negligence by the corporate management of issuers of such securities. ITEM 7: Client Information Provided To Portfolio Managers ____________________________________________________________________________________________________ Sharing Client Information with Portfolio Managers The Program does not use third-party portfolio managers; thus, GWA does not provide client information to such managers. GWA Financial Advisors has access to all of the information the client provides, including financial information, investment objectives, risk tolerance level, tax status, investment experience, financial status, and other data relating to the client's investment profile, trading activity, and account(s), among other information. To provide Program services, GWA will share the client's private information with the Custodian. We can also provide client private information to mutual fund companies, as needed, and with the client’s consent. GWA will only share the information necessary to carry out our obligations to service Program accounts in accordance with our privacy practices and to the extent required to conduct business. GWA has adopted a written Privacy Policy in accordance with Regulation S-P under section 504 of the Gramm-Leach-Bliley Act, which restricts the Adviser and its Associates from the use of and access to the client’s non-public personal information. Clients can obtain a complete copy of GWA’s Privacy Policy and Code of Ethics, which also addresses our fiduciary obligations to clients, including privacy, for free by contacting us directly at 305-205-7752 or by email at gwacompliance.group@bbva.com. ITEM 8: Client Contact With Portfolio Managers ____________________________________________________________________________________________________ As noted above, the Program does not use third-party portfolio managers. There are no restrictions on a client's ability to contact their Financial Advisor or GWA directly with any questions regarding their Program account. GWA, through its Financial Advisors, is available to clients on an ongoing basis to discuss client financial circumstances, their Program portfolio and the securities therein, or to process instructions from clients concerning advisory assets. Clients are required to contact their Financial Advisor with any questions they have regarding their account(s). ITEM 9: Additional Information ____________________________________________________________________________________________________ Legal or Disciplinary Event Disclosure Registered investment advisers such as GWA must disclose all material facts regarding any legal or disciplinary events that would be material to a client's or prospective client's evaluation of the investment adviser or the integrity of its management. Neither GWA nor any of its management persons have any criminal or civil actions, administrative proceedings, or self- regulatory organization proceedings to report material to a client's evaluation of our advisory business, except for the following: With respect to GWA's parent company, BBVA S.A., on December 19, 2016, BBVA S.A. and its subsidiary, BBVA Securities Inc. ("BSI"), entered into a Consent Order of Assessment of a Civil Money Penalty (the "Consent Order") with the Board of Governors of the Federal Reserve System (the "Board"), under which the Board assessed a civil money penalty of $27 million against BBVA S.A. and BSI. 21  BBVA S.A., a U.S. bank holding company, engages in limited securities underwriting and dealing activities through BSI, pursuant to authority granted by the Board under the Bank Holding Company Act ("BHC Act"), and subject to, among other things, restrictions on the amount of gross revenues derived from those activities and certain other conditions and requirements imposed by Board's order (the Operating Standards) or under Board regulations. The civil money penalty was assessed jointly and severally against BBVA S.A. and BSI. The Consent Order related to the following findings of the Board, which the Board determined resulted in unsafe and unsound practices, violations of Section 4 of the BHC Act, Section 5(c) of the BHC Act, Board Operating Standard 8 (and related provisions of the Federal Reserve Act), the Board's Regulation K and conditions and commitments applicable to BBVA S.A. under Board orders: (A)(1) during the period from July 1, 2008, and continuing through March 31, 2013, BBVA S.A. and BSI improperly classified certain types of revenues, resulting in violations of the applicable revenue limits on their securities underwriting and dealing activities under federal banking laws; (2) for the period including at least July 1, 2008, until June 30, 2012, BBVA and BSI filed inaccurate reports with the Board relating to its compliance with the revenue limits; (3) BSI received several extensions of credit from BBVA S.A.'s New York Branch during 2010 and 2011 that were not properly collateralized and BSI failed to pay intercompany fees on market terms; and (4) during the foregoing periods, BBVA S.A. and BSI failed to have adequate management oversight, corporate governance, risk management, and internal controls with respect to applicable revenue limits and the Board's Operating Standards; and (B) BBVA S.A. directly engaged in impermissible underwriting and dealing activities in the United States between July 2011 and October 2011 without the required regulatory approval of the Board. As noted in the Consent Order, BBVA S.A. and BSI took corrective action and restored compliance with the revenue limits and reporting requirements as of April 1, 2013. Clients can view our current disclosure documents at the SEC's IAPD website at www.adviserinfo.sec.gov by searching our firm name, BBVA Global Wealth Advisors, Inc. or CRD # 327326. The SEC's website also provides information about any affiliated person registered or required to be registered as an Investment Adviser Representative of the Firm, including their disclosure items (if any). Copies are also available by contacting us directly at 305-205-7752 or by email at gwacompliance.group@bbva.com. Other Financial Industry Activities & Affiliations GWA is an independent investment advisory firm that provides the investment advisory services indicated within this Form ADV Part 2A Disclosure Brochure. We do not engage in business activities or offer services other than those described herein. Broker-Dealer & Registered Representatives of a Broker-Dealer Neither GWA nor any of its Financial Advisors is registered as or has pending applications to become a broker-dealer or a registered representative of a broker-dealer. Registration as a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor Neither GWA nor any management person is registered or intends to register as a futures commission merchant, commodity pool operator, commodity trading adviser, or an associated person of the preceding entities. BBVA Affiliated Entities BBVA, S.A. Group Banking Services – Parent Company GWA is wholly and directly owned by BBVA S.A., which owns other financial institutions throughout the world. Our advisory services are separate and distinct from the banking services of BBVA S.A. and those of its other subsidiaries. We do not provide recommendations regarding the banking services of BBVA S.A., its affiliates, or other banking entities. BBVA Asset Management S.A. SGIIC From time to time, GWA can advise clients to invest in a fund or funds advised or managed by BBVA Asset Management S.A. SGIIC ("BBVA Asset Management"), another wholly owned subsidiary of BBVA S.A. Recommending funds managed by an affiliated entity presents a conflict of interest because investing in a fund managed by BBVA Asset Management would benefit not only that entity but ultimately BBVA S.A. (GWA's parent company), by generating additional revenues for both entities. GWA mitigates this conflict of interest by only advising on strategies and products that are in the client's best interest based on the client's financial goals, investment objectives and risk tolerance and by disclosing this conflict to you. GWA does not receive 22  compensation directly or indirectly from BBVA Asset Management when it recommends investments in funds managed by BBVA Asset Management to GWA's clients. BBVA Insurance Sales & Services Certain subsidiaries of BBVA SA are insurance companies. While GWA does not recommend or sell insurance products, GWA and GWA Financial Advisors may refer clients or prospects for insurance to its US-based affiliate, BBVA Global Wealth Insurance Agency, Inc. Certain Financial Advisors are licensed insurance agents of BBVA Global Wealth Insurance Agency, Inc. BBVA Quality Funds BBVA Quality Funds is a division of BBVA S.A., specializing in the research and due diligence of mutual funds, ETFs, and pooled investment vehicles, among other investments. GWA has engaged BBVA Quality Funds to provide research and due diligence services that GWA can consider when formulating certain investment recommendations for clients. GWA does not receive any compensation directly or indirectly as a result of the recommendations we can make based on this research and due diligence, and clients are under no obligation to accept these recommendations. BBVA S.A. Corporate Banking - N.Y. Branch GWA has entered into a services agreement with a corporate banking branch of BBVA S.A. whereby BBVA S.A. provides GWA with certain support services, including insurance, human resources management, procurement, travel and expense services, third-party risk management, internal audit, finance and tax services. Such services are not utilized by or recommended to clients. BBVA Securities Inc. Certain subsidiaries of BBVA S.A. are engaged in financial services businesses, including BSI, an SEC-registered Broker- Dealer. GWA does not currently have any relationships or arrangements with BSI that are material to our business. BSI, however, serves as the underwriter for BBVA-issued or guaranteed Structured Notes, which GWA can recommend to clients. Other BBVA S.A. Financial Affiliates Although certain BBVA S.A. subsidiaries act as investment advisers in other jurisdictions, GWA does not currently have any relationships or arrangements with entities outside those disclosed in its ADV Part 1 that are material to GWA's business. Promoter Relationships GWA can enter into Promoter relationships with qualified individuals who are paid to refer clients to the Adviser, which can result in the provision of investment advisory services. GWA’s policy is to ensure that any Promoters used are licensed when required and otherwise qualified to provide investment advice. Unlicensed Promoters can only provide impersonal investment advice by referring to our services and not commenting on using GWA’s services or portfolio construction. The terms of all unaffiliated Promoter arrangements are defined by a contract between the Promoter and GWA, which sets forth the terms of the Agreement and form of compensation to the Promoter, typically a percentage of the advisory fees received from referred clients. Referral arrangements inherently give rise to potential conflicts of interest, particularly when the person recommending an Advisor receives an economic benefit, as the payment received could incentivize the Promoter's referral. Accordingly, GWA is generally required to ensure that the following information is disclosed to referred clients in writing: (1) whether a Promoter is a client or a non-client of GWA, (2) the material terms of any compensation arrangement for the referral, (3) the material conflicts of interest arising from the relationship and/or compensation arrangement, and (4) all material terms of the arrangement, including a description of the compensation to be provided for the referral. Other Business Relationships Third-Party Resources GWA uses third-party resources to help run its business and provide services to its clients. In sourcing these service providers, GWA strives to act in a client’s best interest and find the highest value-added providers to service clients. While the Adviser has developed a network of professionals - accountants, lawyers, and otherwise - outside of the relationships disclosed herein, neither GWA nor its Associates receive compensation for such use or referrals. Bulltick, LLC GWA has a relationship with Bulltick, LLC (“BT”), CRD#: 104005 / SEC#: 8-52493, a registered broker-dealer and member of 23  FINRA, SIPC, and NFA, to provide custodial and execution services under applicable regulatory oversight. This arrangement was initiated to support client accounts that our current custodian, Pershing Advisor Solutions LLC (“PAS”), is unable to accommodate. BT is not affiliated with GWA or its parent company, BBVA S.A. The relationship with BT presents material conflicts of interest due to the personal relationships between BT’s management and certain GWA personnel and affiliates. Specifically, BT’s Miami, FL Managing Director and Minority Partner, Adolfo Lazaro, is the brother of Jaime Lazaro, BBVA S.A.’s Global Head of Global Wealth, who is also the supervisor of GWA’s CEO, Humberto Garcia de Alba Carrillo and an Executive Officer of the Adviser. Additionally, BT’s Principal, CFO, Operations Officer and FINOP, William (“Bill”) A. Herrera, is the spouse of GWA’s Chief Operating Officer and Operations Manager, Catalina M. Cadavid. These relationships can create material conflicts of interest, as they could influence GWA’s selection or recommendation of BT for client accounts. GWA addresses these conflicts by disclosing the relationships and potential conflicts to clients, implementing policies and procedures to ensure that all recommendations are made in the client’s best interest, consistent with its fiduciary duty, and conducting periodic reviews of best execution and due diligence for all broker-dealer relationships. GWA has adopted policies and procedures to identify, mitigate, and monitor these conflicts, and will provide additional disclosures as required under the Advisers Act, SEC rules, and applicable state regulations. Conflicts of Interest Making clients aware of other financial activities, affiliations, relationships, and services presents a conflict of interest since GWA and its Associates can have a financial incentive to submit advisory clients to specific companies or services over others due to compensation received in connection with the transaction rather than client needs (if any). GWA addresses other financial industry activities and affiliation conflicts of interest by requiring Associates to always act in each client's best interests. Clients are not obligated to act upon any recommendations or purchase additional products or services offered via GWA. Further, if they elect to act on any recommendation received, they are not obligated to place the transaction through GWA. The client can act on recommendations received by placing their business and securities transactions with any brokerage firm or third party of their choosing. GWA makes no assurances that another entity's products or services are at the lowest available cost. Clients could obtain the same products or services at a lower price from other providers. The ultimate decision to retain products or services remains at the client's sole discretion. Outside of the information referenced herein, neither the Adviser nor its management persons have any other material relationships or conflicts of interest with other financial industry participants. GWA has adopted and implemented compliance policies and procedures and its Code to mitigate conflicts of interest. GWA’s Code is available for review free of charge to any client or prospective client upon request. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Description of Our Code of Ethics Rule 204A-1 under the Advisers Act requires all investment advisers registered with the SEC to adopt a Code of Ethics that sets forth standards of conduct and requires the investment adviser’s Supervised Persons to comply with federal securities laws. GWA takes its regulatory and compliance obligations seriously and recognizes its statutory duty to oversee the advisory activities of the Supervised Persons who act on its behalf. The Adviser believes each of its advisory clients is owed the highest level of trust and fair dealing and holds Associates to a very high standard of business practices and integrity. To that end, GWA has adopted its Code that sets forth the Firm’s conduct standards in keeping with its fiduciary obligation. GWA strives to comply with applicable laws and regulations governing our practices. GWA’s Code requires all Associates to exercise a fiduciary duty by acting in each client's best interest while consistently placing the client's interests first and foremost. The Code applies to all Associates, including individuals registered with the Adviser as Financial Advisors or considered 'Supervised Persons' under the Advisers Act. The Code can also be applied to any other person the Chief Compliance Officer designates. GWA's Code outlines and prohibits certain activities deemed to create conflicts of interest (or at least the potential for or the appearance of such a conflict) and specifies reporting requirements and enforcement procedures. Associates are required to abide fully by all applicable industry regulations and the Firm's guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code, including any updates. GWA's Code of Ethics is distributed to each Associate at the time of hire, annually, and periodically thereafter. Our Code requires an affirmative commitment by Associates that they will abide by all state and federal securities laws and provisions 24  relating to client information confidentiality, a prohibition on insider trading, restrictions on the acceptance of significant gifts, outside activities reporting, and personal securities trading procedures for Access Persons, among others. Associates are required to attest no less than annually to their compliance with and understanding of the above matters - including confirmation and acknowledgment by every Financial Advisor of the Firm's expectations regarding their conduct, given the duties, responsibilities, and principles required of them. In addition, GWA provides annual training related to the Code of Ethics and monitors the activities of its Supervised Persons on an ongoing basis. Our Code of Ethics is available for review free of charge to any client or prospective client upon request. Buying & Selling for Client Accounts Securities in Which GWA or a Related Person has a Material Financial Interest In the event GWA recommends that clients buy or sell any security in which a related person of GWA has a material financial interest, or if a Supervised Person seeks to invest in the same securities that GWA recommends to its clients, we will manage conflicts of interest by adhering to BBVA S.A.'s "Conflicts of Interests" Policy in addition to GWA's own Code of Ethics and conflicts of interest policies and procedures. These policies establish the general principles and guidelines of action to identify, prevent, manage and, where appropriate, inform the client of conflicts of interest that can arise in the provision of investment and auxiliary services, with a view to complying with the regulations on the protection of the client. Our Code of Ethics is available for review free of charge to any client or prospective client upon request. (Please also see Other Financial Industry Activities & Affiliations above for a discussion of how GWA addresses conflicts of interest with respect to recommendations of funds managed by BBVA Asset Management.) Participation or Interest in Client Transactions & Personal Trading In most cases, GWA neither participates nor has an interest in our client's transactions. We allow Supervised Persons to, at times, participate in or have an interest in financial products or strategies also recommended to clients. As such, it is possible that an Access Person (1) could invest in the same securities (or related securities) that such a person recommends to clients or (2) could recommend securities to clients at or about the same time that such a person buys or sells the same securities for their own account. This presents a potential conflict in that the Access Person might seek to benefit themselves from this type of trading activity in the same securities, either by trading for personal accounts in advance of client trading activity or otherwise. GWA monitors the personal trading of its Access Persons to ensure trades are consistent with the fiduciary obligations owed to our clients. GWA's Financial Advisors and other "Access Persons" must have written clearance for all personal securities transactions (subject to certain exceptions, such as, for example, shares of mutual funds) before completing the transactions. GWA can disapprove any proposed personal securities transaction by such persons, particularly if the transaction appears to pose a conflict of interest or otherwise appears improper. GWA does not permit insider trading and has implemented procedures to ensure that Associates are observing its policy regarding insider trading. Associates know the rules regarding material non-public information and insider trading and seek to ensure they do not benefit personally from the short-term market effects of their client recommendations. Associates can buy or sell specific securities for their accounts based on personal investment considerations, which the adviser does not deem appropriate to buy or sell for clients. In all cases, transactions are affected based on the client's best interests. Agency Cross-Trades An agency cross-trade occurs when an investment adviser executes a trade between two or more of its advisory clients’ accounts. GWA does not currently engage in agency cross-trades. Principal Trades A principal trade is one in which an investment adviser, acting as principal for its own account, buys securities from a client or sells securities to a client. GWA does not currently engage in principal trades. Trade Errors Even with the best efforts and controls, trade errors can happen. A "trade error" can include, among other things, the purchase or sale of an incorrect security, an incorrect amount of a security, or a failure to purchase or sell an intended security. GWA has internal controls in place to strive to prevent trade errors from occurring. We endeavor to detect trade errors prior to settlement and correct or mitigate them expeditiously. If a trade is placed for a client's account, which causes a breach of any regulatory, contractual, investment objective or restriction parameters, our policy is to restore the account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions can include canceling the trade, adjusting an allocation, and/or reimbursing the account. The goal of error correction is to make the client 25  "whole." To the extent an error is caused by a counterparty, such as a broker, we aim to recover any loss associated with such error from such counterparty. Generally, the client will be reimbursed for any loss incurred due to a GWA trade error. Any gains from GWA's trade error will remain with the client. In cases where trade errors result from the client's inaccurate instructions, the trading error will remain the client's financial responsibility. GWA maintains, within its books and records, an accounting of each trade error, including information about the trade and how such error was corrected. Review of Accounts Financial Advisors monitor and supervise all client accounts on an ongoing basis, using automated tools/systems, through periodic meetings with clients and internally at GWA. Accounts and account holdings are also reviewed for accuracy from an administrative, accounting and investment viewpoint. No less than annually, as indicated herein and within each client's executed IAA, client accounts are reviewed by the Financial Advisor responsible for the account, who will convene with clients to evaluate their accounts and discuss, at a minimum, the client's investment objectives, financial situation, suitability of investments and portfolio exposures to ensure the advisory services provided to clients are consistent with investment needs and objectives. More frequent reviews are triggered by material market, economic or political events, client requests, changes in a client's investment objectives or guidelines, changes in a client's financial situation (such as retirement, termination of employment, physical move, or inheritance), or expected or unexpected material cash flow in an account. Changes in tax laws, new investment information, and other changes in the client's financial or personal situation can also prompt a review. GWA determines the frequency, depth and nature of reviews based on the terms of each client's IAA and particular needs as they can be communicated to us by the client. We use technological tools (as noted above) to assist with our reviews on both an account-by-account basis and on a securities holdings basis, as well as performance exceptions and other bases. We conduct reviews to determine if an account's holdings are consistent with the investment objectives and restrictions imposed by the client. Financial Advisors typically manage and review portfolios based on individualized parameters. Clients should promptly communicate any changes in investment objectives and restrictions, as well as changes in financial conditions, to their Financial Advisor. Client Account Reporting GWA will not typically provide clients with regular reports on their accounts. The Custodian will send the client written account statements, at least quarterly, itemizing activity and account transactions, specific investments held in the account, the value of the portfolio, deposits, withdrawals, and advisory fees that occurred during the period of the statement. These statements will be delivered by postal mail or electronically, as selected by the client. GWA urges clients to promptly review any statements they receive directly from the Custodian or otherwise upon receipt to ensure account transaction accuracy. Clients should also compare their account(s) ’ investment performance against the appropriate benchmark applicable to the type of investments held in the account and any periodic information from us. GWA cannot guarantee the accuracy or completeness of any report or any other information provided to the client by the Custodian or another service provider to the client. GWA encourages clients to ask questions about their assets' custody, safety, security, or any statements received and report inconsistencies. If a client believes there are any inaccuracies or discrepancies in any reports received, whether from the Custodian or us directly, or if they do not understand the information in any report, document or statement received, the client should promptly and in all cases before the next statement cycle, report any items of concern to their Financial Advisor or GWA directly at 305-205-7752 or gwacompliance.group@bbva.com. Unless the client indicates otherwise, by promptly notifying GWA in writing of concerns regarding statements received, investments GWA makes at their direction and in line with their stated investment objectives or on their behalf shall be deemed to conform with the client's investment objectives. Any verbal communications, inquiries, or concerns about their account statements should be reconfirmed in writing. If clients are not receiving statements, at least quarterly, from the Custodian, they should promptly inform the Custodian directly and their Financial Advisor. 26  Client Referrals & Other Compensation Client Referrals GWA does not presently have any arrangements with and does not compensate unaffiliated third parties to act as Promoters for our investment advice and management services, but reserves the right to do so in the future. In the event GWA enters into such an arrangement, we will disclose such relationship(s) to each client to the extent required by applicable law and comply with the requirements of Rule 206(4)-1 under the Advisers Act pertaining to compensated "endorsements." Upon request by a client, employees of certain affiliates of BBVA S.A. can refer that client to GWA. The incentive compensation paid by such BBVA S.A. affiliate to its local employees may incorporate such referrals as a component of discretionary bonus programs. However, no fees or compensation are payable or will be paid by GWA (directly or indirectly) to the referring employee or their employer, and there will be no impact on the advisory fee charged by GWA to the client. Other Compensation GWA receives an economic benefit from the Custodian in the form of the support products and services it makes available to us for maintaining client accounts at such a Custodian. Custodians such as PAS serve independent investment advisory firms, providing advisers and their clients access to institutional brokerage services – e.g., trading, custody, reporting, and related services – many of which are not typically available to retail customers. Custodial support services are generally available unsolicited; advisory firms do not have to request them, and the availability to GWA of custodial products and services is not based on the Adviser giving particular investment advice, such as buying particular securities for our clients. These various support services help an investment adviser manage or administer client accounts and grow the advisory business. The Adviser is offered these services at no charge if qualifying amounts of client account assets are maintained with the Custodian. (Please contact us directly for current qualifying amount numbers from the Custodians.) The following is a description of some standard support services GWA can receive from the Custodian: Services That Benefit You Custodial services include access to various institutional investment products, securities transaction execution, and custody of client assets. The investment products available include some that the Adviser might not otherwise have access to or some that would require a significantly higher minimum initial investment by our clients. The services available are subject to change at the discretion of the Custodian. Services That Will Not Always Directly Benefit You The Custodian makes other products and services available to GWA that benefit us but do not directly benefit our clients or their accounts. These products and services assist GWA with managing and administering client accounts. These can include software and other technology, both a Custodian’s own and that of third parties, which can be used to service all, some, or a substantial number of our client accounts and assist with the following:  Providing access to client account data (such as duplicate trade confirmations and account statements).  Facilitating trade execution and allocating aggregated trade orders for multiple client accounts.  Pricing and other market data.  Facilitating the payment of our fees from our client's accounts.  Assisting with back-office functions, recordkeeping, and client reporting. Services that Generally Benefit Only Us The Custodian also offers other services to help us further manage and develop our business enterprise. These services can include:  Educational conferences and events.  Technology, compliance, legal, and business consulting.  Publications and conferences on practice management and business succession. The Custodian provides some of the above services themselves. In other cases, they will arrange for third-party vendors to deliver the services. 27  Research & Soft Dollar Benefits An investment adviser receives soft dollar benefits when obtaining research or other products and services in exchange for client securities transactions or maintaining account balances with a Custodian. The Custodian will offer various brokerage services to us, as indicated previously, including the custody of client securities, effecting securities transactions and performing services incidental to it, platform systems access, duplicate client statements, the ability to direct debit advisory fees directly from client accounts, access to an electronic communications network for order entry and account information, access to no-transaction-fee mutual funds, and the use of overnight courier services. Receipt of these benefits creates a conflict of interest that influences GWA to continue offering the Program through the Custodian because the Custodian will provide these products or services to GWA for free. Further, certain client accounts can benefit from the receipt of any research services received, for which they did not pay any commissions. GWA has no formal soft dollar program in which soft dollars are used to pay for third-party services. And, while the receipt of brokerage and research services from any broker executing transactions for GWA’s clients does not reduce the Adviser’s customary and usual research activities, the receipt of such research can be deemed to be the receipt of an economic benefit. Although customary, this can create a conflict of interest between GWA and its clients since services received from the Custodian benefit GWA because the firm does not have to produce or pay for them if a required minimum of client assets is maintained in Custodial accounts. This required minimum incentives GWA to continue to offer the Program through the Custodian based on our interest in receiving services that benefit our business, rather than based on a client’s interest in receiving the best value in services and the most favorable execution of their transactions. To address this conflict, GWA’s policy is that the Adviser will only participate in soft-dollar arrangements consistent with 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 arrangements, whether or not the client’s transactions pay for it. GWA does not seek to allocate benefits to client accounts proportional to any soft dollar credits generated by the accounts. Clients should be aware that GWA’s acceptance of soft dollar benefits can result in higher commissions charged to the client. Beneficial Interest in Custodial Services GWA chose PAS/Pershing LLC as the Custodian for the Program, recognizing the value of the services the broker provides. We believe it is imperative for our advisory services to our clients to access the type of support offered by the Custodian. Only a few possible firms meet GWA's sourcing criteria for providing our clients with a reliable and satisfactory custodial platform. The Custodian offers soft dollar benefits similar to those of the other firms considered by GWA, and as such, we mitigate conflicts of interest by not only considering this factor in our selection of the Custodian. Furthermore, the clients receive greater access to advanced services and portfolio management tools that improve their overall advisory services from us. Soft dollar benefits are used to service all client accounts, not only those that pay for the benefits. The Custodian GWA receives benefits from the Custodian through the support products and services that the Custodian makes available to GWA and can also make available to other independent investment advisers who also recommend their clients maintain accounts with the Custodian. GWA benefits from this arrangement because the cost of the products and services it receives from the Custodian would otherwise be borne directly by GWA. While clients do not pay more for assets maintained at the Custodian, clients should consider these conflicts: the products and services provided by the Custodian, their benefits to us, and any related conflicts of interest described herein. Conflicts of Interest Referral arrangements and the receipt of other benefits inherently give rise to potential conflicts of interest, particularly when the person recommending an investment adviser receives an economic benefit, as this could incentivize a referral. As noted above, upon request by a client, employees of certain affiliates of BBVA S.A. can refer that client to GWA. The incentive compensation paid by such BBVA S.A. affiliate to its local employees may incorporate such referrals as a component of discretionary bonus programs. However, no fees or compensation are payable or will be paid by GWA (directly or indirectly) to the referring employee or their employer, and there will be no impact on the advisory fee charged by GWA to the client. GWA mitigates this conflict of interest by fully disclosing its referral practices and any compensation or benefit earned in this brochure and only making recommendations believed to be in the client's best interests. 28  Apart from the items disclosed herein, GWA does not receive any additional economic benefits for client referrals or other compensation for this topic. GWA has adopted and implemented compliance policies and procedures and its Code to mitigate conflicts of interest. GWA’s Code is available for review free of charge to any client or prospective client upon request. Financial Information Balance Sheet GWA 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. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients GWA does not have any financial conditions that will likely impair its ability to meet contractual commitments with clients. GWA has no additional financial circumstances to report. Bankruptcy Petitions in The Previous Ten Years GWA has not been the subject of a bankruptcy petition in the last ten years. 29