COLBERT INVESTMENT MGMT FORM ADV PART 2A BROCHURE OCTOBER 2026

COLBERT INVESTMENT MANAGEMENT CO 1001 Brickell Bay Drive, Suite 2000 Miami, FL 33133 Telephone: +1 (305) 400-9982 www.colbertinvestment.com October 22, 2026 FORM ADV PART 2A DISCLOSURE BROCHURE This Form ADV Part 2A Disclosure Brochure (“Brochure”) provides information about the qualifications and business practices of Colbert Investment Management Co. (“Colbert” or the “Adviser”). Colbert is an SEC-registered Investment Adviser. Registration with the SEC or any state securities authority does not imply a certain level of skill or training. Additional information about Colbert is also available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for Colbert Investment Management is 108642. The information in this Brochure has not been approved or verified by the SEC or by any state securities authority. If you have any questions about the contents of this Brochure, please contact us at the telephone number listed above. 1  Item 2 Material Changes This Brochure provides information on Colbert's qualifications and business practices. Clients are encouraged to review this Brochure and Form ADV Part 2B Brochure Supplements for Colbert’s investment advisor representatives for additional information on the qualifications of our Firm and our employees. Since our last annual updating amendment in March 2026, we have made clarifying, formatting, and editing changes to the Brochure to more thoroughly disclose our practices; we also report our new office address and clarify under Item 12 that the Firm does not have soft dollar arrangements. You will receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of Colbert’s fiscal year, which is December 31st. Colbert will provide you with a new Brochure as necessary based on changes or new information, or at any time, without charge, by contacting us at the telephone number listed on the cover page of this Brochure. 2  Item 3 - Table of Contents Item 2 - Material Changes ..................................................................................................... 2 Item 3 - Table of Contents .................................................................................................... 3 Item 4 - Advisory Business .................................................................................................. 4 Item 5 - Fees and Compensation ......................................................................................... 5 Item 6 - Performance-Based Fees and Side-By-Side Management .................................. 7 Item 7 - Types of Clients ....................................................................................................... 7 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ........................... 7 Item 9 - Disciplinary Information........................................................................................ 10 Item 10 - Other Financial Industry Activities and Affiliations .......................................... 10 Item 11 - Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading ................................................................................................................................. 11 Item 12 - Brokerage Practices ............................................................................................ 11 Item 13 - Review of Accounts ............................................................................................ 13 Item 14 - Client Referrals and Other Compensation ........................................................ 14 Item 15 - Custody ................................................................................................................ 14 Item 16 – Investment Discretion ........................................................................................ 15 Item 17 – Voting Client Securities...................................................................................... 15 Item 18 - Financial Information .......................................................................................... 15 3  Item 4 Advisory Business Colbert Investment Management Co (“Colbert”, the “Adviser”, “we”, “our,” or “us) is a Florida corporation established in 1997 by Mr. Karim Armand, its principal owner and Chief Compliance Officer. Colbert offers discretionary or non-discretionary portfolio management services primarily to high-net-worth domestic and international clients and financial institutions. Colbert provides active asset management to its clients. We manage individual accounts for clients using a value-oriented strategy that comprises both fixed income (such as investment-grade and high-yield corporate or government bonds) and equity (common stocks and exchange-traded fund (“ETF”)) portfolios. While we focus on this value-oriented strategy, we tailor portfolios to clients' individual needs, depending on their situation. In particular, we tailor a client’s fixed-income portfolio, whereas clients’ equity portfolios tend to be more uniform across our clients. At the start of the relationship, we will gather information regarding your investment goals, risk profile, current financial situation, and prior investment experience. You may impose reasonable investment restrictions, including restrictions on particular securities or types of investments, subject to our agreement. Colbert requires that any requests for investment limitations or restrictions be made in writing. You should be aware that the performance of restricted portfolios may differ from the performance of portfolios without such restrictions, which may affect overall returns. Clients who fund their accounts by depositing securities authorize us to liquidate those securities and invest the proceeds in accordance with the selected strategy. Colbert does not provide advice regarding the securities being liquidated and is not responsible for any losses incurred in securities positions transferred into your advisory account. Depending on the securities involved, the holding period, and other factors, liquidations may result in redemption charges and a taxable event. You should review the potential tax consequences of these liquidations with your tax advisor. Clients funding their accounts with mutual fund shares may pay redemption fees in addition to any charges incurred on the initial purchase. Clients that hold mutual funds in their advisory account(s) incur our advisory fees in addition to the mutual fund’s operating and management fees and expenses. You should review these costs carefully before transferring mutual fund shares into your advisory account(s). Certain products may not be held in the account or used to fund the account. These include insurance, annuities, private placements, certain limited partnership interests, hedge funds, commodities, and futures. You should consult with your investment advisor representative before attempting to transfer such assets. The advisory fee on transferred assets is assessed as of the day you execute our advisory agreement. You should review these costs carefully before transferring assets into your advisory accounts. 4  As of December 31, 2025, Colbert had discretionary assets under management of $295,841,392. Colbert is not managing any non-discretionary portfolios at this time. Item 5 Fees and Compensation Our fees for portfolio management are calculated as a percentage of assets under management (“AUM”). There are two fee schedules, which depend on whether the account is equity/balanced or fixed income. The fees listed in the schedules below are on a blended annualized percentage basis: For DISCRETIONARY equity or balanced accounts: AUM First $1,000,000 Next $1,000,000 Next $1,000,000 Next $2,000,000 $5,000,000 and over Annual Fee (%) 1.95% 1.75% 1.50% 1.25% 1.00% For DISCRETIONARY fixed income accounts: AUM Annual Fee (%) First $250,000 Next $250,000 Next $500,000 Next $1,000,000 Next $1,000,000 $3,000,000 and over 0.90% 0.85% 0.75% 0.70% 0.65% 0.55% All fees may be amended by our firm upon thirty (30) days' written notice to the client. In our sole discretion, we may negotiate lower fees and account minimums. Clients authorize their custodian financial institutions to pay Colbert’s advisory fees. We charge our clients quarterly fees in arrears. We bill our advisory fees quarterly in arrears, meaning after the end of each calendar quarter. The fee for each quarter is based on the value of your account on the last business day of that quarter, as reported by your custodian or another independent third party. Your account value includes cash balances. It is calculated at market value (or fair market value when no market value is available), plus any credit balance and minus any debit balance. The client may be charged a pro rata fee if the client's service is terminated on a day other than the last business day of the calendar quarter. In that event, the pro rata fee will be due and payable upon termination of the service. Unless otherwise agreed, the client's account will be debited for the 5  advisory fees described above. We are paid fees from the amount of any contribution or transfer from available cash in the client's account or by liquidating the client's assets held in the client's account in an amount equal to the fees that are due. Colbert may waive, adjust, or rebate fees in certain situations. At Colbert’s discretion, Colbert may combine the account values of family members to determine the applicable advisory fee. Colbert may also waive or discount fees for employees’ and family members' accounts. Clients are advised that other clients with similar assets may pay different fees. Clients should also be aware that the same or similar investment services may be available from other investment advisors for a lower fee. Our fees are exclusive of brokerage commissions, transaction fees, and other costs or expenses incurred directly by the client. In addition to the advisory fees charged by our Firm, clients may incur additional fees. Commissions, sales loads, sales charges, management fees, administrative fees, account maintenance fees, odd-lot differentials, transfer taxes, wire transfer and electronic funds fees, and other fees and taxes on brokerage account and securities transactions and other fees may be charged by the broker or dealer selected for execution of the securities transactions in the accounts, by the custodian, and/or by the distributor, issuer, or fund issuing the securities purchased and sold within the accounts. The client is solely responsible for paying all such charges. In addition to all other fees and expenses incurred in managing an advisory account, client accounts that use margin strategies will also incur interest charges. Our firm does not charge fees on any margin balance or on any non-purpose loan balance extended by the custodian. Mutual funds and ETFs charge management fees, which are disclosed in the funds’ or ETFs’ prospectus (i.e., fund management fees, initial or deferred sales charges, mutual fund sales loads, 12b-1 fees, surrender charges, individual retirement account (“IRA”) and qualified retirement plan fees, and other fund expenses). Colbert’s policy is to offer clients funds with the lowest cost and most favorable share class based on the client’s individual needs. Certain offshore funds available only to non-US persons may often charge higher fees and expenses. To the extent that the client's portfolio has investments in mutual funds or ETFs, the client will pay two levels of advisory fees for the advisory service: one to Colbert and the other indirectly to the managers of the mutual funds and ETFs held in the portfolio. A client could invest in a mutual fund directly, without our firm's services. In that case, the client would not receive the services provided by our Firm, which are designed, among other things, to assist the client in determining which funds are most appropriate to the client in light of the client's financial profile and objectives. Accordingly, clients should review both the fees charged by the funds and the fees charged by our Firm to assess the total cost of the investment and value of advisory services. Please refer to Item 12, “Brokerage,” for more information. Clients may terminate the advisory agreement with our Firm at any time by providing written notice. Upon notice of termination, pro rata advisory fees for services rendered up to the point of termination 6  will be charged. If advisory fees cannot be deducted, Colbert will send an invoice for the advisory fees due. Item 6 Performance-Based Fees and Side-By-Side Management This item is not applicable. Colbert does not charge performance-based fees or engage in side-by-side management. Item 7 Types of Clients We generally provide investment advice to individuals (including retirement accounts and IRAs), companies, trusts, banks, insurance companies, and other foreign official institutions, and institutional clients. We generally require a minimum account value of $250,000 to engage our advisory services; however, in certain circumstances, we may reduce this minimum requirement at our discretion. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss We employ a value-oriented investment strategy for our clients. Value investing means paying a price for a security that is lower than our estimate of its intrinsic value, thereby building in what we consider to be a sort of margin of safety if our estimate of intrinsic value turns out to be wrong. We use a “bottom-up” investment approach, placing our primary emphasis on the merits of each investment. We generally refrain from relying on macroeconomic projections or making grand predictions. Through our own research and analysis, we form an opinion on an asset's intrinsic value and then aim to purchase it at a comfortable discount to that value. Sources of research and information that we use may include, but are not limited to, financial publications, company press releases and securities filings, third-party data providers, and other public sources. We do not recommend any particular type of security, sticking mostly to individual bonds and stocks with risk/reward characteristics that suit a client’s portfolio. We tend to favor a buy-and-hold strategy; therefore, we generally do not trade frequently, thus seeking to minimize trading costs. Colbert seeks to implement investment strategies designed to minimize potential losses, but there can be no assurance that these strategies will be successful, particularly in the short term. Clients may lose all or a substantial portion of their assets. Investment performance of any kind is not guaranteed, and past performance is not an indication of future results. All investments and investment strategies carry the risk of loss. Different types of investments involve varying degrees of risk, and there can be no assurance that the future performance of any specific investment, investment strategy, investment model, or product will be profitable, prove successful, or equal any corresponding indicated historical performance level. 7  Principal Investment Risks General Investing Risk: All investments carry some risk, and the strategies cannot guarantee they will achieve their investment objectives. In addition, the strategies we use may fail to produce the intended result. An investment in our strategies is not a bank deposit and is not insured or guaranteed by the Federal Deposit Insurance Corporation or any other government agency. Therefore, you could lose money by investing in our strategies. Our strategies may be appropriate for you if you are investing for goals several years away and are comfortable with stock market risks. Market Risk: Stocks may decline over short or even extended periods. Equity markets tend to be cyclical; there are times when stock prices generally increase and other times when they generally decrease. In addition, the strategies are subject to the risk that the specific types of stocks held will underperform other securities. Value Style Risk: Although the strategy invests in stocks we believe are undervalued, there is no guarantee that the prices of these stocks will not decline further, or that the strategy will be successful. Foreign or Emerging Market Risk: These markets can be highly volatile. Significant changes in prices and liquidity can occur rapidly in response to adverse political, regulatory, market, or economic developments. Investing in foreign markets carries additional risks, including currency risk, political risk, and risk associated with varying accounting standards. Investments in emerging markets may increase these risks and carry additional risks, such as social instability, the risk of nationalization, expropriation or confiscation, foreign exchange controls, restrictions on foreign investment and repatriation of capital. Securities clearing and settlement systems in foreign and emerging markets may not be fully developed, and settlement delays or registration transfer issues may expose clients to illiquidity and market losses. Concentrated Portfolios: These portfolios may not be diversified, may hold securities representing only one or a limited number of companies or sectors, and price movements could result in a greater risk of loss, especially over the short term Exchange Traded Products (ETPs): These securities derive their value from a basket of underlying assets, such as stocks, bonds, commodities, or indices, and trade intraday on a national securities exchange. Generally, ETPs take the form of ETFs or exchange-traded notes. ETFs are open-end investment companies or unit investment trusts whose shares represent an interest in a portfolio of securities. ETFs are subject to market risk, including the possible loss of principal. The value of the portfolio will fluctuate with the value of the underlying securities. ETFs trade like stocks, and brokerage commissions generally apply to buying and selling ETFs unless trading occurs in a fee-based managed account. ETFs may trade at a price below their net asset value. Investors should consider an ETF's investment objective, risks, charges, and expenses carefully before investing. The prospectus, which 8  contains this and other important information, should be read carefully before investing. ETFs may have underlying investment strategy risks similar to investing in commodities, bonds, real estate, international markets or currencies, emerging growth companies, or specific sectors. Fixed Income Risks Interest Rate Risk: The prices of fixed-income securities tend to fluctuate with changes in interest rates. Generally, their price decreases when interest rates rise and increases when interest rates fall. Fixed-income securities with longer maturities are more susceptible to interest rate fluctuations than those with shorter maturities. Therefore, the risk of interest rate fluctuation is greater to the extent that the strategies invest in long-term securities. Credit Risk: Fixed-income securities are also subject to the risk that an issuer will be unable to make principal and interest payments when due. The strategies may invest in fixed-income securities rated BBB- or higher by S&P or Baa3 or higher by Moody’s, or if unrated, determined to be of comparable quality at the time of purchase. Securities rated BBB or Baa3 are considered medium-grade obligations with speculative characteristics and are more vulnerable to adverse business or economic conditions than higher-rated securities. Government Agency Risk: Direct obligations of the U.S. Government, such as Treasury bills, notes and bonds, are supported by its full faith and credit. Indirect obligations issued by Federal agencies and government-sponsored entities generally are not backed by the full faith and credit of the U.S. Treasury. Accordingly, while U.S. Government agencies and instrumentalities may be chartered or sponsored by acts of Congress, their securities are neither issued nor guaranteed by the U.S. Treasury. Some of these indirect obligations may be supported by the right of the issuer to borrow from the Treasury; others are supported by the discretionary authority of the U.S. Government to purchase the agency’s obligations; still others are supported only by the credit of the instrumentality. Prepayment Risk: Prepayment risk is the risk that a debt security may be paid off and the proceeds returned to the investor earlier than anticipated. Depending on market conditions, proceeds may be reinvested at lower interest rates. Leverage: Creates an opportunity for greater total returns but also carries a greater risk of loss from adverse price changes. Losses from short selling may be unlimited, whereas losses from a cash investment are limited to the total amount invested. Colbert generally will not directly engage in short selling in Client accounts but may invest in funds and other instruments that may engage in short selling. Tax Considerations: Legal, tax, and regulatory changes could adversely affect investors by, among other things, restricting their ability to implement investment strategies. Transactions in a client 9  account, including account reallocations and rebalancing, may trigger a taxable event. Colbert does not provide tax advice; clients are urged to consult their tax advisor. Other Risks Cybersecurity Risks: Colbert utilizes electronic communication networks and media to maintain information about its clients and business. This creates an inherent risk of cybersecurity incidents or cyberattacks that may result in the inadvertent disclosure of confidential sensitive information to unintended parties, unauthorized access to such information, or operational disruptions by malicious hackers. Colbert takes other reasonable precautions to safeguard the confidentiality of sensitive information. However, even with reasonable precautions in place, the risk of cybersecurity incidents remains. In the event of such an incident, we will promptly notify the affected parties and take all necessary and appropriate actions in accordance with applicable laws and regulations. Item 9 Disciplinary Information There are no legal or disciplinary events that we believe are material to our client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Item 10 Other Financial Industry Activities and Affiliations Neither Colbert nor its management or associated persons are registered or have an application pending to register with the SEC as a broker-dealer, or registered representative of a broker-dealer, or with the Commodity Futures Trading Commission (“CFTC”) as a Futures Commission Merchant (“FCM”), Commodity Pool Operator (“CPO”), or Commodity trading advisor (“CTA”). National Financial Services, LLC and Fidelity Brokerage Services, LLC (collectively "Fidelity") Colbert offers custody services through Fidelity. Colbert is independently operated and owned and is not affiliated with Fidelity. The institutional platform services Fidelity provides include, among others, brokerage, custody, and other related services. Fidelity's institutional platform services that assist our firm in managing and administering clients' accounts include software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of fees from its clients' accounts; and (v) assist with back-office functions, recordkeeping and client reporting. Fidelity also offers other services intended to help our firm manage and further develop its advisory practice. Such services include, but are not limited to, performance reporting, financial planning, contact management systems, third-party research, publications, access to educational conferences, roundtables, and webinars, practice management resources, access to consultants and other third- party service providers who provide a wide array of business-related services and technology with whom our firm may contract directly. 10  The receipt of these benefits from Fidelity at no cost, or at a reduced cost, creates a conflict of interest. It may incentivize Colbert to recommend Fidelity and increase assets at Fidelity to reduce its expenses and receive these benefits. Colbert manages this conflict through disclosure, enabling clients to make an informed decision. Clients are not obligated to use Fidelity and may select a different Qualified Custodian, provided that it meets Colbert’s due diligence and other requirements. Item 11 Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading We recognize and believe that (i) high ethical standards are essential for our success and to maintain the confidence of our clients; (ii) our long-term business interests are best served by adherence to the principle that the interests of clients come first; and (iii) we have a fiduciary duty to our clients to act for their benefit. All our personnel must put our clients' interests before their own and act honestly and fairly in all respects in dealings with clients. All our personnel must also comply with all federal securities laws. We have adopted a Code of Ethics governing personal trading by our personnel. Among other requirements, the Code of Ethics requires personnel who have access to client portfolio information or our non-public securities recommendations to pre-clear certain personal securities transactions in certain investments, such as initial public offerings or private offerings, with our Chief Compliance Officer. The Code of Ethics also contains personal trading policies that require putting the client’s interests first, prohibit trading based on material nonpublic information, and detail how we may use restricted lists to prevent either our personnel or us from trading on such information. In addition, personnel are required to report certain gifts, business entertainment, and their personal securities transactions and holdings to the Chief Compliance Officer, who must review these reports. Our policy allows us to own and trade securities that we recommend to our clients, subject to certain limitations on the timing of purchases and sales outlined in the Code of Ethics. These limitations are in place to avoid conflicts that could arise if our related persons, or we, were permitted to trade at any time without limitations (such as “front running” client trades). Even if a trade falls within the limitations outlined in the Code of Ethics, the Chief Compliance Officer may deny permission to execute a transaction or reverse it if the transaction would have any adverse economic impact on one of our clients. You may obtain a copy of our Code of Ethics by contacting us at the number listed on the cover page of this Brochure. Item 12 Brokerage Practices Best Execution Colbert will typically use the custodian’s brokers to execute securities transactions. Colbert believes that using the custodian’s broker relationships is in its clients' best interests. The executing brokers 11  may act on an agency or riskless principal basis for a variety of securities and other investments. Although Colbert will seek to obtain competitive rates to the benefit of all clients, Colbert may not necessarily obtain the lowest possible commission rates for specific client account transactions. When using third-party brokers, Colbert may consider research among many other factors. In such cases, Clients may pay higher commissions or markups/markdowns than if Colbert selected a broker that does not provide research. Colbert may have an incentive to select the broker that provides research rather than the one offering the most favorable price or the lowest commission for Clients. To the extent Colbert receives research, Colbert will use it to benefit all clients. (See discussion of Soft Dollar Practices below). In seeking best execution, the determinative factor is not the lowest possible cost but whether the transaction represents the best qualitative execution, taking into consideration the full range of the executing broker’s services, including the institution’s financial strength, reputation, soundness, execution capability, commission rates, and responsiveness. Colbert will periodically evaluate the quality and cost of services received. As part of its evaluation, Colbert will consider the quality and cost of services available from alternative brokers, market makers, and market centers, as well as the institution’s capabilities, financial strength, reputation, soundness, and responsiveness. Soft Dollar Practices Colbert currently has no formal soft dollar arrangements and does not direct client transactions to any particular broker in exchange for soft-dollar benefits. Fidelity makes research and other services available to Colbert as part of its institutional platform, as described in Item 10. These benefits create a conflict of interest because they may incentivize Colbert to recommend Fidelity. To the extent Colbert receives research, it will be used to benefit all clients. Directed Brokerage Clients may direct Colbert in writing to use a particular broker or financial institution to execute some or all of the client's transactions. Client-directed brokerage may cost clients more money, and under such arrangements, Colbert may be unable to achieve the most favorable execution of client transactions. For example, in a directed brokerage arrangement, clients may pay higher brokerage commissions because Colbert may not be able to aggregate orders to reduce transaction costs, or clients may receive less favorable prices. Trade Aggregation When practicable and appropriate, Colbert will aggregate transactions for execution in order to facilitate best execution and allow for the negotiation of more favorable brokerage commissions. In 12  such cases, client portfolio orders for the same security will be combined and executed as a block transaction, and the average execution price across all aggregated purchases and sales will be used for all accounts. A partial fill will be allocated randomly among client accounts or in a manner that is fair to all clients. This practice may not always affect or otherwise reduce fees, commissions, or other costs charged to clients or provide price improvement. In any given situation, Colbert attempts to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation, and the availability of funds, using price averaging, proration, and consistently non-arbitrary allocation methods. Client orders will generally be aggregated with the orders of Colbert’s employees or Access Persons. Allocation of Investment Opportunities From time to time, two or more client accounts may seek to invest in the same securities or pursue a similar strategy. Conflicts of interest may arise regarding the amount of time devoted to managing any one account, or allocating investment opportunities among the client accounts we manage. We may buy or sell a security for a given client but not for another client with the same or similar investment objectives. Clients may have different circumstances, investment strategies, or expected trading levels. Colbert seeks to ensure that no account or group of accounts is favored or preferred over another. Principal and Cross Trades Colbert does not engage in principal trades or agency cross transactions for client accounts. Colbert does not generally effect cross trades between client accounts; any such cross trade would be handled on an exception basis, in accordance with applicable rules, and only if in the best interests of the clients involved. Errors Colbert seeks to identify and rectify errors as quickly as possible. Colbert has a trade error procedure that requires supervisory personnel to review and approve trade corrections. Item 13 Review of Accounts Accounts are reviewed on an ongoing basis and at least quarterly. At least annually, we will perform a comprehensive review of the advisory account and, upon a client's request, we will perform such comprehensive reviews upon the occurrence of any agreed-upon triggering event or events. Factors that may trigger more frequent reviews include, but are not limited to, major market or economic events, client meetings, client’s life events, large deposits or withdrawals, or client requests. 13  For discretionary accounts, if necessary, the allocation of each portfolio is adjusted based on the client's investment objectives, risk tolerance, and financial needs. Clients receive trade confirmations and account statements directly from the custodian at least quarterly. Additionally, clients will receive written quarterly and yearly performance reports from us. Item 14 Client Referrals and Other Compensation At this time, Colbert has not entered into referral agreements with independent solicitors (also known as referral agents or promoters), for the referral of clients to our Firm. However, we may do so at any time under the provisions of Advisers Act Rule 206 (4)-1, as amended, and applicable state laws. Any clients referred to Colbert will be given a full written disclosure describing the terms and fee arrangements between Colbert and the solicitor (s). These arrangements will not result in higher costs to the referred client. In cases where state law requires licensure of promoters, Colbert shall ensure that no solicitation fees are paid unless the solicitor is registered as an investment advisor representative in that state. Item 15 Custody Colbert recommends that clients use Fidelity as their Qualified Custodian. Colbert considers Fidelity’s financial strength, reputation, soundness, and range of services when recommending its custody services. Clients should be aware that the custody fees, commissions, transactions, and other fees charged by Fidelity may be higher or lower than those charged by other financial institutions. We maintain policies and procedures to comply with the requirements of the Custody Rule. The limited ability of Colbert to instruct the Client’s custodian to deduct our advisory fees results in Colbert being deemed to exercise custody over the Client's assets. We do not physically hold clients’ funds or securities or have the authority to withdraw funds (other than our advisory fees) in compliance with the Custody Rule. We are also deemed to have custody of clients’ assets in situations where clients have granted us authority under a standing letter of authorization (“SLOA”) to direct their custodian to transfer funds to a third party they have designated. The SEC has issued a no-action letter providing relief from certain Custody Rule requirements if we comply with the safeguards outlined in the letter. We intend to comply with such safeguards. Clients receive quarterly or more frequent account statements directly from their custodian(s). The custodian(s)’ also offer clients online access to their accounts. The account statements reflect all activity during the period, including purchases and sales, funds deposited or disbursed from the account, and the amount of investment advisory fees paid directly to us. Clients should review their account statements carefully and promptly inform us if they have any questions or have not received their statements. 14  Item 16 Investment Discretion We manage client accounts on both a discretionary and non-discretionary basis. For accounts over which we have investment discretion, our signed client agreements set forth the terms, conditions, and limitations on such authority. According to discretionary authorization, Colbert is authorized to execute securities transactions on the client’s behalf, determine which securities to buy and sell, and the amount of securities to be bought and sold. For non-discretionary accounts, we are required to obtain the client’s approval before implementing our recommendations. Item 17 Voting Client Securities As outlined in the Investment Advisory Agreement, Colbert will generally, but not always, not vote proxies on behalf of clients. Additionally, we generally will not vote on corporate actions, tender offers, or legal proceedings, including bankruptcies and class actions, or on their issuers, that do not require a proxy or are not solicited via a proxy. A copy of our procedures on proxy voting is available upon request by contacting us at the number on the front page of this Brochure. Item 18 Financial Information We are required to provide clients with certain financial information or disclosures about the advisor’s financial condition. As of the date of this brochure, Colbert has no financial commitments or liabilities that could impair our ability to manage client accounts and meet our contractual commitments to clients. Colbert and its management have not been the subject of any bankruptcy or other proceeding that could affect their financial condition. 15