PELICAN ADV 2AB

Item 1: Cover Page FORM ADV PART 2A INFORMATIONAL BROCHURE PELICAN ADVISORY LLC 681 River Highland Blvd. Covington, LA 70433 www.pelicanfo.com Matthew Greene, CCO (985) 237-4033 October 30, 2026 This brochure provides information about the qualifications and business practices of Pelican Advisory, LLC. If you have any questions about the contents of this brochure, please contact us at (985) 635-0770. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Pelican Advisory, LLC is a registered investment advisor. Registration of an Investment Advisor does not imply any level of skill or training. The oral and written communications of an Advisor provide you with information about which you determine to hire or retain an Advisor. Additional information about Pelican Advisory, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2: Material Changes Pelican Advisory, LLC is required to update this section with any material changes. As of the time of this disclosure brochure both Items 9 and Items 10 have been updated. Item 3: Table of Contents Cover Page Item 1: 1 Material Changes Item 2: 2 Table of Contents Item 3: 2 Advisory Business Item 4: 3 Fees and Compensation Item 5: 5 Performance-Based Fees and Side-By-Side Management Item 6: 7 Types of Clients Item 7: 7 Methods of Analysis, Investment Strategies and Risk of Loss Item 8: 7 Disciplinary Information Item 9: 11 Other Financial Industry Activities and Affiliations Item 10: 11 Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading Item 11: 13 Brokerage Practices Item 12: 13 Review of Accounts Item 13: 16 Client Referrals and Other Compensation Item 14: 16 Custody Item 15: 17 Investment Discretion Item 16: 17 Voting Client Securities Item 17: 17 Financial Information Item 18: 18  INFORMATIONAL BROCHURE PELICAN ADVISORY, LLC Item 4: Advisory Business Pelican Advisory LLC (“Pelican”) has been in business since April 2024. Pelican is owned by Matthew Greene. Advisory Services Managing the financial circumstances of a family requires a team comprised of people with knowledge and experience in multiple disciplines. To be as effective as possible, we believe these teams need a leader; someone who can put all the pieces together, overseeing, planning, and managing the finances for the family. This leader becomes the primary point of contact, so the family can focus on what makes them successful. At Pelican, we strive to become a team leader for our clients, easing their path towards the goals they set for their family and the impact of its wealth. This service begins with providing Pelican information including income, investments, savings, insurance, age of family members, goals, financially-related projects, and any other items that are helpful to the firm in assessing a client’s needs. The information is typically provided during personal interviews and may be supplemented with written information. Once the information is received, Pelican will discuss needs and goals with the client, including taking an active role in thinking through priorities for planning in the short, medium, and long term. For some people, this service might be called “financial planning”. At Pelican, it’s more than traditional financial planning, because we at Pelican take an active role. We don’t just advise the family to seek an estate plan, we will help the family identify the need, choose a provider, and then we will work with that provider and the family until that part of the plan is complete. Pelican continues this process throughout the relationship, proactively making recommendations on an ongoing basis in order to constantly work towards meeting client goals, and then providing guidance and leadership to facilitate the tasks required to implement the recommendations. Our clients will have an advisor at the ready for all their major life decisions, taking into consideration how the various aspects of that decision will impact the other areas of the family’s goals and objectives. An integral part of this process is managing the client’s investment assets. We will almost always do this on a “discretionary” basis. This means we will make changes in a client’s investment account on what we feel is an as-needed basis, without consulting the client prior to each change. All of these changes would of course be within the client’s investment objectives. Because of our overall approach to servicing clients, all client assets are managed on a client-by-client basis, with each portfolio designed for that particular client, as opposed to a “one size fits most” approach. Our approach also enables us to provide advice on a variety of assets and asset types: if a client wants to discuss an investment option, we are here to provide guidance on whether we believe that option works within their goals and needs.  LPL Programs We may provide advisory services through certain programs sponsored by LPL Financial LLC (LPL), a registered investment advisor and broker-dealer. Below is a brief description of each LPL advisory program available to Pelican. For more information regarding the LPL programs, including more information on the advisory services and fees that apply, the types of investments available in the programs and the potential conflicts of interest presented by the programs please see the program account packet (which includes the account agreement and LPL Form ADV program brochure) and the Form ADV, Part 2A of LPL or the applicable program. In many instances, LPL makes available mutual funds in a SWM account that offer various classes of shares, including shares designated as Class A Shares and shares designed for advisory programs, which can be titled, for example, as “Class I,” “institutional,” “investor,” “retail,” “service,” “administrative” or “platform” share classes (“Platform Shares”). The Platform Share class offered for a particular mutual fund in SWM in many cases will not be the least expensive share class that the mutual fund makes available, and was selected by LPL in certain cases because the share class pays LPL compensation for the administrative and recordkeeping services LPL provides to the mutual fund. Client should understand that another financial services firm may offer the same mutual fund at a lower overall cost to the investor than is available through SWM. In other instances, a mutual fund may offer only Class A Shares, but another similar mutual fund may be available that offers Platform Shares. Class A Shares typically pay LPL a 12b-1 fee for providing shareholder services, distribution, and marketing expenses (“brokerage-related services”) to the mutual funds. Platform Shares generally are not subject to 12b-1 fees. As a result of the different expenses of the mutual fund share classes, it is generally more expensive for a client to own Class A Shares than Platform Shares. An investor in Platform Shares will pay lower fees over time, and keep more of his or her investment returns than an investor who holds Class A Shares of the same fund. Pelican has a financial incentive to recommend Class A Shares in cases where both Class A and Platform Shares are available. This is a conflict of interest which might incline Pelican, consciously or unconsciously, to render advice that is not disinterested. Although the client will not be charged a transaction charge for transactions, Advisor pays LPL a per transaction charge for mutual fund purchases and sales in the account. Pelican generally does not pay transaction charges for Class A Share mutual fund transactions accounts, but generally does pay transaction charges for Platform Share mutual fund transactions. The cost to Pelican of transaction charges generally may be a factor Advisor considers when deciding which securities to select and whether or not to place transactions in the account. The lack of transaction charges to Pelican for Class A Share purchases and sales, together with the fact that Platform Shares generally are less expensive for a client to own, presents a significant conflict of interest between Pelican and the client. In short, it costs Pelican less to recommend and select Class A share mutual funds than Platform shares, but Platform shares will generally outperform Class A mutual fund shares on the basis of internal cost structure alone. Clients should understand this conflict and consider the  additional indirect expenses borne as a result of the mutual fund fees when negotiating and discussing with Pelican the advisory fee for management of an account. Assets Under Management As of July 15, 2026 Pelican has a total of $119,006,150 in Assets Under Management across 265 accounts, all of which are managed on a discretionary basis. Item 5: Fees and Compensation A. Fees Charged All individuals will be required to execute an agreement with Pelican outlining the services to be performed, as well as the fees for those services. Fees are negotiable. Clients are under no obligation at any time to engage or to continue to engage Pelican for any services. If clients do not receive a copy of this brochure at least 48 hours prior to the execution of an Agreement, clients may terminate the agreement within the first five (5) business days without penalty. Asset Management Fees For those clients receiving asset management services, Pelican’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under Pelican’s management as follows: Market Value of Portfolio % of Assets Up to $500,000 1.25% $500,001-$1,000,000 1.00% $1,000,001-$3,000,000 0.90% Above $3,000,001 0.80% American Funds Accounts Flat 0.50% Pelican generally requires a household account minimum of $100,000 for investment management services which can be waived in the sole discretion of Pelican. For households less than $100,000, an additional .25% is charged. However, Pelican, in its sole discretion, may require a lesser account minimum or charge a lesser investment management fee based upon various factors including, but not limited to, the amount of the assets with Pelican, the level and scope of financial planning services to be rendered and the complexity of the engagement.  B. Fee Payment Asset Management Fees Asset Management fees will be based on the assets under management. The fee is paid quarterly in arrears and comes due on the last day of the calendar quarter of the stated billing cycle based on the balance on that day. In calculating the market value of a client’s assets, assets allocated to cash or a cash proxy, such as a money market account, will be included in the calculation of assets under management. The calculation of the fee is done by the custodian and once the calculation is made, the custodian will deduct the fee from your account and remit it to Pelican. For example, if you give Pelican $100,000 to manage, then your fee is 1.25% annually for a total of $1,250 per year. That fee is then divided by 4 which is $312.50. The $312.50 is what will be deducted for the quarter from the client account. $100,000 x 1.25%/4 = $312.50 If a client becomes a client of Pelican or terminates as a client of Pelican during the quarterly billing period, the amount of the fee would be prorated accordingly from the start of the engagement or the termination of the engagement. C. Other Fees There are no additional fees payable to Pelican. In the event Pelican determines that a client would benefit from allocating assets to a third party investment manager, the fees for that investment manager will be separate from, and in addition to, fees paid to Pelican. Clients should thoroughly and carefully review all materials from any investment manager prior to executing or otherwise entering into any agreement with an investment manager. Clients may incur other expenses with the implementation of advice provided such as commissions, custodian fees, or mutual fund expenses. None of these fees is payable to Pelican. D. Pro-rata Fees Accounts initiated or terminated during the quarter will be charged a prorated fee based on the amount of time remaining in the billing period. An account can be terminated by either party if canceled in writing. E. Compensation for the Sale of Securities Our Firm and representatives do not sell securities for a commission. There are a number of other expenses charged by the custodian that can be associated with holding and investing in securities. The Client will be responsible for any expenses such as transaction fees, none of which are paid to Pelican. Expenses of a fund will not be included in management fees, as they are deducted from the value of the shares by the  mutual fund or ETF manager. For complete discussion of expenses related to each mutual fund or ETF, you should read a copy of the prospectus issued by that fund. Pelican will provide or direct you to a copy of the prospectus for any fund that it recommends to you. Please make sure to read Item 12 of this informational brochure, where we discuss broker- dealer and custodial issues. Item 6: Performance-Based Fees and Side-By-Side Management Pelican will not charge performance-based fees nor participate in side-by-side management. Item 7: Types of Clients Pelican’s primary client type is families with assets of at least $1,000,000. However, Pelican may also advise business owners, high net-worth individuals and pension plans. These additional client types are likely to be related to one of our client families. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Asset allocation strategies are developed for each client based on the needs of that client. Each client portfolio is designed to fit that client’s risk tolerance, as measured by a third party risk tool, Riskalyze. Pelican will develop an asset allocation strategy, which would typically involve some allocation to equities (which can include stock based ETFs or mutual funds) and an allocation to fixed income (which can include bond based ETFs or mutual funds). Pelican will also use other asset types where a Pelican professional deems appropriate. These can include annuities, non-traded securities and structured notes. While Pelican can and does utilize mutual funds where it feels appropriate, Pelican expects to predominantly allocate assets to ETFs in order to lower costs and tax impact for the client. These ETFs are chosen for client portfolios based on an evaluation of cost, performance, investment program and manager. Pelican chooses a selection of large cap growth, large cap value, small cap, international and emerging markets ETFs as the main equity pieces of the portfolio. On the fixed income side, Pelican chooses long duration, mid duration, short duration, and international bond ETFs. All ETFs are evaluated on an ongoing basis. We base our conclusions on predominantly publicly available research, such as regulatory filings, press releases, competitor analyses, and in some cases research we receive from our custodian or other market analyses. We will also utilize technical analyses, which means that we will review the past behaviors of the security and the markets in which it trades for signals as to what might happen in the future. Additionally, as assets are transitioned from a client’s prior advisors to Pelican, clients may hold legacy securities and may place restrictions on individual security types. Legacy securities are those that a client owned prior to or separate from its Pelican portfolio. If a client transitions mutual fund shares to Pelican that are not the lowest-cost share class, and Pelican is not recommending disposing of the security altogether, Pelican will attempt to  convert such mutual fund share classes into the lowest-cost share classes the client is eligible for, taking into account any adverse tax consequences associated with such conversion. Examples of Risks There are always risks to investing. Clients should be aware that all investments carry various types of risk including the potential loss of principal that clients should be prepared to bear. It is impossible to name all possible types of risks. Among the risks are the following:  Political Risks. Most investments have a global component, even domestic stocks. Political events anywhere in the world may have unforeseen consequences to markets around the world.  General Market Risks. Markets can, as a whole, go up or down on various news releases or for no understandable reason at all. This sometimes means that the price of specific securities could go up or down without real reason, and may take some time to recover any lost value. Adding additional securities does not help to minimize this risk since all securities may be affected by market fluctuations.  Currency Risk. When investing in another country using another currency, the changes in the value of the currency can change the value of your security value in your portfolio.  Regulatory Risk. Changes in laws and regulations from any government can change the value of a given company and its accompanying securities. Certain industries are more susceptible to government regulation. Changes in zoning, tax structure or laws impact the return on these investments.  Tax Risks Related to Short Term Trading: Clients should note that Pelican may engage in short-term trading transactions. These transactions may result in short term gains or losses for federal and state tax purposes, which may be taxed at a higher rate than long term strategies. Pelican endeavors to invest client assets in a tax efficient manner, but all clients are advised to consult with their tax professionals regarding the transactions in client accounts.  Purchasing Power Risk. Purchasing power risk is the risk that your investment’s value will decline as the price of goods rises (inflation). The investment’s value itself does not decline, but its relative value does, which is the same thing. Inflation can happen for a variety of complex reasons, including a growing economy and a rising money supply.  Business Risk. This can be thought of as certainty or uncertainty of income. Management comes under business risk. Cyclical companies (like automobile companies) have more business risk because of the less steady income stream. On the other hand, fast food chains tend to have steadier income streams and therefore, less business risk.  Financial Risk. The amount of debt or leverage determines the financial risk of a company.  Default Risk. This risk pertains to the ability of a company to service their debt. Ratings provided by several rating services help to identify those companies with more risk. Obligations of the U.S. government are said to be free of default risk.  Information Risk. All investment professionals rely on research in order to make conclusions about investment options. This research is always a mix of both internal  (proprietary) and external (provided by third parties) data and analyses. Even an adviser who says they rely solely on proprietary research must still collect data from third parties. This data, or outside research is chosen for its perceived reliability, but there is no guarantee that the data or research will be completely accurate. Failure in data accuracy or research will translate to a compromised ability by the adviser to reach satisfactory investment conclusions.  Small Companies. Some investment opportunities in the marketplace involve smaller issuers. These companies may be starting up, or are historically small. While these companies sometimes have potential for outsized returns, they also have the potential for losses because the reasons the company is small are also risks to the company’s future. For example, a company’s management may lack experience, or the company’s capital for growth may be restricted. These small companies also tend to trade less frequently than larger companies, which can add to the risks associated with their securities because the ability to sell them at an appropriate price may be limited as compared to the markets as a whole. Not only do these companies have investment risk, if a client is invested in such small companies and requests immediate or short term liquidity, these securities may require a significant discount to value in order to be sold in a shorter time frame.  Concentration Risk. While Pelican selects individual securities, including mutual funds, for client portfolios based on an individualized assessment of each security, this evaluation comes without an overlay of general economic or sector specific issue analysis. This means that a client’s equity portfolio may be concentrated in a specific sector, geography, or sub-sector (among other types of potential concentrations), so that if an unexpected event occurs that affects that specific sector or geography, for example, the client’s equity portfolio may be affected negatively, including significant losses.  Funds Available Risk. Clients who have check-writing authority for their accounts are responsible for losses related to trades not occurring due to a lack of cash within their account.  Excess Cash Balance Risk. In the rare instances where a client accounts may have cash balances in excess of $250,000, which is the insurance limit of the Federal Deposit Insurance Corporation. For cash balances in excess of that amount, there is an enhanced risk that operation-related counterparty risk related to the account custodian could cause losses in the account. We mitigate this risk by carrying cash balances in amounts either subject to protection or as limited as you, the client, directs. You may elect to participate in a “cash sweep” program through your account custodian which automatically moves excess cash from your investment account into a cash account and then invests that cash into cash- based investments, such as money market funds. We do not receive compensation of any kind for facilitating your participation in such cash sweep accounts.  Transition Risk. As assets are transitioned from a client’s prior advisers to Pelican there may be securities and other investments that do not fit within the asset allocation strategy selected for the client. Accordingly, these investments will need to be sold in order to reposition the portfolio into the asset allocation strategy selected by Pelican. However, this transition process may take some time to accomplish. Some investments may not be unwound for a lengthy period of time for a variety of reasons that may include unwarranted low share prices, restrictions on trading, contractual restrictions on liquidity, or market- related liquidity concerns. In some cases, there may be securities or investments that are never able to be sold. The inability to transition a client's holdings into recommendations  of Pelican may adversely affect the client's account values, as Pelican’s recommendations may not be able to be fully implemented.  Restriction Risk. Clients may at all times place reasonable restrictions on the management of their accounts. However, placing these restrictions may make managing the accounts more difficult, thus lowering the potential for returns.  Risks Related to Investment Term & Liquidity. Securities do not follow a straight line up in value. All securities will have periods of time when the current price of the security is not an accurate measure of its value. If you require us to liquidate your portfolio during one of these periods, you will not realize as much value as you would have had the investment had the opportunity to regain its value. Further, some investments are made with the intention of the investment appreciating over an extended period of time. Liquidating these investments prior to their intended time horizon may result in losses.  Mutual Funds. The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. When selecting mutual funds that have multiple share classes for recommendation to clients, Pelican will take into account the internal fees and expenses associated with each share class, as it is our policy to choose the lowest-cost share class available, absent circumstances that dictate otherwise.  ETFs. The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large bid- ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.  Equity Securities. Equity securities tend to be more volatile than other investment choices. The value of an individual mutual fund or ETF can be more volatile than the market as a whole. This volatility affects the value of the client’s overall portfolio. Small and mid-cap companies are subject to additional risks. Smaller companies may experience greater volatility, higher failure rates, more limited markets, product lines, financial resources, and less management experience than larger companies. Smaller companies may also have a lower trading volume, which may disproportionately affect their market price, tending to make them fall more in response to selling pressure than is the case with larger companies.  Fixed Income. The issuer of a fixed income security may not be able to make interest and principal payments when due. Generally, the lower the credit rating of a security, the greater the risk that the issuer will default on its obligation. If a rating agency gives a debt security a lower rating, the value of the debt security will decline because investors will demand a higher rate of return. As nominal interest rates rise, the value of fixed income securities held by the Fund is likely to decrease. A nominal interest rate is the sum of a real interest rate and an expected inflation rate.  Structured Notes. Pelican may include structured notes within its investment portfolios when deemed appropriate. Structured notes have a relative lack of liquidity due  to the highly customized nature of the investment and rarely trade after issuance. Moreover, the full extent of returns from the complex performance features is not realized until maturity. Selling before maturity may be at a significant discount. Because of this, structured notes tend to be more of a buy-and-hold investment decision. Counterparty risk is another inherent risk with structured notes. A principal protected note is backed by the firm that issued the note. In the case of a bankruptcy of the issuer, the note holder would be repaid at a rate equivalent to other senior unsecured debt holders of the firm. Principal protected notes are not usually FDIC insured. A special note related to the calculation of tax basis: If a client is unable to provide information on cost basis for tax purposes for each investment at the onset of the client relationship, Pelican will be unable to provide accurate cost basis information in the future. To the extent any cost basis calculation is ever performed for a client, such client should be aware that without accurate information, any cost basis estimates prepared by Pelican will be based on the information available combined with certain assumptions as well as mathematical computation. Therefore, if the cost basis is not accurate at the onset of the relationship, there is no guarantee that Pelican’s calculations will be correct, and materially adverse tax circumstances may result. Item 9: Disciplinary Information Yes. One of our financial professionals, Matthew Greene, is currently named in a pending FINRA arbitration claim (filed March 2026) in which a customer alleges he failed to adequately disclose the risks associated with an investment recommendation. The claim does not specify a damages amount, though the firm's good-faith estimate is that potential damages could exceed $5,000. The matter is still pending, and no arbitration panel finding, settlement, or judgment has been reached. Matthew Greene and Gabriel Martin both have customer disputes that are pending for activities while registered representatives at LPL Financial Services related to the same arbitration claim. Free and simple tools are available to research firms and financial professionals at Investor.gov/CRS. Item 10: Other Financial Industry Activities and Affiliations A. (1) - Broker-dealer / (2) – Third-party Money Manager None of the principals of Pelican, Pelican itself, or any of its associated persons are registered, or have an application pending to register, as a broker dealer or as an associated person of a broker-dealer. B. Futures Commission Merchant/Commodity Trading Advisor None of the principals of Pelican, nor any related persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities.  C. Relationship with Related Persons Certain professionals of Pelican are separately licensed as independent insurance agents for purposes of servicing existing clients that have insurance products. Pelican does not intend to sell new insurance products but has the ability to do so if warranted. As such, these professionals may conduct insurance product transactions for Pelican clients in their capacity as licensed insurance agents and will receive customary commissions for these transactions in addition to any compensation received from advisory services. Commissions from the sale of insurance products will not be used to offset or as a credit against advisory fees. These certain professionals therefore have an incentive to recommend insurance products based on the compensation to be received. The receipt of additional fees for insurance commissions is therefore a conflict of interest, and clients should be aware of this conflict when considering whether to engage Pelican to implement any insurance recommendations. Pelican attempts to mitigate this conflict of interest by disclosing the conflict to clients and informing the clients that they are always free to purchase insurance products through other agents that are not affiliated with Pelican, or to determine not to purchase the insurance product at all. Pelican also attempts to mitigate the conflict of interest by requiring employees to acknowledge in the firm’s Code of Ethics, their individual fiduciary duty to the clients of Pelican, which requires that employees put the interests of clients ahead of their own. D. Recommendations of Other Advisers An area of pride for Pelican is our network of experienced professionals who can provide a variety of services for our clients. They may be professionals in the insurance industry that can handle complex cases, or attorneys we believe are capable of creating complex estate plans, among other things. While we may recommend a provider to a client, that client is never under an obligation to choose that provider. Pelican is happy to work with whatever professional advisors the client chooses. In addition, Pelican will never take any sort of referral fee from the professionals we might recommend to a client. PFO Consulting LLC PFO Consulting LLC (“Consulting”) is an affiliated entity that offers planning services under a separate engagement. Consulting is owned by Matthew Greene and Jack Branch, Jr. Consulting does not act as an investment advisor nor does Consulting provide investment advice but does provide access to tax professionals to assist with tax planning and implementation of tax strategies. Consulting does have a conflict of interest where there is an incentive for Consulting to refer clients to their network of tax professionals because of revenue sharing agreements with the tax professionals. The same services could be provided by other tax professionals at a lower cost. PFO Risk Management  PFO Risk Management implements insurance products in accordance with client insurance needs such as life and disability insurance and is owned by Jack Branch Jr. Because certain individuals of Pelican are separately licensed as independent insurance agents and receive additional compensation through PFO Risk Management for the implementation of the insurance products, there is a conflict of interest where there is incentive for the licensed individuals to implement the insurance products. The same services could be provided by other insurance agents at a lower cost. Item 11: Code of Ethics, Participation, or Interest in Client Transactions and Personal Trading A. A copy of our Code of Ethics is available upon request. Our Code of Ethics includes discussions of our fiduciary duty to clients, political contributions, gifts, entertainment, and trading guidelines. B. Not applicable. Pelican does not recommend to clients that they invest in any security in which Pelican or any principal thereof has any financial interest. C. On occasion, an employee of Pelican may purchase for his or her own account securities which are also recommended for clients. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades must be reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. D. On occasion, an employee of Pelican may purchase for his or her own account securities which are also recommended for clients at the same time the clients purchase the securities. Our Code of Ethics details rules for employees regarding personal trading and avoiding conflicts of interest related to trading in one’s own account. To avoid placing a trade before a client (in the case of a purchase) or after a client (in the case of a sale), all employee trades must be reviewed by the Compliance Officer. All employee trades must either take place in the same block as a client trade or sufficiently apart in time from the client trade so the employee receives no added benefit. Employee statements are reviewed to confirm compliance with the trading procedures. Item 12: Brokerage Practices Pelican does not maintain custody of client assets, though Pelican may be deemed to have custody if a client grants Pelican authority to debit fees directly from their account (see Item 15 below). Assets will be held with a qualified custodian, which is typically a bank or broker-dealer. Pelican recommends that investment accounts be held in custody by Schwab Advisor Services (“Schwab”). Pelican is independently owned and operated and is not affiliated with Schwab. Schwab will hold your assets in a brokerage account and  buy and sell securities when Pelican instructs them to, which Pelican does in accordance with its agreement with you. While Pelican recommends that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Pelican does not open the account for you, although Pelican may assist you in doing so. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). How we select brokers/custodians We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are, overall, most advantageous when compared with other available providers and their services. We consider a wide range of factors, including both quantitative (Ex: costs) and qualitative (execution, reputation, service) factors. We do not consider whether Schwab or any other broker-dealer/custodian, refers clients to Pelican as part of our evaluation of these broker-dealers. Your brokerage and custody costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. In addition to commissions, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). Products and services available to us from Schwab Schwab Advisor Services™ (formerly called Schwab Institutional®) is Schwab’s business serving independent investment advisory firms like Pelican. They provide Pelican and our clients with access to its institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help Pelican manage or administer our clients’ accounts, while others help Pelican manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to Pelican. Following is a more detailed description of Schwab’s support services: Services that benefit you Schwab’s institutional brokerage services include access to a broad range of investment  products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that may not directly benefit you. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • Provide access to client account data (such as duplicate trade confirmations and account statements). • Facilitate trade execution and allocate aggregated trade orders for multiple client accounts. • Provide pricing and other market data. • Facilitate payment of our fees from our clients’ accounts. • Assist with back-office functions, recordkeeping, and client reporting. Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers Schwab may provide some of these services itself. In other cases, it will arrange for third- party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our interest in Schwab’s services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. We may have an incentive to recommend that you maintain your account with Schwab, based on our interest in receiving Schwab’s services that benefit our business rather than based on your interest in receiving the best value in  custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/ custodians”) and not Schwab’s services that benefit only us. We do not consider whether Schwab or any other broker-dealer/custodian, refers clients to Pelican as part of our evaluation of these broker-dealers. Directed Brokerage Some clients may request that we utilize a specific broker dealer for their transactions. This can affect what transaction fees are paid, and how much those costs will be. In some cases, clients will have assets managed by a third-party manager, and that manager will have a recommended broker-dealer or custodian other than one recommended by Pelican. Clients which, in whole or in part, direct Pelican to use a particular broker to execute transactions (or whose assets are with a third-party manager who uses a different custodian) for their accounts should be aware that, in so doing, they may adversely affect Pelican's ability to, among other things, obtain best price and execution, and the cost of the transaction may be greater. Clients that direct their brokerage should also be aware that Pelican will generally place such trades after the completion of trades for clients that do not direct their brokerage. Item 13: Review of Accounts All client profiles will be managed on an ongoing basis, with formal reviews with the client on at least an annual basis. However, it is expected that market conditions, changes in a particular client’s account, or changes to a client’s circumstances will trigger a review of accounts. Item 14: Client Referrals and Other Compensation A. Economic Benefit Provided by Third Parties for Advice Rendered to Client. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. In addition, Schwab has also agreed to pay for certain products and services for which we would otherwise have to pay once the value of our clients’ assets in accounts at Schwab reaches a certain size. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. The products and services provided by Schwab, how they benefit us, and the related conflicts of interest are described above (see Item12—Brokerage Practices).  B. Compensation to Non-Advisory Personnel for Client Referrals. Pelican does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody Pelican has the ability to have its advisory fee for each client debited by the custodian on a quarterly basis. Clients are provided, at least quarterly, with written transaction confirmation notices and regular written summary account statements directly from the broker-dealer/custodian and/or program sponsor for the client accounts. Client should carefully review any statement received from the account custodian. Although the payment of adviser fees directly from a client’s account is deemed custody, the custody requirements are not applicable as Pelican complies with the following procedures:  Pelican possesses written authorization from clients to deduct advisory fees from an account held by a qualified custodian;  Pelican sends the qualified custodian written notice of the amount of the fee to be deducted from the client’s account; and  Pelican sends the client a written invoice itemizing the fee, including any formulae used to calculate the fee, the time period covered by the fee and the amount of assets under management on which the fee was based. Item 16: Investment Discretion For those Client accounts where Pelican maintains discretion over client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold, investment discretion is explained to clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the client will execute a Limited Power of Attorney contained in the account opening documents which will grant our firm discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the client. For clients who engage Pelican on a non-discretionary basis, while there will be an ongoing relationship with each client, being involved in various stages of their lives and decisions to be made, Pelican will seek specific approval of changes to client accounts before any changes are made. Clients can always make deposits or withdrawals in their accounts at any time. Item 17: Voting Client Securities Copies of our Proxy Voting Policies are available upon request.  From time to time, shareholders of stocks, mutual funds, exchange traded funds or other securities may be permitted to vote on various types of corporate actions. Examples of these actions include mergers, tender offers, or board elections. Clients are required to vote proxies related to their investments, or to choose not to vote their proxies. Pelican will not accept authority to vote client securities. Clients will receive their proxies directly from the custodian for the client account. Upon a client’s request, Pelican will give clients advice on how to vote proxies, but it is the responsibility of the client and the outside managers to vote client securities. Item 18: Financial Information Pelican does not require the prepayment of fees more than six (6) months or more in advance and therefore has not provided a balance sheet with this brochure. There are no material financial circumstances or conditions that would reasonably be expected to impair our ability to meet our contractual obligations to our clients.