Overview

Headquarters
Walnut Creek, CA
Total Firm Assets
$172 million
Average High-Net-Worth Client Portfolio Size
$4.6 million
Minimum Account Size
$1,000,000

Fee Structure

Primary Fee Schedule (CAVU WEALTH ADVISORS, LLC - 2026 ADV PART 2 AMENDMENT)

MinMaxMarginal Fee Rate
$0 $2,000,000 1.00%
$2,000,001 $5,000,000 0.75%
$5,000,001 $10,000,000 0.40%
$10,000,001 and above 0.25%

Minimum Annual Fee: $10,000

Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $10,000 1.00%
$5 million $42,500 0.85%
$10 million $62,500 0.62%
$50 million $162,500 0.32%
$100 million $287,500 0.29%

Clients

High-Net-Worth Share of Firm Assets
69.37%
Number of High-Net-Worth Clients
26
Total Client Accounts
81
Discretionary Accounts
81

Services Offered

Services: Financial Planning, Portfolio Management for Individuals

Regulatory Filings

SEC CRD Number
340677

Primary Brochure: CAVU WEALTH ADVISORS, LLC - 2026 ADV PART 2 AMENDMENT (2026-05-04)

View Document Text
CAVU Wealth Advisors, LLC 1220 Oakland Blvd., Suite 200 Walnut Creek, CA 94596 Phone: 925.388.0372 Fax: 877.240.1488 www.cavuwealth.com May 4, 2026 This Brochure provides information about the qualifications and business practices of CAVU Wealth Advisors LLC, (CAVU). If you have any questions about the contents of this Brochure, please contact David Sylvester at 925.289.9902 or via email: david@cavuwealth.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. 1 CAVU WEALTH ADVISORS is a registered investment advisor. Registration of an investment advisor does not imply any level of skill or training. An Advisor's oral and written communication offers information to help you decide whether to hire or retain them. Additional information about CAVU WEALTH ADVISORS also is available on the SEC’s website at www.adviserinfo.sec.gov. Our Brochure may be requested by contacting David Sylvester, Founding Principal at 925.289.9902 or david@cavuwealth.com. Our Brochure is also available on our website www.cavuwealth.com, also free of charge. Additional information about CAVU is available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site provides information about any persons affiliated with CAVU who are registered, or are required to be registered, as investment Advisor representatives of CAVU. Item 2 – Material Changes 1. CAVU Wealth Advisors, LLC began operation after spinning out of Blue Trust on May 2, 2026 2 Item 3 -Table of Contents Item 1 – Cover Page 1 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 11 Item 12 – Brokerage Practices 12 Item 13 – Review of Accounts 13 Item 14 – Client Referrals and Other Compensation 14 Item 15 – Custody 14 Item 16 – Investment Discretion 14 Item 17 – Voting Client Securities 15 Item 18 – Financial Information 15 Item 19 – Requirements for State-Registered Advisors – Owner/Employee Details 15 3 Item 4 – Advisory Business CAVU Wealth Advisors, LLC (CAVU) is a Registered Investment Advisor that provides two major types of services: (1) investment management and (2) financial planning. For most clients we bundle both services together to provide a comprehensive wealth management service for clients. We feel that this holistic approach provides the most effective service and a satisfying result for clients. We use the words “comprehensive” and “holistic” to describe our approach to working with clients. We believe that the financial advice we provide is better when we fully integrate all relevant factors in a client’s life into that advice. We seek to understand a client’s goals and incorporate discussions and actions related to estate planning (legal), tax planning (accounting), and insurance – all areas where our clients typically use other professional advisors. As part of our service, and at no extra charge, we offer to help coordinate the advice from all the client’s professional advisors. Our services can be categorized under two broad areas: (1) investment management and (2) financial planning. These services (described in more detail under Item 8) are bundled together in our comprehensive approach. We charge just one fee for the entire service. With all clients, we provide ongoing monitoring of client portfolios as part of our advisory service. The fee for our service is based on a fixed percentage of the assets under management at the time of billing. Occasionally, CAVU will provide financial consulting based on an hourly rate of $450. These types of services are discussed in detail below. Clients and Assets Under Management As of May 4, 2026, CAVU provides wealth management services for 81 clients. We manage $172 million in client assets. All CAVU assets are managed on a discretionary basis. This means that our clients authorize CAVU to make investment decisions independent of their approval. However, all investment decisions are guided by a written Investment Policy Statement that the client has signed. See Item 16, below. David Sylvester, CFA, CFP® is the founder and owns 66 2/3rds of CAVU. Hilary Disher CFP®, CAVU’s tax- strategist, is the co-owner of CAVU with a 33 1/3rd ownership interest. Each owner’s interest is held by their respective family trust entity. There are no other direct or indirect owners. Held-Away Account Services We provide an additional service for accounts not held at Schwab, but where we do have discretion. These are primarily retirement assets (401(k) accounts, etc.) 529 plans, variable annuities, and other assets not held at Schwab. We provide asset allocation and rebalancing strategies on these assets on behalf of the client. We regularly review the current holdings, and available investment options in these accounts, monitor the accounts, rebalance, and implement our strategies as necessary. 4 Billing of Held-Away Account Assets Held-away assets that we manage are billed using the client’s current fee schedule. These fees are usually deducted from the client’s taxable account that is managed by CAVU and held at Schwab. Otherwise, the client will be sent an invoice to be paid by check or other means. Item 5 – Fees and Compensation CAVU is a “fee-only” advisor. To be clear, CAVU does not accept any compensation for the sale of securities or other investment products. This includes asset-based sales charges or service fees from the sale of mutual funds. We charge an annual fee based on a percentage of assets under management. The fee is assessed on a quarterly basis (1/4 of the annual percentage fee) and is paid by the client at the beginning of the quarter based on the average account balance for the previous 90 days. Our minimum annual fee is $10,000 per year. We may waive that minimum fee, or negotiate our fees, under special circumstances. In most instances, CAVU fees are withdrawn directly from client accounts. Occasionally, CAVU will accept fees in the form of check or credit card payment. Financial Planning clients. A few CAVU clients have chosen not to utilize our investment expertise; they have their financial assets managed elsewhere. These clients hired CAVU just for our financial planning expertise. For these clients, we develop a written scope of services and negotiate an annual fee for the services we provide. We bill our Financial Planning clients quarterly, with ¼ of the annual fee due at the time of our billing. Clients can cancel their financial planning relationship with us at any time. Our fee will be prorated, and any unearned fees will be refunded to the client. Other Fees. Clients may incur and pay fees that are charged by our custodians, mutual funds, and ETF fund providers. CAVU does not benefit or share in any fees that 3rd parties may charge our clients. Separately Managed Account (SMA) fees. For some clients we recommend the use of an SMA as part of their investment strategy. We use SMA accounts, which are managed by a third party, to provide “direct indexing” and the related potential tax benefits for these clients. The SMA provider charges a service fee, similar to mutual fund and ETF management fees. This fee is disclosed in writing to the client and is paid by the client via a quarterly withdrawal by the SMA provider from the client account. CAVU does not receive any fee revenue that is paid to SMA providers. Said differently, SMA clients will pay two types of fees: a fee to the SMA provider and a fee paid to CAVU. This is identical to our clients who own ETFs and mutual funds; they pay a fee to the ETF/mutual fund manager, and they pay a fee to CAVU. “Soft Dollar” and other non-financial benefits received by CAVU. CAVU does not participate in any “soft-dollar” agreements. CAVU does receive access to research, technology, and custodial services from Schwab. Access to these features and services is given to all advisory firms that utilize the custodial services of Schwab. However, since CAVU does not pay for these services, we may face a potential conflict of interest as we are incentivized to recommend Schwab as our custodian. 5 For individual clients, CAVU generally provides non-investment financial planning advice on topics which include risk management, tax planning, cash flow management, retirement planning, education funding, wealth transfer, and other topics. This “comprehensive” advice is included in the annual fee we charge. Specialized Services Provided at an Hourly Rate. Occasionally CAVU may also contract with non-clients to provide specialized financial planning, consulting or advisory services at a rate of $450 per hour. All hourly fees are billed in arrears for work provided. This service is not for our current clients (who are billed as described above), but only for individuals who are seeking specific advice without having CAVU manage their financial assets under our annual fee agreement. Termination of Investment Advisory Agreements. All investment advisory agreements for CAVU services may be terminated at any time without penalty by written notice by the client to CAVU. Any fees paid by the client, but not yet earned by CAVU (i.e., calculated by a pro rata method), will be refunded in full, typically by crediting the client in the form of payment that was used in the previous fee payment. Assets Under Management Fee Schedule: Individual clients. These clients receive investment management and financial planning services. Institutional clients. These clients receive only investment management services. Annual Fee Schedule – Individual Accounts1 Fee Account Size 1.00% on portion up to - $ 2,000,000 0.75% on portion over - $ 2,000,000 0.40% on portion over - $ 5,000,000 0.25% on portion over - $10,000,000 Hourly Fee for Financial Planning Services2: $450 per hour 1 We aggregate related household accounts for purposes of applying fee breakpoints. 2 Financial planning services are normally included in the annual fee schedule above. However, in certain circumstances the client and advisor will determine that a specific planning project is outside of the normal scope of the annual fee. In these instances, CAVU will provide a letter identifying the scope of the project and the hourly fees that will be charged. 6 Institutional Fee Schedule Fee Account Size 0.75% on portion up to - $2,000,000 0.50% on portion over - $2,000,000 0.35% on portion over - $5,000,000 0.25% on portion over - $10,000,000 CAVU reserves the right to accept or decline a new client portfolio to manage. CAVU reserves the right to offer lower fees than stated above, under special circumstances. No fees will be charged, however, that are higher than those stated above. Item 6 – Performance-Based Fees and Side-By-Side Management CAVU does not charge any performance-based fees (fees based on a share of capital gains or capital appreciation of client assets). Item 7 – Types of Clients CAVU provides portfolio management services to individuals and institutions. Our primary market is for individual clients with financial assets ranging between $1 million and $25 million. We have found this market needs and appreciates the holistic approach to wealth management that CAVU practices. As a result of our low fees and use of low-cost passive investment funds, we believe that we are also an attractive investment management option for small and medium sized institutional accounts. These clients would typically be small trusts, foundations, endowments, charitable organizations, small businesses and defined contribution (i.e. 401k) or defined benefit retirement plans. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Our Investment Process The first step in our investment process is to determine the optimal asset allocation (between equities and fixed income) for the client. We work with the client to determine his/her tolerance for risk. We also take other factors into consideration (including, but not limited to, such factors as current net worth, financial asset composition, sources of income, near-term need for cash, etc.) before settling on 7 a target allocation. Once determined, we believe that a client's allocation should only change based on changes in the client's circumstances and not based on market movements or conditions. After determining the appropriate equity allocation, we then begin to build a portfolio that gives our clients broad exposure to the global capital markets. In most cases CAVU recommends portfolios based on various appropriate asset classes. The vehicles used to achieve these asset classes are usually “managed portfolios” such as no-load mutual funds and exchange traded funds representing particular markets and asset classes. When determining which of these “managed portfolios” to use, we focus on many factors (including, but not limited to, the long-term record of the fund, it's expense ratio, fidelity to its representation of that asset class, and the likely tax and cost consequences associated with investing in that managed portfolio). CAVU pays particular attention to the risk and return characteristics of the different assets classes that we recommend. For most clients we believe it is appropriate to provide some limited exposure to international markets which are usually not denominated in U.S dollars and which have different growth rate, risk, and return characteristics. We define “Asset Class” as a group of financial instruments with similar characteristics, market behavior, and regulatory treatment. Each asset class we use has been studied by academics for years and has a corresponding risk and return profile. Creating a portfolio out of asset classes gives clients a well- diversified portfolio that allows rebalancing potential to optimize returns over a long period of time. Most client portfolios consist of approximately 15 distinct asset classes. The equity portion might consist of 11 asset classes including U.S. based companies in the following asset classes: large company, large company value, small company, small company value and REIT managed portfolios. International exposure would include international large company, small company, small company value, emerging markets, emerging market small company and emerging market value. For clients with a global portfolio, U.S. equities would comprise approximately 2/3rds of the entire equity allocation, with non-U.S. equities comprising approximately 1/3rdof the equity exposure. Fixed income exposure is designed to provide a return on investment with very limited volatility. We focus on “managed portfolios” (i.e. mutual funds and ETFs) consisting of high credit quality securities. In addition, the “duration” in the portfolios is kept short to minimize volatility that could be caused by fluctuating interest rates. The outcome is a portfolio encompassing roughly 15 distinct asset classes that collectively contain thousands of individual securities. Diversification is enhanced by using appropriate non-U.S. asset classes. In making investment recommendations or preparing financial plans, CAVU obtains general information from commercially available services, including services covering taxation, investment companies, real estate investment trusts, stocks and bonds, annuities, market conditions, and historical information and rating on individual securities. CAVU may also employ consultants to provide additional expertise in 8 unique situations. Part of effective investment management is paying attention to the tax consequences of each investment decision. Frequently we manage several accounts for a client, some taxable and some tax deferred (retirement) accounts. We pay attention to “asset location” which often leads to tax- inefficient asset classes (notably REITS, fixed income securities and possibly value oriented funds) being placed in the tax deferred accounts. CAVU's investment strategies are developed to meet several basic requirements. First, they must be directed at a client's needs, goals, objectives, and risk tolerance. Second, they must be based on a disciplined, long-term investment outlook. CAVU will not attempt to predict short-term market movements, nor will CAVU engage in any “market-timing” strategies. As mentioned earlier, an important part of CAVU’s services is risk management. However, all investments made by CAVU have some degree of price volatility. None of the investments are guaranteed. All carry the possibility of loss of principal. Investing in securities involves risk of loss that clients should be prepared to bear. Our Planning Services CAVU provides financial planning services as part of our comprehensive service to our individual clients. CAVU supplies analysis in a broad range of financial areas. The specific nature of the planning services desired by the client will be determined prior to CAVU starting its work. The financial planning process starts with the gathering of financial information either through oral interviews or the completion of a financial questionnaire by the client. CAVU then consults with the client and prepares a written plan based on the individual client's financial needs, goals and tax status. The client receives a copy of this written plan, which is presented and discussed in one or more personal meetings. Implementation of any recommendations made in the plan is at the client's discretion. In most cases, a plan will consist of a “Strategic Financial Plan,” which outlines specific financial and retirement goals and calculates the rate of return and savings rate required to achieve them. Normally the strategic plan also contains an asset summary, consisting of a compilation of the client's existing investment assets. In some cases, the plan may contain other analyses depending on individual needs. These may include tax planning, insurance needs planning and educational funding models. In each case, written recommendations will be made on the investments, budgets, cash flows, and savings that the analysis suggests. Risk Management Helping to manage the risks that affect clients is a primary function of CAVU’s service. The assessment of risks listed below apply to our methods of analysis as well as our investment strategy. 9 The risks listed below are some (but not all) of the risks that we monitor for our clients: CAVU Solutions Key Risks Client emotion Asset allocation Longevity Market Business & Event Interest rate Credit Currency Liquidity Geopolitical Advisor discipline and investment architecture Test and evaluate client’s tolerance for volatility/assess cash flow needs Develop and monitor strategic financial plan Design portfolios to efficiently accept this risk Diversify away using index-like investment funds Keep fixed income maturities short Concentrate fixed income in Investment grade securities Recognize global economy and maintain diversification Assess cash needs, use very liquid investment securities Diversify across all geographies and avoid investment exposure to non- transparent economies Use large custodians (Schwab, Fidelity) to hold client assets. Diversify Construct portfolios with >90% in daily ability to liquidate entire position Diversification Monitor portfolios for index tracking error Cybersecurity Liquidity risk Concentration SMA manager CAVU's approach to risk management incorporates a variety of strategies designed to address the diverse risks faced by clients. By systematically evaluating asset allocation, longevity, market conditions, business and event risks, interest rate exposure, credit quality, currency diversification, liquidity, geopolitical factors, cybersecurity, liquidity risk, concentration, and manager oversight, CAVU aims to provide tailored solutions that support client goals and help mitigate potential losses. This comprehensive methodology reflects our commitment to disciplined financial planning and proactive risk assessment, ensuring that clients' portfolios are constructed and monitored with care and expertise. Item 9 – Disciplinary Information Registered investment Advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of CAVU or the integrity of CAVU’s management. CAVU and its employees have never been involved in any disciplinary action. Item 10 – Other Financial Industry Activities and Affiliations In connection with its financial and investment advisory services, CAVU may provide advice on the need for insurance products. However, this advice can only be implemented through a third-party agent licensed to sell insurance. (To maintain its fiduciary role, CAVU has chosen not to sell any insurance products.) There will be no commissions or benefits, either directly or indirectly, received by CAVU on these transactions. CAVU may provide investment management services to other financial advisors on an independent contractor basis. The investment management philosophy, process, methodology, and investment 10 vehicles would be substantially similar to the investment process described under Item 8 above. CAVU charges a fee for these services, which is based on the assets under management at the end of the quarter. Item 11 – Code of Ethics CAVU has adopted a Code of Ethics for all supervised people of the firm describing its high standard of business conduct and fiduciary duty to its clients. The Code of Ethics includes, among other things, provisions relating to the confidentiality of client information, fairness and full disclosures. (See full Code of Ethics below.) All supervised people at CAVU must acknowledge the terms of the Code of Ethics annually, or as amended. From time-to-time principals of CAVU may recommend investments that they already own or intend to purchase for their own accounts. Indeed, the principals of CAVU have a policy to purchase for their own accounts, to the extent consistent with their goals and objectives, the same investments recommended to clients in similar circumstances. In most instances such transactions will involve publicly traded mutual funds and ETFs. In the case of ETFs, our personal trading policy is to complete all client orders prior to any identical ETF trading in our own account. To avoid any potential conflicts of interest involving personal trades, CAVU has adopted a Code of Ethics which includes personal trading and insider trading policies and procedures. CAVU's Personal Trading Policy also requires employees to report personal securities transactions on at least a quarterly basis and provide CAVU with a detailed summary of certain holdings (both initially upon commencement of employment and annually thereafter) over which such employees have a direct or indirect beneficial interest. The firm will provide a copy of the Code of Ethics to any clients or prospective clients upon request. CAVU Wealth Advisors Code of Ethics Objectivity: We strive to be as unbiased as possible in providing advice to clients. Confidentiality: We will keep all client data private unless authorization is received from the client to share it. We will treat all documents with care and take care when disposing of them. Relations with clients will be kept private. Competence: We strive to maintain a high level of knowledge and ability. We participate in continuing education at least at the minimum level required for a CFP® certificant. We won’t provide advice in areas where we are not capable. 11 Fairness & Suitability: Our dealings and recommendations with clients will always be in the client’s best interests. Integrity & Honesty: We will maintain a high degree of integrity and honesty in all our activities. This includes our activities with our clients, our fellow workers, prospective clients, and our third-party vendors. Regulatory Compliance: Following government regulations is important to ensuring that we remain above reproach as professionals. Full Disclosure: We will always fully describe the method of our compensation and identify potential conflicts of interest to our clients. Professionalism: We will conduct ourselves in a way that would be a credit to our profession. This includes, but is not limited to, integrity, honest treatment of clients, and treating everyone with respect. Adopted February 12, 2010 Item 12 – Brokerage Practices Client assets are held in an institutional brokerage account with an independent custodian such as Charles Schwab & Co. (Schwab) or Fidelity. Most of our clients have their primary accounts held at Schwab. CAVU will only use custodians with well-known national reputations, and who are members of the Securities Investor Protection Corporation (SIPC), and the New York Stock Exchange. Annually, CAVU reviews the custodial landscape to assess the attractiveness of each provider’s services and cost structure. We review execution quality, commission rates, financial stability, and the range of services provided by custodians. CAVU has continued with Schwab as our primary custodian due to their competitive cost structure, their customer service, and their well-regarded reputation in the markets we serve. The independent custodians normally charge commissions on the purchase and sale of securities that CAVU buys and sells. These fees, which normally range between $0 and $25 per trade, are also charged for the purchase and redemption of no-load mutual funds. Substantially all mutual fund trades initiated by CAVU are currently charged a $25 trading fee by Schwab. All transaction costs are paid by the client. Neither CAVU nor its principals share in any fees charged by custodians. CAVU places all trades through custodian broker/dealer firms where the investments are held. As a result, we do not act as a principal or an agent in any of the trades that we initiate. Trade Aggregation (block trading). When rebalancing client portfolios and/or tax-loss harvesting, we attempt to trade our positions via the FIXX system. This allows us to utilize block trading, where all clients receive the same price for transactions in the same security. Block trading negates the problem of clients receiving different prices for similar trades that are executed at almost the same time. 12 Once a new client’s assets are transferred and invested in their own accounts, little trading takes place. On an ongoing basis our primary trading activity is related to occasional portfolio rebalancing or transactions to raise cash for distribution to the client. As a result of our investment process, we believe client trading costs are de minimis to investment performance. On a periodic and systematic basis, CAVU reviews its brokerage relationship with Schwab (and any other brokers utilized to execute trades) to ensure that it is fulfilling its fiduciary duty to seek best execution on transactions. We have found Schwab’s trading costs to consistently be in the same range with the other large custodians (primarily Fidelity). However, since we require our clients to have custodial accounts at Charles Schwab or Fidelity, there is a possibility that the transaction fees a client pays to these custodians would be higher than if the client were to choose a different custodian. CAVU’s custodians and several of the mutual fund firms that we use provide proprietary and third-party information that is not otherwise available to individual investors. These services are provided to CAVU (and other RIA and institutional advisors) in the normal course of business. There is no extra charge to CAVU or its clients for these services and they are not dependent on CAVU's level of business with the service provider. CAVU does not maintain any “soft dollar” arrangements. CAVU has no affiliation with its custodians or other service providers. CAVU uses these services for client accounts but receives no compensation, either directly or indirectly. Item 13 – Review of Accounts Client accounts are reviewed on a periodic basis: 1. Monthly portfolio review. Performed by a principal of CAVU. This review is intended to highlight asset class allocations within the portfolios. Market movements may have caused those allocations to drift when compared to the client's target allocation, which may then require buy and sell transactions to rebalance the allocations. 2. Annual review. Each account is subject to a thorough and formal review by a principal of CAVU. Performance of each asset class is reviewed along with the overall account asset class allocation, and the tax impact of any changes. Each of these issues is reviewed and discussed with the client. The strategic financial plan, if applicable, is also reviewed with the client at this time. Formal communication with CAVU clients comes from both CAVU and the custodian where the client has their accounts. The following are the formal communication methods: 1. Monthly statement. Initiated by the custodian (Schwab, etc.) This statement, generated for each account, shows all activity in the account over the previous month, along with the account balances. 13 2. Quarterly review. Initiated by CAVU. This report provides the client with a snapshot of their portfolio returns, the quarterly fee, and perhaps a letter from CAVU. 3. Annual review. Prepared by CAVU. Describes in detail the performance of the portfolio and the various asset classes that comprise the portfolio. Comparisons are made to appropriate benchmarks. Item 14 – Client Referrals and Other Compensation CAVU does not compensate anyone for providing referrals to our firm. From time-to-time we may provide referrals to our clients regarding potential services from accountants, attorneys and insurance agents. We do not receive any compensation for referrals that we make. Item 15 – Custody Clients receive monthly statements from the custodial firm that holds their investment assets. CAVU urges clients to carefully review such statements (we call these custodial statements the clients’ “financial bible”) and compare the official custodial records to the account statements that CAVU provides each quarter. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. When opening custodial accounts, clients authorize CAVU to withdraw its management fees from the client accounts. CAVU does this on a quarterly basis. This process is consistent with industry practice. By withdrawing fees from client accounts our regulators deem CAVU to have limited (“constructive”) custody. We send a statement to the client’s custodian and the custodian then debits the account and sends the money to CAVU. The custodian, however, does not review or calculate the fee. It is important for CAVU’s clients to review their quarterly CAVU statement and the monthly custodian account statements to ensure that the management fee was calculated and assessed correctly. Item 16 – Separately Managed Account As a result of new technological trends in the industry and the advent of commission-free trading, CAVU has embraced the use of Separately Managed Accounts (SMA). These accounts, sub-managed by a third party, provide clients with an enhanced ability to benefit from tax-loss harvesting while also providing the opportunity to benefit from substantial gains that can occur within any well diversified portfolio. All SMA accounts will be custodied by Schwab or Fidelity and the client will always have immediate access to their funds. The sub-manager will provide the trading and tax loss harvesting activities. CAVU will oversee the entire account and will continue to manage the client’s entire portfolio using a holistic approach. SMA firms charge a fee (usually 20-30 basis points per year) for their services. These fees are roughly 14 equivalent, or slightly higher, than the operating fees charged by the ETF provider, which are the securities that an SMA account would replace. We view the tax-deferral benefits that SMA accounts can offer to be significantly greater than the small incremental cost the client might experience by moving from an ETF portfolio to a SMA. Item 17 – Investment Discretion CAVU usually receives discretionary investment authority from the client at the outset of an advisory relationship. This discretionary authority allows CAVU to buy and sell securities in client accounts. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the specific client account. Investment guidelines are determined by the client’s Investment Policy Statement (IPS) which is crafted with the client’s input and contains their written authorization. Occasionally an IPS will contain specific language restricting CAVU from investing in certain securities or types of securities. Item 18 – Voting Client Securities As a matter of firm policy and practice CAVU does not accept authority to vote proxies and we do not provide proxy voting services. Clients retain the responsibility for receiving and voting proxies for any, and all, securities maintained in their portfolios. However, clients may contact CAVU to ask for advice regarding the clients’ voting of proxies. Item 19 – Financial Information Registered investment Advisors are required in this Item to provide you with certain financial information or disclosures about CAVU’s financial condition. CAVU has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients. Neither CAVU nor its principals have been the subject of a bankruptcy proceeding. Item 20 – Requirements for State-Registered Advisors – Employee Details Our People and our advisory standards To provide professional services, CAVU requires a college degree and another professional designation, typically either CFA or CFP® designation. In some cases, particularly for our tax specialists, a Certified Public Accountant (CPA) license is required. The following people are responsible for determining the general investment advice given to clients: 15 David George Sylvester, CFA, CFP® Year of Birth: 1955 Education and Professional Designations: • University of Richmond, Richmond, VA BS in 1977 • Chartered Financial Analyst, 19851 • Certified Financial Planner®, 20092 Business Background preceding five years: Mr. Sylvester was associated with CAVU Wealth Advisors, the predecessor firm to CAVU Wealth Advisors, LLC from 2009 until May 1, 2023. For the past three years he as worked for Blue Trust as a private wealth advisor. Regulatory disciplinary action: There has never been any disciplinary action associated with Mr.Sylvester Other Business Activities: Mr. Sylvester is not involved in any other business activities. Additional Compensation: Mr. Sylvester’s sole compensation is as an owner of CAVU. Supervision: Mr. Sylvester is self-supervised. Requirements for State-Registered Advisers: No items to disclose. * * * * * 1 CFA certification requires an undergraduate education of a bachelor’s degree and four years of professional work experience or a combination of professional work experience and education that totals four years. 2 CFP® certification requires completed university level coursework through a program registered with CFP Board and bachelor’s degree or higher from an accredited university and a passing score on the CFP exam. In addition, two to three years of work experience is also required before earning the CFP designation. Hilary S. Disher Year of Birth: 1983 Education and Professional Designations: • University of Richmond, Richmond VA - BS, 2005 • Certified Public Accountant, 20073 • • Certified Financial Planner®, 20184 Business Background preceding five years: Blue Trust, Walnut Creek, CA 2023 – 2026 CAVU Wealth Advisors, Walnut Creek, CA 2014 - 2023 Regulatory disciplinary action: There has never been any disciplinary action associated with Ms. Disher. Other Business Activities: Ms. Disher is not involved in any other business activities. Additional Compensation: Ms. Disher's sole compensation is as an owner of CAVU. Supervision: Ms. Disher is supervised by Mr. Sylvester. Requirements for State-Registered Advisers: No items to disclose. No CAVU employee is compensated for advisory services with performance-based fees. Additionally, no CAVU employee has a relationship or financial arrangement with any issuer of securities. 3 CPA certification requires a bachelor’s degree, with a minimum of 150 semester hours of formal education 16 and passing score on the Uniform CPA exam. 4 See Footnote 2 above. 17

Frequently Asked Questions