CORDA INVESTMENT MANAGEMENT, LLC

Form ADV Part 2A Disclosure Brochure CORDA Investment Management, LLC 8955 Katy Freeway, Suite 200 Houston, TX 77024 Phone: (713) 439-0665 (713) 465-1308 Fax: Websites: www.cordamanagement.com August 2025 Item 1 Cover Page This brochure provides information about the qualifications and business practices of CORDA Investment Management, LLC. If you have any questions about the contents of this brochure, please contact us at (713) 439-0665. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about CORDA Investment Management, LLC is also available on the SEC's website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for CORDA Investment Management, LLC is 108046. CORDA Investment Management, LLC is a Registered Investment Adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Item 2 Summary of Material Changes Form ADV Part 2A requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since the last filing of this Firm Brochure, dated February 2025, we have the following material changes to report. Item 4: Advisory Business: CORDA acts as an ERISA 3(38) Investment Manager in which it has discretionary management and control of retirement plan assets. Please see Item 4 in the following pages for more information regarding our status as a 3(38) Investment Manager. Estate Planning Services Through an unrelated law firm, HK Legacy Law PLCC (“HKLL”) CORDA clients can access attorney led estate planning document preparation and other legal services. Although we recommend clients use the services of HKLL, clients are not obligated or required to use such services or HKLL, and Corda is not paid for the referral to HKLL. The services of CORDA and HKLL are separate and distinct from one another, each with a separate agreement for services rendered. There is no common ownership between CORDA and HKLL. Item 5: Fees and Compensation: Our fee for Portfolio Management Services is based on a percentage of your assets we manage and is set forth in the following fee schedule: Asset Value Annual Fee 1.00% From $0 to $2,000,000 From $2,000,001 to $5,000,000 0.85% From $5,000,001 to $10,000,000 0.50% 0.25% Over $10,000,001 Our fee for preparing simple individual tax returns is $1,250. 2  Item 3 Table Of Contents Item 1 Cover Page .................................................................................................................................... 1 Item 2 Summary of Material Changes ....................................................................................................... 2 Item 3 Table Of Contents .......................................................................................................................... 3 Item 4 Advisory Business .......................................................................................................................... 4 Item 5 Fees and Compensation................................................................................................................. 7 Item 6 Performance-Based Fees and Side-By-Side Management ............................................................. 8 Item 7 Types of Clients.............................................................................................................................. 9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 9 Item 10 Other Financial Industry Activities and Affiliations ....................................................................... 11 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................. 11 Item 12 Brokerage Practices ................................................................................................................... 12 Item 13 Review of Accounts .................................................................................................................... 13 Item 14 Client Referrals and Other Compensation................................................................................... 14 Item 15 Custody ...................................................................................................................................... 15 Item 16 Investment Discretion ................................................................................................................. 15 Item 17 Voting Client Securities .............................................................................................................. 16 Item 18 Financial Information .................................................................................................................. 16 Item 19 Requirements for State Registered Advisers .............................................................................. 16 Item 20 Additional Information ................................................................................................................. 16 3  Item 4 Advisory Business Description of Services and Fees CORDA Investment Management, LLC is a registered investment adviser based in Houston, Texas. We are organized as a limited liability company under the laws of the State of Texas. We have been providing investment advisory services since 1999. CORDA is primarily owned by Bonner C. Barnes and other family members and Keith Roberts is Chief Compliance Officer. Currently, we offer Portfolio Management Services and Pension Consulting. These services are custom-made for each of our clients. The following paragraphs describe our services and fees. Refer to the descriptions of the advisory services below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "we", "our" and "us" refer to CORDA Investment Management, LLC and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and all individuals providing investment advice on behalf of our firm. Portfolio Management Services We offer discretionary portfolio management services to our clients and prospective clients. Our investment advice is tailored to meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will meet with you to determine your investment objectives, risk tolerance, and other relevant information (the "suitability information") at the beginning of our advisory relationship. We will use the suitability information we gather from our initial meetings and discussions to develop a strategy that enables our firm to give you continuous and focused investment advice and/or to make investments on your behalf. As part of our portfolio management services, we will customize an investment portfolio for you in accordance with your risk tolerance and investing objectives. Once we construct an investment portfolio for you, we will monitor your portfolio's performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and in your financial circumstances. If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities, and the amount of securities, to be purchased or sold for your account without your approval prior to each transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm or trading authorization forms. You may limit our discretionary authority (for example, limiting the types of securities that can be purchased or sold for your account) by providing our firm with your restrictions and guidelines in writing. Should you exercise the right to limit our discretionary authority, these securities may be held as non-discretionary assets. Part of our portfolio management service includes financial planning services which may range from broad-based financial planning to consultative or single subject planning. This service is provided at no additional cost to portfolio management clients. Pension Consulting Services We offer pension consulting services to employee benefit plans and their fiduciaries based upon the needs of the plan and the services requested by the plan sponsor or named fiduciary. In general, these services may include an existing plan review and analysis, plan-level advice regarding fund selection and investment options, education services to plan participants, investment performance monitoring, 4  and/or ongoing consulting. These pension consulting services will generally be non-discretionary and advisory in nature. The ultimate decision to act on behalf of the plan shall remain with the plan sponsor or other named fiduciary. • Diversification • Asset allocation • Risk tolerance • Time horizon We may also provide additional types of pension consulting services to plans on an individually negotiated basis. All services, whether discussed above or customized for the plan based upon requirements from the plan fiduciaries (which may include additional plan-level or participant-level services) shall be detailed in a written agreement and be consistent with the parameters set forth in the plan documents. Either party to the pension consulting agreement may terminate the agreement upon 5 days' written notice to the other party. The pension consulting fees will be prorated for the quarter in which the termination notice is given and any unearned fees will be refunded to the client. Tax Preparation Services CORDA offers assistance in the preparation and filing of individual federal and state income tax returns. Clients who desire tax preparation services may utilize our team of tax professionals and CPAs but are not obligated to do so. Estate Planning Services Through an unrelated law firm, HK Legacy Law PLCC (“HKLL”) CORDA clients can access attorney led estate planning document preparation and other legal services. Although we recommend clients use the services of HKLL, clients are not obligated or required to use such services or HKLL, and Corda is not paid for the referral to HKLL. The services of CORDA and HKLL are separate and distinct from one another, each with a separate agreement for services rendered. There is no common ownership between CORDA and HKLL. ERISA Plan Services: 3(38) Investment Manager CORDA acts as an ERISA 3(38) Investment Manager in which it has discretionary management and control of retirement plan assets. 1. Fiduciary Services include: • Advisor has discretionary authority and will make the final decision regarding the initial selection, retention, removal and addition of investment options in accordance with the Plan’s investment policies and objectives. • Assist the Plan Sponsor with the selection of a broad range of investment options consistent with ERISA Section 404(c) and the regulations thereunder. • Assist the Plan Sponsor in the development of an investment policy statement. The IPS establishes the investment policies and objectives for the Plan. • Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative for participants who are automatically enrolled in the Plan or who have otherwise failed to make investment elections. The Plan Sponsor retains the sole responsibility to provide all notices to the Plan participants required under ERISA Section 404(c) (5). • Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain, remove or replace investment options. 5  • Meet with Plan Sponsor on a periodic basis to discuss the reports and the investment recommendations. 2. Non-fiduciary Services include: • Assist in the education of Plan participants about general investment information and the investment alternatives available to them under the Plan. The Advisor’s assistance in education of the Plan participants shall be consistent with and within the scope of the Department of Labor’s definition of investment education (Department of Labor Interpretive Bulletin 96-1). As such, the Advisor is not providing fiduciary advice as • defined by ERISA to the Plan participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. • Assist in the group enrollment meetings designed to increase retirement plan participation among the employees and investment and financial understanding by the employees. CORDA may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Plan Sponsor. 3. CORDA has no responsibility to provide services related to the following types of assets (“Excluded Assets”): a. Employer securities; b. Real estate (except for real estate funds or publicly traded REITs); c. Stock brokerage accounts or mutual fund windows; d. Participant loans; e. Non-publicly traded partnership interests; f. Other non-publicly traded securities or property (other than collective trusts and similar vehicles); or g. Other hard-to-value or illiquid securities or property. Types of Investments We recommend all types of securities, and we do not necessarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Additionally, we may advise you on any type of investment that we deem appropriate based on your stated goals and objectives. We may also provide advice on any type of investment held in your portfolio at the inception of our advisory relationship. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor ("DOL") Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02") where applicable, we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; 6  • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from an ERISA account to an account that we manage or provide investment advice to, because the assets increase our Assets Under Management and, in turn, our advisory fees. In contrast, we receive less, or no, compensation if assets remain in the current plan or are rolled over to another Company's plan in which you may participate. Assets Under Management As of December 31, 2024, we provide continuous management services for $1,639,609,960 in client assets on a discretionary basis, and $87,028,669 in client assets on a non-discretionary basis for a total of $1,726,638,629 in regulatory assets under management. Item 5 Fees and Compensation Our fee for Portfolio Management Services is based on a percentage of your assets we manage and is set forth in the following fee schedule: Annual Fee Asset Value 1.00% From $0 to $2,000,000 From $2,000,001 to $5,000,000 0.85% From $5,000,001 to $10,000,000 0.50% 0.25% Over $10,000,001 Not all of our clients are on the same fee schedule, and the fee schedule and assets we bill on have changed over the life of the firm. We reserve the right to negotiate any fees based on numerous factors. Therefore, some clients pay more or less than others for similar services. Our annual fees are billed and payable quarterly in advance based on the value of your account on the last day of the previous quarter. If the portfolio management agreement is executed at any time other than the first day of the calendar quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending on individual client circumstances. In general, we charge a minimum annual fee of $5,000 to open and maintain an advisory account. In our sole discretion, we may waive or lower this minimum fee in accordance with a lower minimum account size. We may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts to meet the stated minimum as well as to meet a lower fee threshold.. For example, we may combine account values for you and your minor children, joint accounts with your spouse, and other types of related accounts. Combining account values may increase the asset total, which may result in your paying a reduced advisory fee based on the available breakpoints in our fee schedule stated above. Additionally, we offer our Next Generation ("Next Gen") program to children of existing clients. The program includes features such as No Account Minimum investment requirements, no fee on the first $100,000 invested for the first year, and the establishment of a systematic deposit to the account. If there is a change to a client's fee schedule, we will provide a formal written notice to the client. 7  An additional component of our service includes financial planning services which may range from broad-based financial planning to consultative or single subject planning. This service is provided at no additional cost to portfolio management clients. We will upload a copy of an invoice to our password protected website and/or send a paper invoice for the payment of our advisory fees and we will deduct our fee directly from your account through the qualified custodian holding your funds and securities. With regard to direct debiting, we will deduct our advisory fee only when you have given our firm written authorization permitting the fees to be paid directly from your account. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account. Although we will receive a duplicate copy of your account statements, we encourage you to review all statements received from the qualified custodian for accuracy. We typically debit management fees 14 days after they have been posted to the website or sent via mail. We encourage you to reconcile our invoices with the statement(s) you receive from the qualified custodian. If you find any inconsistent information between our invoice and the statement(s) you receive from the qualified custodian, please call our main office number located on the cover page of this brochure. You may terminate the portfolio management agreement upon five days' written notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the portfolio management agreement, which means you will incur advisory fees only in proportion to the number of days in the quarter for which you are a client. Our fee for Pension Consulting Services is 0.50% of the Plan assets with a $1,000,000 account minimum. If you choose to engage CORDA for tax preparation services, you will typically enter into a separate agreement and pay a separate fee in addition to the fees paid to CORDA for investment advisory and other services. Our fee for preparing simple individual tax returns is $1,250. However, additional fees will apply for the preparation of more complex schedules and forms as agreed upon in advance of the engagement. An hourly rate of $250 is billed separately for more complex matters or in the event of an audit for which we are offering additional assistance. Additional Fees and Expenses As part of our investment advisory services provided to you, we may invest, or recommend that you invest, in mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds or exchange traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include a management fee and other fund expenses. You will also incur transaction charges and/or brokerage fees when purchasing or selling securities. These charges and fees are typically imposed by the broker-dealer or custodian through whom your account transactions are executed. We do not share in any portion of the brokerage fees/transaction charges imposed by the broker-dealer or custodian. To fully understand the total cost you will incur, you should review all the fees charged by mutual funds, exchange traded funds, our firm, and others. For information on our brokerage practices, please refer to the Brokerage Practices section of this Brochure. Item 6 Performance-Based Fees and Side-By-Side Management We do not accept performance-based fees or participate in side-by-side management. Performance- based fees are fees that are based on a share of capital gains or capital appreciation of a client's account. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance- 8  based fees. Our fees are calculated as described in the Fees and Compensation section above and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your advisory account. Item 7 Types of Clients We offer investment advisory services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines may affect the composition of your portfolio. Methods of Analysis We will use one or more of the following investment strategies when formulating investment advice: Charting Analysis – involves the gathering and processing of price and volume pattern information for a particular security, sector, broad index or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data is used to detect departures from expected performance and diversification and predict future price movements and trends. • Risk: Our charting analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Technical Analysis – involves studying past price patterns, trends, and interrelationships in the financial markets to assess risk-adjusted performance and predict the direction of both the overall market and specific securities. • Risk: The risk of market timing based on technical analysis is that our analysis may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Fundamental Analysis – involves analyzing individual companies and their industry groups, such as a company's financial statements, details regarding the company's product line, the experience and expertise of the company's management, and the outlook for the company and its industry. The resulting data is used to measure the true value of the company's stock compared to the current market value. • Risk: The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock's value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. We will use one or more of the following methods of analysis when providing investment advice to you: Investment Strategies Long-Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. 9  • Risk: Using a long-term purchase strategy generally assumes the financial markets will go up in the long termwhich may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall financial markets advance. Purchasing investments long-term may create an opportunity cost - "locking-up" assets that may be better utilized in the short-term in other investments. Short-Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities' short- term price fluctuations. • Risk: Using a short-term purchase strategy generally assumes that we can predict how financial markets will perform in the short-term, which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long-term trading. There are many factors that can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of times. We provide an options strategy to clients holding a large and concentrated position in an equity holding. Our strategy allows for the unwinding of this position and the creation of a more diversified portfolio by purchasing or selling puts/calls and hedging the position as needed. The options strategy can be structured to enhance the income off the investment and/or reduce the downside exposure. In addition, we can also build a cash secured put portfolio to enhance a current income stream and to offer investors a way to purchase shares of equities at prices below the current value should we get put the security. Tax Considerations Our strategies and investments may have unique and significant tax implications. However, unless we specifically agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets. Regardless of your account size or any other factors, we strongly recommend that you consult with a tax professional regarding the investing of your assets. Moreover, as a result of revised IRS regulations, custodians and broker-dealers will begin reporting the cost basis of equities acquired in client accounts on or after January 1, 2011. Your custodian will default to the highest cost accounting method for calculating the cost basis of your investments. You are responsible for contacting your tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another accounting method is more advantageous, please provide written notice to our firm immediately and we will alert your account custodian of your individually selected accounting method. Please note that decisions about cost basis accounting methods will need to be made before trades are settled, as the cost basis method cannot be changed after settlement. Risk of Loss Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives will be met. Past performance is in no way an indication of future performance. Recommendation of Particular Types of Securities As disclosed under the Advisory Business section in this brochure, we recommend all types of securities, and we do not necessarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very 10  general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with that investment. Cybersecurity Risk CORDA Management and its service providers may be subject to operational and information security risks resulting from cyberattacks. Cyberattacks include, among other behaviors, stealing or corrupting data maintained online or digitally, denial of service attacks on websites, the unauthorized release of confidential information or various other forms of cybersecurity breaches. Cybersecurity attacks affecting CORDA and its service providers may adversely impact Clients. For instance, cyberattacks may interfere with the processing of transactions, cause the release of private information about Clients, impede trading, subject CORDA to regulatory fines or financial losses, and cause reputational damage. Similar types of cybersecurity risks are also present for issuers of securities in which Clients accounts may invest in, qualified custodians, governmental and other regulatory authorities, exchange and other financial market operators, or other financial institutions. Cybersecurity incidents that could ultimately cause them to incur losses, including for example: financial losses, cost and reputational damages, and loss from damage or interruption of systems. Although CORDA has established its systems to reduce the risk of these incidents occurring, there is no guarantee that these efforts will always be successful, especially considering that CORDA does not directly control the cybersecurity measures and policies employed by third-party service providers or those of its clients. Item 9 Disciplinary Information We are required to disclose the facts of any legal or disciplinary events that are material to a client's evaluation of our advisory business or the integrity of our management. We do not have any required disclosures under this item. Item 10 Other Financial Industry Activities and Affiliations We have not provided information on other financial industry activities and affiliations because we do not have any relationship or arrangement that is material to our advisory business or to our clients with any of the types of entities listed below. 1. broker-dealer, municipal securities dealer, or government securities dealer or broker 2. investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or "hedge fund," and offshore fund) 3. other investment adviser or financial planner 4. futures commission merchant, commodity pool operator, or commodity trading advisor 5. banking or thrift institution 6. accountant or accounting firm 7. lawyer or law firm 8. insurance company or agency 9. pension consultant 10. real estate broker or dealer 11. sponsor or syndicator of limited partnerships Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to protect your interests at all times and to demonstrate our commitment to our fiduciary duties 11  of honesty, good faith, and fair dealing with you. All of our Associated Persons are expected to adhere strictly to these guidelines. Persons associated with our firm are required to report any violations of our Code of Ethics. Additionally, we maintain and enforce written policies reasonably designed to prevent the misuse or dissemination of material, non-public information about you or your account holdings by persons associated with our firm. Our Code of Ethics is available to you upon request. You may obtain a copy of our Code of Ethics by contacting Keith Roberts at (713) 439-0665. Participation or Interest in Client Transactions Neither our firm nor any of our Associated Persons has any material financial interest in client transactions beyond the provision of investment advisory services as disclosed in this brochure. We do not engage in principal trading (i.e., the practice of selling to advisory clients from a firm’s inventory or buying from advisory clients into a firm’s inventory). In addition, we do not recommend any securities to advisory clients in which it has some proprietary or ownership interest although its personnel sometimes own the same securities recommended to clients. Personal Trading Practices Our firm or persons associated with our firm may buy or sell securities for you at the same time we or persons associated with our firm buy or sell such securities for our own account. We may also combine our orders to purchase securities with your orders to purchase securities ("block trading"). Please refer to the Brokerage Practices section in this Brochure for information on our block trading practices. A conflict of interest exists in such cases because we have the ability to trade ahead of you and potentially receive more favorable prices than you will receive. To mitigate this conflict of interest, it is our policy that neither our Associated Persons nor we shall have priority over your account in the purchase or sale of securities. Item 12 Brokerage Practices We generally recommend that securities be purchased through the facilities of Charles Schwab & Co, Inc ("Schwab"). We participate in the Schwab Advisor Network and this program is discussed more fully in Item 14 Client Referrals and Other Compensation). Charles Schwab is an independent and unaffiliated SEC-registered broker-dealer and FINRA member. Schwab offers to independent investment advisers, services that include custody of securities, trade execution, clearance and settlement of transactions. We receive some benefits from Schwab through our participation in this program. In addition to the benefits disclosed below, we may receive benefits such as assistance with conferences and educational meetings from product sponsors. Refer to Item 14 Client Referrals and Other Compensation for additional disclosures on this topic. In selecting a broker dealer, we will endeavor to select those brokers or dealers that will provide the best services at the lowest commission rates possible. The reasonableness of commissions is based on several factors, including the broker's ability to provide professional services, competitive commission rates, volume discounts, execution price negotiations, and other services. In recognition of the value of research services and additional brokerage products and services Schwab provides, you may pay higher commissions and/or trading costs than those that may be available elsewhere. Refer to Item 14 Client Referrals and Other Compensation for additional disclosures on this topic. Directed Brokerage Subject to our participation in programs sponsored by various broker dealers, we routinely recommend that you direct our firm to execute transactions through Schwab. As such, we may be unable to achieve the most favorable execution of your transactions, and you may pay higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of 12  services. Not all advisers require their clients to direct brokerage. Refer to Item 14 Client Referrals and Other Compensation for additional disclosures on this topic. Block Trades We may combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as "block trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion regarding factual and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. Advisory Board Member Bonner Barnes, Managing Member of CORDA Investment Management, LLC ("CORDA") serves on the Schwab Advisor Services Advisory Board (the "Advisory Board"). As described under this Item, CORDA may recommend that clients establish brokerage accounts with Charles Schwab & Co., Inc. ("Schwab") and/or its affiliates (e.g. TD Ameritrade Institutional) to maintain custody of the clients' assets and effect trades for their accounts. The Advisory Board consists of representatives of independent investment advisory firms who have been invited by Schwab management to participate in meetings and discussions of Schwab Advisor Services' services for independent investment advisory firms and their clients. Generally, Board members serve for two-year terms. Mr. Barnes's term ends in 2025. Advisory Board members enter into nondisclosure agreements with Schwab under which they agree not to disclose confidential information shared with them. This information generally does not include material nonpublic information about the Charles Schwab Corporation, whose common stock is listed for trading on the New York Stock Exchange (symbol SCHW). The Advisory Board meets in person or virtually approximately twice per year and has periodic conference calls scheduled as needed. Advisory Board members are not compensated by Schwab for their service, but Schwab does pay for or reimburse Advisory Board members' travel, lodging, meals and other incidental expenses incurred in attending Advisory Board meetings. Item 13 Review of Accounts Bonner Barnes, managing member of CORDA, and John Schloegel, investment adviser representative, will monitor client accounts on an ongoing basis. These reviews are designed to ensure that the advisory services provided to you are consistent with your current investment needs and objectives. Additional reviews may be conducted based on various circumstances, including, but not limited to: • contributions and withdrawals; • year-end tax planning; • market moving events; • security specific events; and/or, • changes in your risk/return objectives. We will provide you with additional or regular written reports in conjunction with account reviews. Reports we provide to you will contain relevant account and/or market-related information such as an inventory of account holdings and account performance, etc. In addition, you will receive trade confirmations and monthly or quarterly statements from your account custodian(s). You should compare our statements with the statements from your account custodian(s) to reconcile the information reflected on each statement. 13  Item 14 Client Referrals and Other Compensation As disclosed under Item 12 above, CORDA participates in Charles Schwab's institutional customer program and CORDA may recommend them to clients for custody and brokerage services. There is no direct link between CORDA's participation in any program and the investment advice it gives to its Clients, although CORDA receives economic benefits through its participation in the programs that are typically not available to Charles Schwab retail investors. These benefits include the following products and services (provided without cost or at a discount): receipt of duplicate Client statements and confirmations; research related products and tools; consulting services; access to a trading desk serving CORDA participants; access to block trading (which provides the ability to aggregate securities transactions for execution and then allocate the appropriate shares to Client accounts); the ability to have advisory fees deducted directly from Client accounts; access to an electronic communications networks for Client order entry and account information; access to mutual funds with no transaction fees and to certain institutional money managers; and discounts on compliance, marketing, research, technology, and practice management products or services provided to CORDA by third party vendors. Schwab may also have paid for business consulting and professional services received by CORDA's related persons. Some of the products and services made available by Schwab through the program may benefit CORDA but may not benefit its Client accounts. These products or services may assist CORDA in managing and administering Client accounts, including accounts not maintained at either custodian. Other services made available by Schwab are intended to help CORDA manage and further develop its business enterprise. The benefits received by CORDA or its personnel through participation in this program does not depend on the amount of brokerage transactions directed to Schwab. As part of its fiduciary duties to clients, CORDA endeavors at all times to put the interests of its clients first. Clients should be aware, however, that the receipt of economic benefits by CORDA or its related persons in and of itself creates a potential conflict of interest and may indirectly influence CORDA's choice of Charles Schwab for custody and brokerage services. CORDA (Advisor) receives client referrals from Charles Schwab & Co., Inc. ("Schwab") through CORDA's participation in Schwab Advisor Network® ("the Service"). The Service is designed to help investors find an independent investment advisor. Schwab is a broker-dealer independent of and unaffiliated with CORDA. Schwab does not supervise Advisor and has no responsibility for CORDA's management of clients' portfolios or Advisor's other advice or services. CORDA pays Schwab fees to receive client referrals through the Service. CORDA's participation in the Service may raise potential conflicts of interest described below. CORDA pays Schwab a Participation Fee on all referred clients' accounts that are maintained in custody at Schwab and a Non-Schwab Custody Fee on all accounts that are maintained at, or transferred to, another custodian. The Participation Fee paid by Advisor is a percentage of the fees the client owes to Advisor or a percentage of the value of the assets in the client's account, subject to a minimum Participation Fee. CORDA pays Schwab the Participation Fee for so long as the referred client's account remains in custody at Schwab. The Participation Fee is billed to CORDA quarterly and may be increased, decreased or waived by Schwab from time to time. The Participation Fee is paid by CORDA and not by the client. CORDA has agreed not to charge clients referred through the Service fees or costs greater than the fees or costs CORDA charges clients with similar portfolios who were not referred through the Service. CORDA generally pays Schwab a Non-Schwab Custody Fee if custody of a referred client's account is not maintained by, or assets in the account are transferred from Schwab. This Fee does not apply if the client was solely responsible for the decision not to maintain custody at Schwab. The Non-Schwab Custody Fee is a one-time payment equal to a percentage of the assets placed with a custodian other than Schwab. The Non-Schwab Custody Fee is higher than the Participation Fees Advisor generally would pay in a single year. Thus, CORDA will have an incentive to recommend that client accounts be held in custody at Schwab. 14  Our participation in the Program does not reduce or eliminate our fiduciary duty to obtain best execution when selecting brokers to execute securities transactions on behalf of clients. Additionally, any fees Schwab charges our firm for participating in the Program will decrease the amount of money we make when offering investment advice to you. Therefore, while we have a fiduciary duty to provide services that are in your best interest, we may have an incentive to recommend advisory programs and services that may be less costly for us, but not as suitable to your needs. Our participation in the Program does not diminish our fiduciary duty to recommend and provide advisory services to you that are not only suitable, but that are also in your best interest. Item 15 Custody We do not take custody of your funds or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. We may have the authority to deduct our advisory fees from your account, but only if you previously consented to such deduction in writing. Otherwise, we will send you an invoice for the payment of our advisory fees. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. When we have the ability to directly debit our fee from your account, the account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account(s) each billing period. You should carefully review account statements for accuracy. We will also provide statements to you reflecting the amount of advisory fee deducted from your account. Wire Transfer and/or Standing Letters of Authorization Our firm, or persons associated with our firm, may effect wire transfers from client accounts to one or more third parties designated, in writing, by the client as long as the client has provided the qualified custodian with written authorization that allows us to do so. Such written authorization is known as a Standing Letter of Authorization. However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by reason of having custody, as long as we meet the following criteria: 1. You provide a written, signed instruction to the qualified custodian that includes the third party's name and address or account number at a custodian; 2. You authorize us in writing to direct transfers to the third party either on a specified schedule or from time to time; 3. Your qualified custodian verifies your authorization (e.g., signature review) and provides a transfer of funds notice to you promptly after each transfer; 4. You can terminate or change the instruction; 5. We have no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party; 6. We maintain records showing that the third party is not a related party to us nor located at the same address as us; and 7. Your qualified custodian sends you, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16 Investment Discretion You may grant our firm discretion over the selection and amount of securities to be purchased or sold for your account(s) without obtaining your consent or approval prior to each transaction. Before we can buy or sell securities on your behalf, you must first sign our Investment Agreement. You may specify investment objectives, guidelines, and/or impose certain conditions or investment parameters for your account(s). For example, you may specify that the investment in any particular stock or industry should not exceed specified percentages of the value of the portfolio and/or 15  restrictions or prohibitions of transactions in the securities of a specific industry or security. In such cases, these securities may be held in your account as non-discretionary assets. Please refer to the Advisory Business section in this Brochure for more information on our discretionary management services. Item 17 Voting Client Securities We will not vote proxies on behalf of your advisory accounts. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of applicable securities, you are responsible for exercising your right to vote as a shareholder. In most cases, you will receive proxy materials directly from the account custodian. However, in the event we were to receive any written or electronic proxy materials, we would forward them directly to you by mail, unless you have authorized our firm to contact you by electronic mail, in which case, we would forward any electronic solicitation to vote proxies. Item 18 Financial Information We are not required to provide a balance sheet or other financial information to our clients because we do not require the prepayment of fees in excess of $1,200 and six months or more in advance; we do not take custody of client funds or securities; and, we do not have a financial condition that is reasonably likely to impair our ability to meet our commitments to you. Moreover, we have never been the subject of a bankruptcy petition. Item 19 Requirements for State Registered Advisers We are a federally registered investment adviser; therefore, we are not required to respond to this item. Item 20 Additional Information Your Privacy We view protecting your private information as a top priority. Pursuant to applicable privacy requirements, we have instituted policies and procedures to ensure that we keep your personal information private and secure. We do not disclose any nonpublic personal information about you to any nonaffiliated third parties, except as permitted by law. In the course of servicing your account, we may share some information with our service providers, such as transfer agents, custodians, broker-dealers, accountants, advisers, consultants, and attorneys. We restrict internal access to nonpublic personal information about you to employees who need that information in order to provide products or services to you. We maintain physical and procedural safeguards that comply with regulatory standards to guard your nonpublic personal information and to ensure our integrity and confidentiality. We will not sell information about you or your accounts to anyone. We do not share your information unless it is required to process a transaction, at your request, or required by law. You will receive a copy of our privacy notice prior to or at the time you sign an advisory agreement with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual basis. Please contact Bonner Barnes or Keith Roberts at (713) 439-0665 if you have any questions regarding this policy. Trade Errors 16  In the event a trading error occurs in your account, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. In the event of a credit balance in any custodial error account on a monthly or quarterly basis, Charles Schwab reserves the right to disburse any proceeds to the charity or philanthropic organization of its choice. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. 17