CULLEN INVESTMENT GROUP

Item 1 – Cover Page Cullen Investment Group, Ltd. Disclosure Brochure March 16, 2026 This Form ADV Part 2A ("Disclosure Brochure") provides information about the qualifications and business practices of Cullen Investment Group, Ltd ("Cullen," the "Firm," "Our," "Us," or "We"). If you have any questions about the content of this Disclosure Brochure, please contact (337) 237- 8000 or email cullen@cullenonline.com. Cullen is an investment adviser registered with the Securities and Exchange Commission (the "SEC"). Registration as an investment adviser with the SEC is not intended to imply any level of skill or training. This Disclosure Brochure is designed to provide you with information about Cullen and its business practices and to assist you in determining whether or not to retain the Firm. The information in this Disclosure has not been verified by the Securities and Exchange Commission or any state securities authorities. Additional information about the Firm can be directly accessed by clicking on the hyperlink to Cullen's Disclosure Brochure. For further details, please refer to the SEC's Investment Adviser Public Disclosure website at adviserinfo.sec.gov. You may search using our unique identification number, known as the CRD number, to locate specific information. The Firm's CRD number is 18266. Cullen Investment Group, Ltd. 1404 South College Road Lafayette, Louisiana 70503 Phone: (337) 237-8000 www.cullenonline.com  Item 2 – Material Changes Cullen Investment Group has not had any material changes since its last annual updating amendment filed on January 14, 2025 and ensuing other than annual amendments filed February 24, 2025 and July 10, 2025. 2 | P a g e  Item 3 – Table of Contents Item 1 – Cover Page .......................................................................................................................................................................... 1 Item 2 – Material Changes ................................................................................................................................................................ 2 Item 4 ‒ Advisory Business ............................................................................................................................................................... 4 Item 5 ‒ Fees and Compensation ...................................................................................................................................................... 6 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 ............................................................................................ 8 Item 9 ‒ Disciplinary Information.................................................................................................................................................... 11 Item 10 ‒ Other Financial Industry Activities and Affiliations ......................................................................................................... 11 Item 11 ‒ Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................................... 12 Item 12 ‒ Brokerage Practices ......................................................................................................................................................... 13 Item 13 ‒ Review of Accounts ......................................................................................................................................................... 14 Item 14 – Client Referrals and Other Compensation ...................................................................................................................... 15 Item 15 ‒ Custody ........................................................................................................................................................................... 16 Item 16 ‒ Investment Discretion ..................................................................................................................................................... 16 Item 17 ‒ Voting Client Securities (Proxy Voting) ............................................................................................................................ 17 Item 18 ‒ Financial Information ...................................................................................................................................................... 17 3 | P a g e  Item 4 ‒ Advisory Business A. Firm Overview Cullen Investment Group, Ltd. ("Cullen," the "Firm," "We," "Our," "Us") is a fee-only independent registered investment adviser located in Lafayette, Louisiana. The Firm was organized in October 15, 1986, and have evolved through several stages of growth and development. The Firm initially registered as a broker-dealer in FINRA1 in August 1987 and later expanded its services by registering as an investment adviser with the Securities and Exchange Commission2 ("SEC") in July 2002. As of December 2024, following the voluntary termination of its broker-dealer registration, Cullen operates exclusively as an SEC-registered investment adviser. This transition has no impact on the investment advisory services provided to clients. Mr. David C. Bordes, President and Founder, and Mr. Stephen L. Nickel, Vice President, are the principal owners of the Firm. Mr. Bordes brings over 45 years of investment experience to the Firm. Mr. Nickel joined Cullen in 2003 and became a principal owner in 2007. Mr. Nickel brings over 20 years of investment experience to the Firm. B. Description of Our Services We provide personalized investment advisory services to meet our clients’ unique investment needs. We offer three distinct services: Investment Management Services, Cash Management Services, and 401(k) Plan Consulting Services. Our Investment Management Services deliver comprehensive portfolio management. This service is designed for individuals, high-net worth individuals, trusts, estates, charitable organizations, and other business entities seeking professional portfolio management. These services are offered on a discretionary basis. This service involves ongoing monitoring and portfolio management to deliver solutions tailored to each client's specific needs. The Firm works closely with each client to determine their investment objectives, time horizon, and risk tolerance through detailed questionnaires to construct the optimal portfolio. Portfolio construction involves the careful selection of individual securities to create an investment strategy aligned with the client's objectives. Once the client's objectives are established, the Firm will construct a portfolio comprising various investment vehicles. These typically include stocks, bonds, mutual funds, and cash equivalents (e.g., money market funds, T-Bills, and CDs). The specific securities selected will depend on the client's objectives, tax status, and risk tolerance. Cash equivalents and fixed-income selections are particularly important for clients seeking retirement income or capital preservation. The Firm's investment approach is primarily long-term, with typical holding periods of 3 to 5 years for equity positions. However, the Firm may adjust positions based on valuation targets or changes in fundamental circumstances. After constructing a portfolio, we provide ongoing monitoring for suitability and performance, with regular reporting to clients. Valuable tax strategies are employed when 1 Formerly, the National Association of Securities Dealers or NASD 2 Registration as an investment adviser with the Securities and Exchange Commission is not intended to imply any level of skill or training. 4 | P a g e  appropriate. Clients may impose restrictions on investing in certain securities or types of securities and may maintain multiple accounts with varying investment objectives. Our Cash Management Services provide professional management of liquid assets through a carefully constructed portfolio on a discretionary basis. The portfolio may include one or more of the following products: FDIC-insured certificates of deposit (CDs), government securities, money market funds, or short-term municipal securities, with maturities typically up to five years. Based on a client's tax status, we select an appropriate mix of taxable and tax-exempt securities. We employ laddering strategies to enhance yields while managing interest rate risk and maintaining appropriate liquidity for our clients. For our 401(k) Plan Consulting Services, we provide investment consulting services to employer- sponsored retirement plans. In this capacity, we consult with employers on plan investment options and provide guidance on investment menu selection and monitoring. We collaborate with Human Resource departments to assist with plan enrollment processes and participant onboarding. As part of our ongoing service commitment, we conduct annual on-site meetings with employees to provide educational resources and review their retirement plans, helping ensure participants understand their investment options and can make informed decisions about their retirement savings. C. Client-Tailored Services and Client-Imposed Restrictions We tailor our advisory services to meet each client's individual needs. Through personal discussions and detailed questionnaires, we establish each client's objectives, time horizon, and risk tolerance. The portfolio we develop and manage is based on these factors. For our investment management clients, we accommodate restrictions on investing in certain securities or types of securities. Clients may also maintain multiple accounts with varying investment objectives. For our 401(k) plan consulting services, we work with plan sponsors to understand their employee demographics and plan objectives to provide appropriate guidance on investment menu construction. D. Wrap Fee Programs We do not participate in wrap-fee programs. E. Regulatory Assets Under Management As of December 31, 2024, the Firm managed $909,951,360 client assets on a discretionary basis. 5 | P a g e  Item 5 ‒ Fees and Compensation A. Advisory Fee Structure 1. Investment Management Services We charge an annual fee based on a percentage of assets under management according to the blended fee schedule: Assets Under Management Annualized Fee % First $1,000,000 1.00% Next $4,000,000 0.75% Next $15,000,000 0.50% Over $20,000,000 Negotiable Under this blended or graduated fee schedule, each tier of assets is charged the corresponding fee percentage. For example, client assets valued at $7,000,000 would be charged as charged as follows: • First $1,000,000 at 1.00% = $10,000 • Next $4,000,000 at 0.75% = $30,000 • Next $2,000,000 at 0.50% = $10,000 Total annual fee = $50,000 (0.714% blended rate) The minimum account size is generally $500,000, which may be met by aggregating Investment Management Services accounts within the same household. We may accept smaller accounts at our discretion. Our standard fee schedule may be negotiable based on factors such as account size and service requirements. Pre-existing advisory clients may be subject to different fee arrangements based on the terms in effect when they entered into their advisory relationship. 2. Cash Management Services For Cash Management Services (“CMS”), the Firm charges a flat annual fee of 0.25% on all assets in each Cash Management Services account. While CMS does not require a minimum account size, this service is only available to existing Investment Management Service clients. Our standard fee of 0.25% may be negotiable based on factors including account size and service requirements. Pre-existing advisory clients may be subject to different fee arrangements based on the terms in effect when they entered into their advisory relationship. 6 | P a g e  3. 401(K) Plan Consulting Services For 401(k) Plan Consulting Services, the Firm charges an annual fee of 0.25% of plan assets. B. Fee Billing and Method of Payment For Investment Management Services and Cash Management Services, we bill advisory fees quarterly in advance based on the account's market value at the end of the previous calendar quarter. For new accounts, we prorate the fee for the remainder of the current quarter based on the initial account value. Asset flows during the quarter resulting in a fee adjustment (credit or debit) over $100 will be reflected on the following quarter's bill. Fees are typically deducted directly from client accounts the next business day after billing. For 401(k) Plan Consulting Services, fees are billed in advance based on the plan’s market value at the end of the previous calendar quarter. Fees are deducted directly from participant accounts by the plan’s custodian. C. Other Fees and Expenses Clients pay additional fees and expenses beyond our advisory fees, including: • Custodial and brokerage fees (transaction fees, annual IRA fees, account closure fees) • Mutual fund expense ratios (management fees charged by mutual fund companies Please see Item 12 (Brokerage Practices) for additional information about brokerage fees. D. Advance Payment Refunds Clients may terminate their investment advisory agreement at any time by providing written notice. Upon termination, we will refund the prorated portion of any prepaid fees for the remainder of the quarter. E. Additional Compensation Neither Cullen nor any supervised persons accept compensation for the sale of securities or other investment products. Item 6 ‒ Performance-Based Fees and Side-By-Side Management We do not charge any performance-based fees on investment advisory accounts we manage. Item 7 ‒ Types of Clients Cullen offers its advisory services to individuals, high-net-worth individuals, trusts, estates, charitable organizations, qualified plan sponsors, and other business entities. For information about our minimum account-sized requirements, please see "Item 5 – Fees and Compensation." 7 | P a g e  Item 8 ‒ Methods of Analysis, Investment Strategies, and Risk of Loss Investing in securities involves the risk of loss that clients should be prepared to bear. While Cullen employs strategies to mitigate risk, we cannot guarantee that clients will not incur losses. We encourage clients to discuss their risk tolerance with us thoroughly. We employ two primary investment strategies to manage client assets: our Basic Value Strategy and our Bucket Approach to Retirement. These strategies are implemented after careful fundamental analysis and consideration of each client's individual circumstances. Methods of Analysis: Our primary method is fundamental analysis, through which we evaluate: • Business models and their attractiveness • Financial strength and stability • Management quality and demonstrated efficiency • Quantitative metrics include: o Sales ratios o Book values o Growth rates o Returns on equity o Financial strength indicators Intrinsic value calculations o We utilize the following information sources for our analysis: • Financial publications • Corporate activity inspections • Annual reports and prospectuses • SEC Filings • Company press releases • Research services, including Morningstar and Value Line • Corporate rating services • Third-party research materials Investment Strategies: 1. Basic Value Strategy • This is our core investment approach applied across all client portfolios. Key elements include: • Portfolio diversification across 20-30 carefully selected companies • Long-term holding periods (typically 3-5 years or longer) • Focus on securities trading at attractive discounts to intrinsic value 8 | P a g e  • Emphasis on patience and discipline in execution • Very low portfolio turnover to minimize costs and tax implications • Application to all security selections, including stocks, bonds, and fund vehicles • Avoidance of market timing This strategy seeks companies with attractive business models, solid finances, and high-quality management that have demonstrated superior efficiency in running the company. We focus on securities that are attractive in relation to their sales, book values, rates of growth, returns on equity, and financial strength. 2. Bucket Approach to Retirement For retirement-focused clients, we implement a specialized strategy that includes: Integration with our Basic Value Strategy for long-term growth portions of the portfolio • Creation of a cash bucket invested in money market funds, CDs, and ultra-short-term bond funds • Maintenance of 3-5 years of anticipated withdrawal needs in conservative investments • Automated monthly deposits to replicate employment income streams • This approach recognizes that clients need consistent income streams in retirement while addressing longevity risk through continued growth investment. The strategy helps clients avoid becoming too conservative with their investments as life expectancy increases. B. Material Risks Our investment strategies and methods of analysis involve the following material risks: Value Strategy Risks: • Value investments may remain undervalued for extended periods, affecting portfolio returns • Concentrated portfolios (20-30 positions) may increase volatility compared to broader diversification • Long-term holding periods require patience through market cycles and temporary downturns • Company-specific risks in individual security selection may impact overall portfolio performance • Market risk affecting overall security prices regardless of individual company performance • Economic conditions affecting corporate performance and valuations Cash Management/Bucket Approach Risks: Interest rate risk may affect fixed-income portions of portfolios Inflation risk may impact the purchasing power of conservative investments • Credit risk in corporate debt instruments could lead to defaults • • Reinvestment risk when rates decline affects income generation • Longevity risk if the portfolio is too conservative 9 | P a g e  • Liquidity needs may require selling in unfavorable markets Risk Mitigation Approaches: We attempt to reduce risks through: • Disciplined diversification across positions • Careful fundamental analysis before investment • Asset allocation aligned with client objectives • Regular portfolio monitoring and rebalancing when needed • Balance between growth and capital preservation • Low turnover to minimize transaction costs C. Primary Security Types and Material Risks We primarily recommend the following securities, each carrying specific risks: Individual Stocks: • Company-specific business and financial risks: A company's performance can be negatively impacted by poor management decisions, competitive pressures, industry changes, or deteriorating financials, potentially leading to a decline in stock value • Market volatility: Stock prices can fluctuate significantly based on general market conditions, economic factors, or global events, regardless of company fundamentals • Potential for complete loss of principal: In extreme cases such as bankruptcy, stockholders may lose their entire investment as they are last in line for claims on company assets Individual Bonds: • Interest rate risk: When interest rates rise, bond prices typically fall. This inverse relationship can reduce the market value of bonds held in the portfolio, particularly those with longer maturities. • Credit risk: The issuer may fail to make interest or principal payments when due or may default • entirely. Changes in an issuer's credit rating can also affect bond values. Inflation risk: Fixed interest payments may lose purchasing power over time if inflation rates exceed the bond's yield • Limited liquidity: Some bonds, especially municipal or corporate issues, may be difficult to sell at desired prices if market conditions change or immediate cash is needed. Open-end and Closed-end Funds: • Management risk: Fund performance depends heavily on manager skill and strategy execution. Changes in management or strategy can affect returns. • Market risk: Funds are subject to the same market forces affecting their underlying securities. Diversification within a fund does not guarantee against loss 10 | P a g e  • Expense considerations: Management fees and operating expenses can reduce overall returns, particularly in low-yield environments • Premium/discount variations (closed-end funds): These funds can trade above (premium) or below (discount) their net asset value, affecting investor returns independent of fund performance Money Market Funds and Cash Equivalents (used in Bucket Strategy): Interest rate risk: Low rates may result in minimal returns that fail to keep pace with inflation • • Credit risk: While generally considered safe, money market funds can experience losses if underlying securities default • Purchasing power risk: Extended periods in cash-equivalent securities may erode real returns due to inflation • FDIC limitations: Some cash vehicles may not be government-insured, exposing them to potential institutional failure risk These risks are discussed with clients upon account opening and periodically throughout our relationship. We work to align investment strategies and risk levels with each client's objectives and risk tolerance while acknowledging that all investment strategies carry some level of risk that clients must be prepared to bear. Item 9 ‒ Disciplinary Information There are no legal or disciplinary events that are material to a client or prospective client's evaluation of our advisory business or its principal owners, Mr. Bordes or Mr. Nickel. Item 10 ‒ Other Financial Industry Activities and Affiliations A. Broker-Dealer Registration Status The Firm is not registered as a broker or dealer, nor does it have an application pending to register as a broker-dealer. B. Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Adviser, and Non-U.S. Registrations Cullen is not registered with the U.S. Commodities Trading Commission as a Commodity Pool Operator or Commodity Trading Firm. C. Material Relationships Cullen does not have any relationships or arrangements that are material to a client's evaluation of our advisory business. 11 | P a g e  D. Other Investment Advisers Cullen does not select or recommend other investment advisers for our clients and does not receive compensation, directly or indirectly, from other advisers. Item 11 ‒ Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Cullen has implemented a Code of Ethics (the "Code") that defines our fiduciary commitment to each client. This Code applies to all persons associated with Cullen ("Supervised Persons"). The Code was developed to provide general ethical guidelines and specific instructions regarding our duties to you, our client. Cullen and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each client. The Code covers various topics but is not limited to: • Standards of business conduct • Personal securities transactions and reporting • Quarterly transaction reports • Insider trading prevention • Outside business activities • Gifts and entertainment policies • Whistleblower procedures To request a copy of Cullen's Code, please contact us at (337) 237-8000. B. Personal Trading with Material Interest Neither Cullen nor any related person has a material interest financial interest in securities recommended to clients. The Firm does not act as a principal in any transaction, act as a general partner in a partnership, or act as an investment adviser to an investment company. C. Personal Trading in the Same Securities as Clients Cullen allows our supervised persons to purchase or sell the same securities that may be recommended to and purchased on behalf of clients. Owning the same securities we recommend (purchase or sell) to you presents a conflict of interest that, as a fiduciary, we must disclose to you and mitigate through policies and procedures. The Firm maintains and enforces personal trading policies through its Code of Ethics, including required quarterly transaction reporting and annual holdings reports. 12 | P a g e  D. Personal Trading at the Same Time as Clients While Cullen permits supervised persons to purchase or sell securities that may be recommended to and purchased on behalf of clients, we maintain strict controls to prevent conflicts. As a general practice, employee trades are executed on different days from client trades to avoid potential conflicts. In the limited circumstances where employee and client trades occur on the same day, we conduct a review of these transactions. Based on this review, trades may be aggregated and executed at an average price, or prices may be adjusted to ensure clients receive the more favorable execution. Item 12 ‒ Brokerage Practices A. Factors Considered in Selecting Broker-Dealers Cullen has established an institutional relationship with Raymond James & Associates ("Raymond James"), a FINRA member broker-dealer, which serves as both the executing broker-dealer for client transactions and the qualified custodian for client assets. Cullen is independently owned and operated and is not affiliated with Raymond James. In selecting Raymond James, Cullen considers several factors, including: • Financial stability and reputation • Quality and speed of trade execution • Research and analytical tools • Technology and operational capabilities • The quality of client services These factors are regularly reviewed to ensure that the arrangement with Raymond James continues to meet Cullen's duty of best execution and the overall needs of our clients. While we believe our arrangement with Raymond James is in the best interests of our clients, by directing clients to use a particular broker, we may be unable to achieve the most favorable execution, and this practice may cost clients more money. B. Soft Dollar Arrangements Cullen does not participate in any soft dollar arrangements. We do not receive research or other products or services from a broker-dealer or a third party in connection with client securities transactions ("soft dollar benefits"). C. Custodial Arrangements As part of its institutional platform, Raymond James provides us with access to its institutional trading and custody services, which may not be available to retail investors. These services are generally available to independent investment advisers at no charge to them as long as client assets are maintained in accounts at Raymond James. Services include brokerage, custody, research, and access to mutual funds 13 | P a g e  and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. Raymond James generally does not charge separately for custody services but is compensated by charging commissions or other fees on trades it executes or that settle in client accounts. Certain trades may not incur Raymond James commissions or transaction fees. Clients may incur additional fees from Raymond James for other services, such as wire transfers or other account-specific fees. D. Aggregating and Allocating Trades Cullen generally executes orders for client accounts individually and does not aggregate orders for multiple client accounts due to the personalized portfolio management approach we provide to each client. When we do not aggregate orders, we may be unable to achieve the most favorable execution of client transactions, and this practice may cost clients more money. From time to time, we execute block trades when appropriate for multiple client accounts. In these cases, trades are executed at an average price with participating accounts receiving the same execution price and sharing transaction costs pro-rata, through another method (e.g., random) may be used when necessary to ensure fair and equitable treatment over time. Item 13 ‒ Review of Accounts A. Review of Accounts Client accounts are reviewed at least quarterly by an assigned investment adviser representative, either by Mr. Bordes or Mr. Nickel. These reviews evaluate each account's performance, balance, transactions, and current security positions relative to the client's stated investment objectives. Additionally, Mr. Bordes, in his capacity as Chief Compliance Officer, conducts a separate quarterly review of all client accounts as part of the Firm's compliance program. B. Other Account Reviews In addition to periodic reviews, we conduct account reviews when triggered by any of the following factors: • Material changes in market conditions • Client meetings or client-initiated requests • Significant developments affecting portfolio holdings • Cash inflows or outflows • Changes in relevant tax laws • Receipt of new investment information that may impact strategy • Changes in a client's personal or financial situation 14 | P a g e  C. Regular Reports Clients receive written portfolio statements at least quarterly. These statements include: • Total portfolio market value • Name and amount of each security held • Percentage weight of individual positions and asset class allocations • The current market value of each security • Cash balance • Unrealized gains and losses (in both dollar amounts and percentages) • Current yields Upon client request, we also provide: • Written performance reports • Supplemental tax information for portfolio holdings Our regular reporting ensures clients have a comprehensive view of their portfolio status and performance. Copies of all written reports are maintained in the client's file. Item 14 – Client Referrals and Other Compensation A1. Economic Benefits of Utilizing Raymond James & Associates Cullen has established an institutional relationship with Raymond James & Associates ("Raymond James"), a FINRA member registered broker-dealer, to serve as both executing broker-dealer and qualified custodian. As an investment adviser utilizing Raymond James' institutional platform, the Firm receives access to software and related support without cost because of our clients' custody of assets at Raymond James. Services provided by Raymond James benefit many, but not all, of Cullen's clients. The receipt of economic benefits from Raymond James creates a potential conflict of interest since these benefits may influence Cullen's recommendation of Raymond James as both executing broker-dealer and custodian. A2. Services that May Only Benefit Cullen Raymond James also offers other services to Cullen that may not directly benefit Cullen's clients. These services include access to educational conferences and events, practice management resources, technology support, consulting services, and discounts for various service providers. Access to these services creates an incentive for us to recommend Raymond James, which presents a conflict of interest. B1. No Compensation Received for Referrals to Service Providers Cullen does not receive any compensation for client referrals. However, Cullen may refer clients to unaffiliated service providers such as attorneys, tax preparers, accountants, estate planners, real estate 15 | P a g e  agents, and loan officers ("Service Providers"). Cullen does not receive any compensation for these referrals. In turn, these Service Providers may refer clients to Cullen. Whether Cullen receives a client referral or refers a client to a Service Provider, no compensation is received or paid. Item 15 ‒ Custody Investment Management Accounts and Fee Deductions at Qualified Custodians As disclosed in "Item 5 – Fees and Compensation," Cullen directly debits advisory fees from client accounts. As part of the billing process, Cullen calculates the fee amount and advises Raymond James of the fee amount to be deducted from each client's account. Raymond James, acting as the qualified custodian, provides each client with custody statements at least quarterly, which reflects the deduction of the quarterly advisory fee. Importance of Verification of the Fee Calculation As Raymond James does not calculate the fee deduction amount, it is vital for clients to carefully review their custody statements to ensure the accuracy of the calculation. Clients should also compare any reports received from Cullen with their Raymond James custody statements. If clients believe there is an error in their custody statement, they should contact Cullen directly. Class Action Lawsuits We do not determine if securities held by clients are the subject of class action lawsuits or if they are able to participate in litigation to recover damages on a client's behalf for losses as a result of actions, misconduct, or negligence by issuers of securities held. Item 16 ‒ Investment Discretion We provide investment management services on a discretionary basis. Discretionary authority means that we have the power to buy, sell, or rebalance securities in a client's account without obtaining the client's prior consent for each transaction. To grant us discretionary authority, clients must execute an Investment Management Contract (the “Contract). The Contract, along with the Investment Advisory Client Information form and Investment Advisory Account Guidelines form, documents the scope of our discretionary authority and any client- specific investment restrictions. Our discretionary authority becomes effective upon execution of the Contract. 16 | P a g e  Item 17 ‒ Voting Client Securities (Proxy Voting) The Firm does not vote proxies for securities held in client accounts. Clients are solely responsible for receiving and voting proxies for all securities maintained in their portfolios. Proxies are sent by Raymond James, the qualified custodian, or the transfer agent directly to the client. While Cullen does not vote proxies, we are available to answer general questions regarding proxy voting matters. Item 18 ‒ Financial Information Cullen does not require the payment of fees of $1,200 or more six months or more in advance. No financial condition of which the Firm is currently aware would impair the Firm's ability to meet its contractual commitment to its clients. The Firm has not been the subject of a bankruptcy petition within the past ten years. 17 | P a g e