Curtis Capital Advisors

Item 1: Cover Page Curtis Capital Advisors, LLC Form ADV Part 2A Brochure Address: 7900 College Blvd., Suite 140, Overland Park, KS 66210 Phone: (913) 344-5443 Email: chris@curtisca.com Website: www.curtisca.com This brochure provides information about the qualifications and business practices of Curtis Capital Advisors, LLC. If you have any questions about the contents of this brochure, please contact us at the telephone number or email address listed above. 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. Curtis Capital Advisors, LLC is a registered investment advisor, but registration does not imply a certain level of skill or training. Additional information about Curtis Capital Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov and by searching for CRD# 330835. Page 1 of 21 Date of Brochure: June 11, 2026  Item 2: Material Changes This Brochure dated June 11, 2026, represents an amendment to the Brochure for Curtis Capital Advisors, LLC. Since the filing of the last annual update Brochure dated January 20, 2026, we have made various minor updates, but no material changes were made. Pursuant to regulatory requirements, we will deliver to you a summary of any materials change to this and subsequent Brochures within 120 days of the close of our fiscal year. We may further provide other ongoing disclosure information about material changes as necessary. All such information will be provided to you free of charge. Currently, our Brochure may be requested by contacting us at (913) 344-5443. Additional information about the firm is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with the firm who are registered as investment adviser representatives of the firm. Page 2 of 21 Date of Brochure: June 11, 2026  Item 3: Table of Contents 1 2 3 4 6 8 9 10 12 13 Item 1: Cover Page Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business Item 5: Fees and Compensation Item 6: Performance-Based Fees & Side-By-Side Management Item 7: Types of Clients Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Item 9: Disciplinary Information Item 10: Other Financial Industry Activities & Affiliations Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading Item 12: Brokerage Practices Item 13: Review of Accounts Item 14: Client Referrals and Other Compensation Item 15: Custody Item 16: Investment Discretion Item 17: Voting Client Securities Item 18: Financial Information 14 15 16 17 18 19 20 21 Page 3 of 21 Date of Brochure: June 11, 2026  Item 4: Advisory Business A. Curtis Capital Advisors, LLC (the “Advisor,” “we,” “us,” or “our”) is an investment advisor founded in 2024, which is currently registered with the US Securities and Exchange Commission and principally owned by Christopher Costello. B. Advisor offers the following types of advisory services: i. Discretionary Investment Management. Advisor provides ongoing discretionary investment management services to its clients based upon each client’s current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of clients’ account(s). This information will then be used to make investment decisions that reflect clients’ individual needs and objectives on an initial and ongoing basis. Advisor’s investment decisions will allocate portions of clients’ account(s) to various asset classes classified according to historical and projected risks and rates of return. Advisor will retain the discretion to buy, sell, or otherwise transact in securities and other investments in a client’s accounts without first receiving the client’s specific approval for each transaction. Such discretionary authority is granted by a client in his or her investment management agreement with Advisor. Clients may impose restrictions on investing in certain securities or types of securities so long as such Advisor. restrictions may reasonably be implemented by Advisor generally implements its investments strategy by allocating clients’ investable assets across a diversified risk-based portfolio of no-load mutual funds and/or exchange traded funds (“ETFs”), stocks, bonds, certificates of deposit, municipal securities, U.S. Government securities, money market funds, real estate investment trusts (“REITs”), etc. ii. Non-Discretionary Investment Management. Advisor provides ongoing non-discretionary investment management services to its clients based upon each client’s current financial condition, goals, risk tolerance, income, liquidity requirements, investment time horizon, and other information that is relevant to the management of clients’ account(s). This information will then be used to make investment recommendations that reflect clients’ individual needs and objectives on an initial and ongoing basis. Advisor’s investment recommendations will allocate portions of clients’ account(s) to various asset classes classified according to historical and projected risks and rates of return. Advisor will not be granted the discretion to buy, sell, or otherwise transact in securities and other investments in a client’s accounts, and may do so only upon receiving the client’s specific approval for each transaction. Clients may impose restrictions on investing in certain securities or types of securities so long as such restrictions may reasonably be implemented by Advisor. Advisor generally implements its investments strategy by allocating clients’ investable assets across a diversified risk-based portfolio of no-load mutual funds and/or exchange traded funds (“ETFs”), stocks, bonds, certificates of deposit, municipal securities, U.S. Government securities, money market funds, real estate investment trusts (“REITs”), etc.. iii. Financial Planning. When rendering financial planning services (which may be provided either in connection with investment management services or as a standalone service), Advisor will evaluate and make recommendations with respect to various financial planning topics that are relevant to a particular client. Such topics can include, for example, retirement planning, education savings, cash flow management, debt reduction, estate planning, insurance needs, risk mitigation, tax planning, charitable giving strategies, and/or financial goal tracking. Implementation of Advisor’s recommendations will be at the discretion of the client. Page 4 of 21 Date of Brochure: June 11, 2026  When rendering financial planning services, a conflict exists between Advisor’s interests and the interests of its clients; clients are under no obligation to act upon Advisor’s financial planning recommendations. If a client elects to act on any of the recommendations made by Advisor, the client is under no obligation to effect the transaction through Advisor or any of its personnel. iv. Referral Services. From time to time and when appropriate for a particular client, Advisor will refer clients to an independent and third-party investment Advisor (“Third-Party Advisor”) with whom we have a written agreement and who compensate us for such referrals to manage a portion of a client’s portfolio. Our referral services are limited to making referrals and are only made when we deem it appropriate - we do not retain any ongoing oversight or management for any assets managed by such referred Third-Party Advisors. We will not be responsible for reviewing the ongoing performance of the assets being managed by the Third-Party Advisor or the Third-Party Advisor’s services. If the Client decides to engage the Third-Party Advisor, Client will enter into an advisory agreement directly with the Third-Party Advisor. C. Advisor does not participate in any wrap fee programs. D. 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 (“ERISA”) and/or the Internal Revenue Code (the “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 rule’s provisions, we must: put our interest ahead of yours. Under this special i. Meet a professional standard of care when making investment recommendations (give ii. iii. iv. 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; 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 v. vi. Give you basic information about conflicts of interest. E. As of December 31, 2025, the firm had $165,500,000 in assets under management, $159,000,000 of which was managed on a discretionary basis and $6,500,000 of which was managed on a non- discretionary basis. Page 5 of 21 Date of Brochure: June 11, 2026  Item 5: Fees and Compensation A. Advisor is compensated for its advisory services primarily by fees charged based on a client’s assets under management with Advisor. For clients that do not wish to engage Advisor to provide ongoing portfolio management or advisory services, Advisor alternatively offers standalone financial planning services on a flat-fee or hourly basis, subject to negotiation with a client. The hourly rate for standalone financial planning services is $500 an hour. Fixed fees for standalone financial planning services begin at $2,500. Fees are negotiable, and each client’s specific fee schedule is included as part of the investment client. by advisory agreement signed Advisor and the Advisor’s standard fee schedule is included below, subject to negotiation with a client: Client Assets Under Management $0 - $999,999 $1,000,000 - $2,999,999 $3,000,000 - $9,999,999 $10,000,000 and above Annual Fee Percentage (paid quarterly) 1.00% 0.75% 0.50% 0.25% B. The fee schedule above is a ‘tiered’ or ‘blended’ fee schedule, which means that different annual fee percentages will apply to different ranges of client assets under Advisor’s management. Fees are deducted in advance on a quarterly basis from clients’ assets and based upon the average daily balance of such assets managed by Advisor during the prior calendar quarter. Outstanding margin balances and cash are included in the assets upon which fees are assessed. C. In addition to the fees charged by Advisor, clients will incur brokerage and other transaction costs from parties other than the Advisor. Please refer to Item 12: Brokerage Practices, for further information on such brokerage and other transaction-related practices. Clients will also typically incur additional fees and expenses imposed by independent and unaffiliated third-parties, which can include qualified custodian fees, mutual fund or exchange traded fund fees and expenses, mark-ups and mark-downs, spreads paid to market makers, wire transfer fees, check-writing fees, early-redemption charges, certain deferred sales charges on previously-purchased mutual funds, margin fees, charges or interest, IRA and qualified retirement plan fees, and other fees and taxes on brokerage accounts and securities transactions. These additional charges are separate and apart from the fees charged by Advisor and Advisor does not share in these charges. D. If Advisor or client terminates the advisory agreement before the end of a quarterly billing period, Advisor’s fees will be prorated through the effective date of the termination. The pro rata fees for the remainder of the quarterly billing period after the termination will be refunded to the client. E. We do not charge referral fees to clients for the provision of Referral Services. However, the Third- Party Advisor to whom we refer will generally charge referred clients an advisory fee, a portion of which will be shared with us. Such advisory fees are not increased solely as a result of our referral. The specific amount to be paid by Third-Party Advisors to us will vary. Clients referred to a Third- Party Advisor by us will receive a disclosure statement that details the fee payment arrangement between us and the Third-Party Advisor. F. Associated persons of the firm are allowed to be licensed insurance agents, and from time to time will earn an ordinary and customary commission from insurance commissions shared with the various insurance agency(ies) whose products are sold. This creates a conflict of interest, because the individual has the potential to earn both a shared insurance commission and advisory fee revenue from a client. The firm addresses this conflict of interest by fully disclosing this insurance commission sharing arrangement in this brochure, by only making an insurance agency referral Page 6 of 21 Date of Brochure: June 11, 2026  when believed to be in the best interest of clients, and informing clients in this brochure that they are under no obligation to purchase an insurance product through the insurance agency to whom he refers clients. Page 7 of 21 Date of Brochure: June 11, 2026  Item 6: Performance-Based Fees & Side-By-Side Management Neither Advisor nor any of its supervised persons accepts performance-based fees (fees based on a share of capital gains or capital appreciation of the assets of a client). Neither Advisor nor any of its supervised persons engage in side-by-side management. Page 8 of 21 Date of Brochure: June 11, 2026  Item 7: Types of Clients Advisor generally provides its services to individuals, high-net-worth individuals, and trusts. Advisor does not require a minimum account value to open or maintain an account. Page 9 of 21 Date of Brochure: June 11, 2026  Item 8: Methods of Analysis, Investment Strategies & Risk of Loss A. We firmly believe that it is impossible to consistently correctly time the market or consistently select which specific investments will outperform the market in general or its category peers. As such, we do not attempt to time the market nor do we lead our clients to believe that we will select investments that will outperform any specific benchmark or category peer. We believe that it is outside the realm of our ability, and any other Advisor’s ability for that matter, to consistently do such. Therefore, we focus on the 3 things that ARE within our control and our clients’ control. 1) The overall allocation between equities (historically higher returns with higher volatility), bonds or fixed income (historically lower returns with lower volatility) and cash-like investments (little or even negative return due to inflation but little or no volatility). 2) The total investing expenses inclusive of the fee paid to an advisor and the fees associated with the investments utilized in their portfolio (transaction fees, internal expenses, etc). 3) Their investment behavior. In other words - their decision making in the face of market volatility. Specifically greed or fear and whether or not they allow those emotions to dictate their investment decisions. Our investment strategy primarily involves the research and selection of mutual funds and exchange traded funds (ETFs) for our clients’ portfolios, but we may include other investments as well. Our goal with each client is to construct an investment portfolio that seeks the maximum gain over time balanced carefully against each client’s unique risk tolerance and financial goals. Our belief and conviction is that investing in publicly traded equities should produce the highest returns over time but we also realize that very few clients have the risk tolerance to maintain their entire investment portfolio in equities given the inevitable, periodic declines in the stock market. As such, we work to strike the right balance for each client in terms of their overall allocation between equities, other more conservative investments such as fixed income investment and cash (money market) balances, and other investments. We believe in a bias towards using index funds for the majority of our clients’ portfolios. This allows us to minimize the total investing expense in relation to using a majority of actively managed funds that generally come with higher internal expenses. Data has shown that, over time, lower cost index funds tend to outperform a majority of their higher cost actively managed peer funds. In certain cases, we may still use actively managed funds in sectors where indexing has not historically provided outperformance. We believe that the preponderance of the value that our firm provides its clients comes in the form of managing the behavior once the investment portfolio is implemented. Historically, data has shown that the majority of individual investors without proper guidance underperform the market benchmarks. We believe that this isn’t due to poor security selection rather it is most often a result of attempts to time the market - both on the buy side and the sell side. Said another way, even average performing investments held over long periods of time have historically shown to produce superior returns than top performing investments that are traded in and out of. In summary, it is our intention to implement an investment strategy for each client to maximize the potential for long term return balance against their own unique tolerance for risk and volatility and then do our best to keep our clients in that strategy for as long as possible. Changes to the investment strategy should only come from careful discussions with the client when their life situation and/or goals change as opposed to knee jerk reactions to swings in the market. We aim to help our clients resist the inevitable temptations to chase outperforming investments or sectors and/or panic out of investments or sectors during the inevitable downturns. We believe that this is Page 10 of 21 Date of Brochure: June 11, 2026  our best chance to add the most value in relation to the cost to work with us - far exceeding the work of security selection itself. Given this, it is imperative that each client make us aware as soon as possible if their financial situation, their investing goals or tolerance for risk and volatility changes. B. Our investment approach includes investing in the stock market. Investing in the stock market carries significant risks. Although we try to reduce risk by diversifying a portfolio across multiple asset classes and many hundreds of individual equities and fixed income instruments - this doesn’t mean that the value of your accounts won’t decline. Although we may use average assumptions for projection and planning purposes, that in no way means that we guarantee any particular rate of return. All investments are subject to fluctuation in value and potential loss of principle. Therefore it is possible that you could lose part of your investment. In addition the volatility risk, you are also subject to the following risks: 1. Market Risk: This refers to the possibility that the value of investments will decrease due to market factors. This risk affects almost all types of investments, including stocks, bonds, and real estate. Market risk can be influenced by a variety of factors such as economic downturns, political instability, or changes in interest rates. 2. Credit Risk: This risk is particularly relevant for bond investors. It's the risk that the bond issuer will not be able to make the principal and interest payments. This could lead to a default, which might cause the investor to lose some or all of the investment. 3. Interest Rate Risk: This affects investments like bonds. If interest rates rise, the value of existing bonds typically falls because new bonds will likely be issued at the higher rates, making the old ones less attractive in comparison. 4. Liquidity Risk: This is the risk that an investor might not be able to buy or sell investments quickly without significantly affecting the investment's price. Some investments, like real estate or certain small-cap stocks, have higher liquidity risk than others, such as large-cap stocks. 5. Inflation Risk: This is the risk that inflation will erode the purchasing power of the returns on your investments. Fixed-income investments are particularly vulnerable to inflation risk because the return might not keep up with the rate of inflation. 6. Currency Risk: For investments in foreign assets, there's a risk that currency fluctuations can affect the investment value. If you invest in a foreign stock and that country's currency weakens against yours, the value of your investment could decrease when converted back to your home currency. 7. Concentration Risk: This risk comes from not diversifying your investments. If you invest a large portion of your portfolio in a single investment or sector, you're more exposed to the risks of that particular investment or sector. 8. Geopolitical Risk: Events such as wars, terrorism, elections, and sanctions can have significant impacts on financial markets. These risks are unpredictable and can cause market volatility. 9. Regulatory/Legal Risk: Changes in laws and regulations can affect the value of certain investments. For example, regulatory changes in the environmental sector could impact companies in industries like oil and gas or renewables. By understanding these risks, we can help our clients take steps to mitigate them, such as through diversification, careful research, and adopting a long-term perspective on their investments. It's also crucial to align investments with your risk tolerance and financial goals. Page 11 of 21 Date of Brochure: June 11, 2026  Item 9: Disciplinary Information There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of Advisor’s advisory business or the integrity of Advisor’s management. Page 12 of 21 Date of Brochure: June 11, 2026  Item 10: Other Financial Industry Activities & Affiliations A. Neither Advisor nor any of its management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. B. Neither Advisor nor any of its management persons are registered, or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading Advisor, or an associated person of the foregoing entities. C. Neither Advisor nor any of its management persons have any relationship or arrangement with any related person below: i. ii. iii. iv. v. vi. vii. viii. ix. x. broker-dealer, municipal securities dealer, or government securities dealer or broker 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) other investment advisor or financial planner futures commission merchant, commodity pool operator, or commodity trading advisor banking or thrift institution accountant or accounting firm lawyer or law firm pension consultant real estate broker or dealer sponsor or syndicator of limited partnerships D. Associated persons of the firm are allowed to be licensed insurance agents and from time to time will earn an ordinary and customary commission from the sale of an insurance product in such capacity. This creates a conflict of interest, because the individual has the potential to earn both an insurance commission and advisory fee revenue from a client. The firm addresses this conflict of interest by fully disclosing relationships with the applicable insurance providers, and informing clients that they are under no obligation to purchase an insurance product through the associated person. E. As described in Item 4, we limit our referrals to Third-Party Advisors with whom we have a written agreement and who compensate us for such referrals. This creates a financial incentive for us to refer prospective clients to such Third-Party Advisors, and therefore presents a conflict of interest. To the extent certain Third-Party Advisors pay us higher fees, this creates an incentive to refer you to such Third-Party Advisors instead of third-party advisors that pay us lower fees. We address this conflict of interest by fully disclosing it in this brochure, by additionally disclosing the compensation arrangement with applicable Third-Party Advisors at the time a referral is made, and by only referring prospective clients to Third-Party Advisors we believe to be in prospective clients’ best interests. Page 13 of 21 Date of Brochure: June 11, 2026  Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading A. Advisor has adopted a code of ethics that will be provided to any client or prospective client upon request. Advisor’s code of ethics describes the standards of business conduct that Advisor requires of its supervised persons, which is reflective of Advisor’s fiduciary obligations to act in the best interests of its clients. The code of ethics also includes sections related to compliance with securities laws, reporting of personal securities transactions and holdings, reporting of violations of the code of ethics to Advisor’s Chief Compliance Officer, pre-approval of certain investments by access persons, and the distribution of the code of ethics and any amendments to all supervised persons followed by a written acknowledgement of their receipt. B. Neither Advisor nor any of its related persons recommends to clients, or buys or sells for client accounts, securities in which Advisor or any of its related persons has a material financial interest. C. From time to time, Advisor or its related persons will invest in the same securities (or related securities such as warrants, options or futures) that Advisor or a related person recommends to clients. This has the potential to create a conflict of interest because it affords Advisor or its related persons the opportunity to profit from the investment recommendations made to clients. Advisor’s policies and procedures and code of ethics address this potential conflict of interest by prohibiting such trading by Advisor or its related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances Advisor will act in the best interests of its clients. D. From time to time, Advisor or its related persons will buy or sell securities for client accounts at or about the same time that Advisor or a related person buys or sells the same securities for its own (or the related person’s own) account. This has the potential to create a conflict of interest because it affords Advisor or its related persons the opportunity to trade either before or after the trade is made in client accounts, and profit as a result. Advisor’s policies and procedures and code of ethics address this potential conflict of interest by prohibiting such trading by Advisor or its related persons if it would be to the detriment of any client and by monitoring for compliance through the reporting and review of personal securities transactions. In all instances Advisor will act in the best interests of its clients. Page 14 of 21 Date of Brochure: June 11, 2026  Item 12: Brokerage Practices A. Advisor considers several factors when recommending a custodial broker-dealer for client transactions and determining the reasonableness of such custodial broker-dealer’s compensation. Such factors include the custodial broker-dealer’s industry reputation and financial stability, service quality and responsiveness, execution price, speed and accuracy, reporting abilities, and general expertise. Assessing these factors as a whole allows Advisor to fulfill its duty to seek best execution for its clients’ securities transactions. However, Advisor does not guarantee that the custodial broker-dealer recommended for client transactions will necessarily provide the best possible price, as price is not the sole factor considered when seeking best execution. After considering the factors above, Advisor recommends Charles Schwab & Co., Inc. (“Schwab”) as the custodial broker-dealer for client accounts. i. Advisor does not receive research and other soft dollar benefits in connection with client securities transactions, which are known as “soft dollar benefits”. However, the custodial broker-dealer(s) recommended by Advisor do provide certain products and services that are intended to directly benefit Advisor, clients, or both. Such products and services include (a) an online platform through which Advisor can monitor and review client accounts, (b) access to proprietary technology that allows for order entry, (c) duplicate statements for client accounts and confirmations for client transactions, (d) invitations to the custodial broker-dealer(s)’ educational conferences, (e) practice management consulting, (f) occasional business meals and entertainment, and (g) certain client transaction cost reimbursements and or waivers. The receipt of these products and services creates a conflict of interest to the extent it causes Advisor to recommend Schwab as opposed to a comparable custodial broker- dealer. Advisor addresses this conflict of interest by fully disclosing it in this brochure, evaluating Schwab based on the value and quality of its services as realized by clients, and by periodically evaluating alternative broker-dealers to recommend. ii. Advisor does not consider, in selecting or recommending custodial broker-dealers, whether Advisor or a related person receives client referrals from a custodial broker-dealer or third- party. iii. Advisor maintains discretionary authority over client accounts and does not allow clients to direct Advisor to execute transactions through a specified broker-dealer. B. Advisor retains the ability to aggregate the purchase and sale of securities for clients’ accounts with the goal of seeking more efficient execution and more consistent results across accounts. Aggregated trading instructions will not be placed if it would result in increased administrative and other costs, custodial burdens, or other disadvantages. If client trades are aggregated by Advisor, such aggregation will be done so as not to disadvantage any client and to treat all clients as fairly and equally as possible. Page 15 of 21 Date of Brochure: June 11, 2026  Item 13: Review of Accounts A. Christopher Costello monitors client accounts on an ongoing basis, and typically reviews client accounts no less than on a quarterly basis. Such reviews are designed to ensure that the client is still on track to achieve his or her financial goals, and that the investments remain appropriate given the client’s risk tolerance, investment objectives, major life events, and other factors. Clients are encouraged to proactively reach out to Advisor to discuss any changes to their personal or financial situation. B. Other factors that may trigger a review include, but are not limited to, material developments in market conditions, material geopolitical events, and changes to a client’s personal or financial situation (the birth of a child, preparing for a home purchase, plans to attend higher education, a job transition, impending retirement, death or disability among family members, etc.). C. We do not monitor or otherwise review accounts managed by Third-Party Advisors. Clients are encouraged to proactively reach out to their Third-Party Advisor to discuss any changes to their personal or financial situation. D. The custodial broker-dealer will send account statements and reports directly to clients no less frequently than quarterly. Such statements and reports will be mailed to clients at their address of record or delivered electronically, depending on the client’s election. If agreed to by Advisor and client, Advisor or a third-party report provider will also send clients reports to assist them in understanding their account positions and performance, as well as the progress toward achieving financial goals. Page 16 of 21 Date of Brochure: June 11, 2026  Item 14: Client Referrals and Other Compensation A. We will enter into contractual agreements to act as a promoter/solicitor for certain Third-Party Advisors. Pursuant to these agreements, we will receive compensation as consideration for successful referrals made to Third-Party Advisors. As described above in Item 12, the custodial broker-dealer(s) recommended for client accounts provides certain products and services that are intended to directly benefit Advisor, clients, or both. B. Neither Advisor nor a related person directly or indirectly compensates a person who is not Advisor’s supervised person for client referrals. Page 17 of 21 Date of Brochure: June 11, 2026  Item 15: Custody Advisor recommends that clients’ assets be held by a qualified custodian. Although we do not hold assets, we may have limited control in some instances to trade on your behalf, to deduct our advisory fees from your account with your authorization, or to request disbursements on your behalf (although various types of written authorizations are required depending on the type of disbursements). If a client receives account statements from both the custodial broker-dealer and Advisor or a third-party report provider, client is urged to compare such account statements and advise Advisor of any discrepancies between them. Page 18 of 21 Date of Brochure: June 11, 2026  Item 16: Investment Discretion Advisor accepts discretionary authority to manage securities accounts on behalf of clients only pursuant to the mutual written agreement of Advisor and the client through a power-of-attorney, which is typically contained in the Advisory agreement signed by Advisor and the client. This includes the authority to buy, sell, and otherwise transact in securities and other investment products in client’s account(s) without necessarily consulting with clients in advance. Clients may place reasonable limitations on this discretionary authority so long as it is contained in a written agreement and/or power-of-attorney. Page 19 of 21 Date of Brochure: June 11, 2026  Item 17: Voting Client Securities A. Advisor does not have and will not accept authority to vote client securities. B. Clients will receive their proxies or other solicitations directly from their custodial broker-dealer or a transfer agent, as applicable, and should direct any inquiries regarding such proxies or other solicitations directly to the sender. Page 20 of 21 Date of Brochure: June 11, 2026  Item 18: Financial Information A. Advisor does not require or solicit prepayment of more than $500 in fees per client, six months or more in advance. B. Advisor has no financial condition that is reasonably likely to impair its ability to meet contractual commitments to clients. C. Advisor has not been the subject of a bankruptcy petition at any time during the past ten years. Page 21 of 21 Date of Brochure: June 11, 2026