Evolution Wealth Advisors, LLC

Item 1 – Cover Page Evolution Wealth Advisors, LLC also known as EWA 20900 NE 30th Avenue, Suite 517 Aventura, FL 33180 (305) 921-4740 www.ewadvisors.net March 2026 This Brochure provides information about the qualifications and business practices of Evolution Wealth Advisors, LLC (“EWA”, “us”, “we”, “our”). If you (“client”, “your”) have any questions about the contents of this brochure, please contact us at (305) 921-4740. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or by any state securities authority. EWA’s IARD firm number is 285142. We are a registered investment adviser. Our registration as an investment adviser does not imply any level of skill or training. Additional information about EWA is also available on the SEC’s website at www.adviserinfo.sec.gov (click on the link, select “investment adviser firm” and type in our firm name). The results will provide you with both Parts 1 and 2 of our Form ADV.  Item 2 – Material Changes Since the filing of our last annual updating amendment of Form ADV Part 2A (“Disclosure Brochure”), dated March 2025, there have been no material changes to note in this current document. We have made the following changes: • Item 8 – We have added Legal and Regulatory Matters risks, System Failures and Reliance on Technology risks, Cybersecurity risk, Pandemic risks and Emerging Technology (e.g., Artificial Intelligence) risks. Additionally, we have made other changes that we do not consider material, solely to clarify or enhance existing disclosures. In future filings, this section of the Disclosure Brochure will address only those “material changes” that have been incorporated since our last delivery or posting of this document on the SEC’s public disclosure website (IAPD) at www.adviserinfo.sec.gov. We will periodically update this Disclosure Brochure and send to you an updated copy including a summary of material changes, or a summary of material changes that includes an offer to send you a copy [either by electronic means (email) or in hard copy form]. If you would like another copy of this Disclosure Brochure, please download it from the SEC website as indicated above or contact our Chief Compliance Officer, Luciana Roditi at the telephone number listed on the cover page or via email at lroditi@ewadvisors.net. 2  Item 3 – Table of Contents Item 1 – Cover Page 1 Item 2 – Material Changes 2 Item 3 – Table of Contents 3 Item 4 – Advisory Business 4 Item 5 – Fees and Compensation 8 Item 6 – Performance-Based Fees and Side-By-Side Management 11 Item 7 – Types of Clients 12 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss 12 Item 9 – Disciplinary Information 19 Item 10 – Other Financial Industry Activities and Affiliations 20 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal 22 Trading Item 12 – Brokerage Practices 24 Item 13 – Review of Accounts 29 Item 14 – Client Referrals and Other Compensation 30 Item 15 – Custody 31 Item 16 – Investment Discretion 32 Item 17 – Voting Client Securities (i.e., Proxy Voting) 32 Item 18 – Financial Information 34 Item 19 – Requirements for State-Registered Advisers 34 3  Item 4 – Advisory Business Evolution Wealth Advisors, LLC, also known as EWA, is a limited liability company organized under the laws of the State of Florida since July 28, 2016. EWA is principally owned by Roberto Vainrub through the Roberto Vainrub Revocable Trust, Alan Rotter through the Alan Rotter Revocable Trust, Marcel Apeloig through the MAHR Trust, Antonino Ciulla, Michael Marciano, and Alfonso Angrisano. We have been registered as an investment adviser with the SEC since September 8, 2017, and notice filed in applicable States in order to provide the investment advisory services as described within this document. As of December 31, 2024, our assets under management totaled: Discretionary Managed Accounts: ................ $1,325,111,147 Non-Discretionary Managed Accounts:............. $632,817,734 Assets Under Advisement1: ........................... $3,399,547,884 Total: ............................................................. $ 5,357,476,765 This Disclosure Brochure provides you with information regarding our qualifications, business practices, and the nature of advisory services that should be considered before becoming our advisory client. Please contact Luciana Roditi, Chief Compliance Officer, if you have any questions about this Brochure. Individuals associated with EWA will provide investment advisory services on our behalf. Such individuals are known as Investment Advisor Representatives (“IARs”). We require IARs engaged in determining or offering investment advice to clients to be properly licensed and registered in the states, unless exempted, in which they provide investment advisory services. Below is a description of the investment advisory services we offer. For more detail on any product or service please reference your Investment Advisory Agreement (“IAA”) or contact your IAR. Your IAR will recommend various types of portfolio management services to help meet your investment goals. Portfolio Management Services We provide discretionary advisory and non-discretionary services through separately managed accounts based on your stated investment objectives and restrictions. When 1 Assets under advisement represent assets in which we provide consulting and/or consolidation services and for which we have neither discretionary authority nor responsibility for arranging or effecting the purchase or sale of recommendations provided to and accepted by the ultimate client. Inclusion of these assets will make our total assets number different from assets under management disclosed in Item 5.F of our Form ADV Part 1A due to specific calculation instructions for Regulatory Assets Under Management. 4  you invest through a Separately Managed Account (“SMA”), you own individual securities. Although IARs will oversee many separately managed accounts and some accounts may be managed with other accounts to a specific strategy, your account is separate and distinct from all others. We have developed several model portfolios primarily utilizing Exchange Traded Funds (“ETFs”), Mutual Funds, Bonds, and Equities. In addition, we invest in or recommend any other type of security, including but not limited to, exchange-listed securities, securities traded over-the-counter, foreign issuers, warrants, corporate debt securities (other than commercial paper), commercial paper, , certificates of deposit, municipal securities, mutual fund shares, United States governmental securities, options contracts on securities, , , asset backed securities, mortgage backed securities, non-US sovereign debt, structured notes and other alternative investments. The models range in risk tolerance from conservative to Growth Plus in Balanced Accounts and Investment Grade to High Yield in Fixed Income Accounts. Generally, in the balanced accounts, the more aggressive models have higher allocation to equity ETFs or funds, as opposed to fixed income ETFs and funds, than the more conservative models. There are different types of portfolios that we offer and that we will allocate your assets to, based on your investment objectives and risk tolerance. We regularly monitor the performance of each security selected for each model. Further, we rebalance the portfolios at least once annually. In addition to our own research, we utilize third-party research services to assist us with formulating asset allocation, industry and sector selection, and individual investment recommendations in constructing and maintaining our portfolios. Our discretionary services encompass investment supervisory and management services defined as providing continuous investment advice based on the client’s risk profile and individual needs. Non-discretionary services would authorize us to provide investment recommendations but require your approval to proceed. You make the ultimate decision regarding the purchase or sale of investment. During initial consultation(s), your IAR will have a comprehensive discussion about your financial condition, priorities, and concerns. Based upon these conversations, we will then work to create either a formal investment policy statement or informal agreed upon investment objectives to serve as the primary point of reference and ensure that your objectives are clearly defined. We review your financial situation and needs with you, on an ongoing basis, to accommodate changes to your long term goals and objectives. ‐ One of our IARs, in consultation with you, will decide either to use the model portfolios, to use them for only a portion of your assets, or not to use them. These IARs will also 5  tailor their recommendations and investments based on your investment objectives and risk tolerance through individual stocks, bonds, options, municipals, variable or fixed insurance products, funds, alternative investments, or other individual securities. You have the option of imposing reasonable investment restrictions on certain securities, industries, sectors, or asset classes by providing us with written instructions when you open your advisory account, or at any time thereafter. Please note, such restrictions may affect the composition and performance of your portfolio. For these reasons, the performance of the portfolio may not be identical with our average client. We offer these services through wrap fee accounts and non-wrap fee accounts. The wrap fee program is administered by our custodian Charles Schwab & Co., Inc. (“Schwab”), StoneX Financial, Inc., (“StoneX”) and IBKR Securities Services, LLC (“IBKR”). We do not offer non-wrap fee accounts at those custodians EWA also offers investments in Private Funds (including private equity, private debt, co- investment and/or hedge funds). Such investments are made only for clients who are qualified clients. “Qualified client” means: (i) A natural person who, or a company that, immediately after entering into the contract has at least $1,100,000 under the management of the investment adviser, (ii) A natural person who, or a company that, the investment adviser reasonably believes, immediately prior to entering into the contract, either has a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more than $2,200,000 (excluding the primary residence); or is a “qualified purchaser” as defined in section 2(a)(51)(A) of the Investment Company Act of 1940 at the time the contract is entered into [the term “Qualified Purchaser” includes a trust with assets in excess of $5 million, not formed to acquire the securities offered, and whose purchase is directed by a sophisticated person], or (iii) A natural person who immediately prior to entering into the contract is (a) an executive officer, director, trustee, general partner, or person serving in a similar capacity, of the investment adviser; or (b) an employee of the investment adviser (other than an employee performing solely clerical, secretarial or administrative functions with regard to the investment adviser) who, in connection with his or her regular functions or duties, participates in the investment activities of such investment adviser, provided that such employee has been performing such functions and duties for or on behalf of the investment adviser, or substantially similar functions or duties for or on behalf of another company for at least 12 months. 6  Prospective investors in Private Funds should be aware that the funds are unregistered investment vehicles. Additional risks, restrictions on withdrawals and redemptions, and other important information associated with the pooled unregistered investment vehicles are outlined in each Private Fund’s offering documents. Prospective investors should review these documents carefully for information regarding these and other important additional considerations and risks. Non-Discretionary Consulting Services EWA has entered into consulting arrangements with clients to provide periodic communications with opinions on investment matters including strategy, portfolio structure, asset allocation and/or risk analysis (including recommendations on individual securities). These services are offered on a non-discretionary basis where the client, at its discretion, may implement any of the recommendations by instructing us or their custodian directly. Recommendations may be based on an individual client’s specific investment objectives, needs and financial plan, but typically, are more generally based on macro market assumptions and indicators. The specificity of the recommendations will be based on each client’s preferred relationship with us. Therefore, certain recommendations will not be tailored to an individual client’s needs, but to the market in general. Given the nature of these relationships and the advice provided, we do not typically accept restrictions on accounts. Consolidation Services We can provide consolidation services to our clients. This service entails aggregating the client’s accounts that we supervise with their other accounts, assets, or alternative investments that we do not supervise. This service provides a global view of the client’s assets in order to make informed recommendations and decisions. An initial assessment of which assets will be aggregated will allow EWA to determine if there is an additional cost for this service. We also offer this service as an independent service or as part of a consulting arrangement. IRA Rollover Recommendations In complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020- 02"), when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are a fiduciary within the meaning of Title I of the 7  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 conflicts with client interests. We operate under an exemption that requires we act in the clients’ best interests and not put our or our employees’ interests ahead of the clients’ interests. Under this exemption, we must: • meet a professional standard of care when making investment recommendations (give prudent advice), • never put our or our employees’ financial interests ahead of the clients when making recommendations (give loyal advice), • avoid making misleading statements about conflicts of interest, fees, and • investments, follow policies and procedures designed to ensure that we and our employees give advice that is in the clients’ best interests, • charge no more than is reasonable for services, and • give the clients basic information about conflicts of interest. We benefit financially from the rollover of the clients’ assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we and our employees believe it is in the client’s best interest. Wrap Fee Program We provide management services under a “wrap fee” structure, but we do not perform portfolio management services as part of other sponsors’ wrap fee programs. EWA manages accounts similarly whether structured as a wrap account or not. Clients participating in a wrap fee arrangement pay a single fee for advisory, brokerage and custodial services. Clients’ portfolio transactions will be executed without commissions in a wrap fee arrangement. For further details regarding our wrap fee program, please refer to the Evolution Wealth Advisors Wrap Brochure. Item 5 – Fees and Compensation Portfolio Management Services We generally work with clients who will invest with EWA over $1,000,000 in investable assets which can be reached within the first twelve (12) months of entering into the IAA. Fees for our services are as follows: 8  Non-Wrap Fee Program Fees Fees for clients in the non-wrap fee program are negotiable and can be up to 0.80%. Fee calculations are based on factors that include, but are not limited to, the total value of assets managed under the client relationship with EWA. The fees are payable quarterly in arrears on the last day of the quarter and are charged as a fixed fee or a percentage of assets under management, as determined by the terms agreed upon in the IAA. Quarterly fees that are charged as a percentage of assets under management are calculated as the sum of fees computed at the end of each month by EWA, based on the month end market value, during the calendar quarter. Please note that the balance your fee is based on may not match the statement you receive from the custodian due to dividends, incoming contributions, outgoing withdrawals, settlement issues, etc. The first quarterly payment will be prorated to cover the period from the date the account is opened through the end of the calendar quarter. Thereafter, the fee will be calculated based upon the market value of the account as of the close of business on the last business day of each month of the calendar quarter and will be due and payable on the last business day of each calendar quarter. Wrap Fee Program Fees Fees for clients in our wrap fee program will be a percentage of assets managed up to 1.25% for international clients and 0.95% for US clients. Such fees are negotiable for clients whose assets managed under the client relationship with EWA exceed $10,000,000. Please refer to the Evolution Wealth Advisors Wrap Brochure for further details about the wrap fee program fees. Private Funds Fees When EWA recommends or invests client assets into Private Funds, EWA will charge a management fee that will be calculated as a percentage of the value of the invested capital, or the most current valuation available, and will be billed quarterly. Clients who participate in the wrap fee program will be billed in advance or in arrears and clients who participate in the non-wrap fee program will be billed in arrears. For fees paid in arrears, the initial fee will be prorated to cover the period from the date of the investment through the end of the calendar quarter. We bill you based on the original investment, or the valuation indicated in the last statement as of the end of the billing period. The maximum fee is 1.25% for international clients and 1.00% for US clients. Fees paid in advance are computed based on the total market value of the portfolio at the end of the previous quarter. Due to the illiquid nature of these investments, sometimes we do not receive quarterly valuations; therefore, whenever we receive an updated investment value, your fee will 9  be calculated accordingly. The amount of the fee will depend on considerations such as the transaction’s complexity, the work performed by EWA, the expected return, and third- party costs. In addition to quarterly management fees, at the discretion of the Fund Manager, EWA can also receive a portion of the performance fee (also called carried interest for Private Equity Funds) charged by the Fund Manager. Our receipt of such carried interest is a result of negotiation with the Fund Manager. We, at our discretion, distribute none, part or the whole, carried interest to you, our client. These fees and their specific calculations are disclosed in the Private Equity Fund’s Offering Documents and will be explained by your EWA representative. Limited Negotiability of Advisory Fees Although EWA has established the fee schedules disclosed above, we reserve the option to negotiate the fees on a client-by-client basis. In determining the fees, we will consider the facts, circumstances, and needs of the clients. We will also consider the complexity of the client, assets to be managed, anticipated future additional assets, related accounts, portfolio style, account composition, and reports to be provided, among other factors. We will provide the specific annual fee schedule in the contract between the adviser and each client. Certain related client accounts will be grouped for the purpose of reaching the minimum account size requirements and determining the annual fee. Contracts may be terminated by either party with thirty days written notice. A pro-rata refund will be made of all fees paid in advance of the accepted termination date. EWA can invoice the client directly or have their fees directly debited from the custodian under client authorization. Non-Discretionary Consulting Services In a non-discretionary consulting arrangement, the client will pay a fee which can be a flat fee, or a fee computed on the total market value of the portfolio. Fees are negotiable and payable monthly or quarterly in advance or in arrears based on the IAA for such non- discretionary consulting services. Fees will be based and computed on the value of the portfolio at the end of each month or quarter, or by dividing the annual flat fee over 12 months or four quarters. Other Fees The advisory fee does not cover charges imposed by third parties for investments held in the account, such as contingent deferred sales charges or 12b-1 trails on mutual funds, or performance/carried interest fees charged by private equity funds. In addition, each mutual fund and private equity fund also charges asset management fees, which 10  are in addition to our advisory fees. Other fees charged by a mutual fund may also include, but are not limited to, upfront sales charges and other fund expenses. The advisory fee described above does not cover debit balances or related margin interest or SEC fees or other fees or taxes required by law. The fees charged by such funds or managers are disclosed in each fund’s prospectus. You should review the fund’s prospectus for a complete description of all fees and expenses. All of these other fees are exclusive of, and in addition to, our compensation. We do not offset our fees by these charges. Please see Item 12 - Brokerage Practices for additional information. For our non-wrap accounts, our fees do not include brokerage commissions, transaction fees, and other brokerage related costs and expenses that are paid by you. You will pay any additional fees imposed by custodians, brokers, and other third parties. Termination of Contracts The IAA may be terminated at any time by either party with thirty days written notice. The final quarterly payment will be prorated for the number of months, plus calendar days for partial months, services were provided during the quarter of the accepted termination date. A refund will be made on a pro-rata (by day) basis of any fees paid in advance of the accepted termination date. Full refunds will only be made in cases where cancellation occurs within five (5) business days of signing the IAA. Termination of the IAA will not affect (i) the validity of any action previously taken by us under the agreement; (ii) liabilities or obligations of the parties initiated before termination of the IAA; or (iii) your obligation to pay advisory fees (prorated through the date of termination). Any unearned portion of the fee will be refunded to the client as determined in accordance with the terms of IAA. Any refunds due to the client shall be made as soon as possible from receipt of notice of termination. For the purposes of this provision, a contract is considered entered into when all parties to the contract have signed the contract, or, in the case of an oral contract, otherwise signified their acceptance, any other provisions of this contract notwithstanding. Detailed information on the termination terms and fees can be found in the applicable IAA. Item 6 – Performance-Based Fees and Side-By-Side Management With the exception of Private Funds (including co-investments in private equity funds and Pre-IPOs), we do not charge advisory fees on a share of the capital gains or capital appreciation of the funds or securities in a client account (so-called performance-based 11  fees). However, as described under Item 5, we can participate in the performance fees charged by private funds that we recommend if participation is offered by the fund manager and agreed upon in the contract. This creates a potential conflict of interest because we could benefit by recommending investments that earn a performance fee. However, we have implemented a compliance program that monitors your investment objectives and risk tolerance to help ensure that you are invested in assets that reflect your goals and risk tolerance. Our compensation structure is disclosed in detail in Item 5 above. Item 7 – Types of Clients We provide advisory services to high-net-worth individuals, family offices, corporations or other business entities, and foundations. For wrap accounts, we generally work with clients who have $1,000,000 or more in investable assets with EWA which can be reached within the first twelve (12) months of entering into the IAA. If after the first year the account is below our minimum amount, we will assess a minimum yearly fee of $12,500 (for non-US clients) and $9,500 (for US accounts) paid quarterly in advance or in arrears based on the IAA. EWA has (and reserves the right to) waived its minimum advisory fee for certain clients’ 401K Plans, children’s 529 Plans, clients with a long history with the firm, etc. However, the decision to waive the minimum fee is ours and will not be a uniform decision in each case. As noted, factors such as the client’s history with the firm, as well as the time we feel we will need to be devoted to the client are considered, among other factors. Fees are negotiable for accounts over $10 million. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies Method of Analysis We use several different methods of analysis and sources of information when formulating investment strategies. In addition to our own research, our recommendations may also be obtained from research sources that include financial publications, research prepared by others, annual reports, prospectuses and other regulatory filings, company press releases and other sources. 12  In formulating our investment advice and/or managing your assets, we employ different research methods such as macroeconomic analysis, Manager analysis, fundamental analysis, charting and technical analysis. Manager Analysis: In this type of analysis, we compare managers in the same asset categories based on extensive criteria (e.g., performance, length of time in business, risk attributes, costs etc.) in an attempt to identify a manager that we feel will help us meet our client’s investment objectives. Fundamental Analysis. We may attempt to measure the intrinsic value of a security or mutual fund by looking at economic and financial factors (including the overall economy, industry conditions, and valuation measures) to determine if the investment is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors. Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in poorly managed or financially unsound companies that may underperform regardless of market movement. Charting. In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict how long the trend may last and when that trend might reverse. Investment Strategies The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. We may use one or more of the following investment strategies when providing investment advice to you: • 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. • 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. 13  • Margins Transactions - borrowing money from a broker to purchase stock. The collateral for the loan is normally securities in the investor's account. • Option Strategies - buying or selling of one or more options that differ in one or more of the options' variables. We generally intend to use these for hedging purposes to reduce portfolio risk. Risk of Loss, Disclosures, and other important information There are inherent risks involved for each investment strategy or method of analysis we use and the particular type of security we recommend. Investing in securities involves the risk of loss, which clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease, and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market and ask our firm any questions you may have. The value of your investment may be affected by one or more of the following risks, any of which could cause the portfolio’s return or the portfolio’s yield to fluctuate: Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Factors such as domestic and international economic growth and market conditions, interest rate levels, and political events affect the securities markets. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad times. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Company Size Risks: Generally, the smaller the market capitalization of a company, the fewer the number of shares traded daily, the less liquid its stock and the more volatile its price. Companies with smaller market capitalizations also tend to have unproven track records. These factors also increase risks and make these companies more likely to fail 14  than companies with larger market capitalizations. Foreign Investing Risks: Investments in foreign companies and markets carry a number of economic, financial, and political considerations that are not associated with the U.S. markets and that could unfavorably affect account performance. Among those risks are greater price volatility; weak supervision and regulation of securities exchanges, brokers and issuers; higher brokerage costs; fluctuations in foreign currency exchange rates and related conversion costs; adverse tax consequences; and settlement delays. Fixed Income Securities: Client accounts with all or a portion of the underlying assets invested in fixed income securities are subject to the following risks: Interest Rate Risks: Prices of fixed income securities rise and fall in response to changes in the interest rate paid by similar securities. Generally, when interest rates rise, prices of fixed income securities fall. Interest rate changes have a greater effect on the price of fixed income securities with longer maturities. Credit Risks: Credit risk is the possibility that an issuer or counterparty will default on a security or repurchase agreement by failing to pay interest or principal when due. If an issuer defaults, the value of a fixed income security may decrease. Lower credit ratings correspond to higher credit risk. Bonds rated below BBB or Baa have speculative characteristics. Call Risks: If the fixed income securities are redeemed by the issuer before maturity (or “called”), the fund may have to reinvest the proceeds in securities that pay a lower interest rate, which may decrease the portfolio’s overall yield. This will most likely happen when interest rates are declining. Liquidity Risks: Liquidity risk refers to the possibility that an investor may not be able to sell or buy a security or close out an investment contract at a favorable price or time. Consequently, an investor may have to accept a lower price to sell a security, sell other securities to raise cash or give up an investment opportunity, any of which could have a negative effect on investment performance. Infrequent trading of securities also may lead to an increase in their price volatility. ETF and Mutual Funds Risk: ETFs and mutual funds are subject to investment advisory and other expenses, which will be indirectly paid by clients. As a result, the cost of our investment strategies will be higher than the cost of investing directly in ETFs or mutual funds, as there are two levels of fees. ETFs and mutual funds are subject to specific risks, depending on the nature of the fund. ETFs are professionally managed pooled vehicles that invest in stocks, bonds, cryptocurrencies, short-term money market instruments, other mutual funds, other 15  securities, or any combination thereof. ETF managers trade fund investments in accordance with fund investment objectives. ETF risk can be significantly increased for funds concentrated in a particular sector of the market, or that primarily invest in small cap or speculative companies, use leverage (i.e., borrow money) to a significant degree, or concentrate in a particular type of security (i.e., equities), rather than balancing the fund with different types of securities. ETFs can be bought and sold throughout the day like stocks, and their price can fluctuate throughout the day. During times of extreme market volatility, ETF pricing may lag versus the actual underlying asset values. This lag usually resolves itself in a short period of time (usually less than one day); however, there is no guarantee this relationship will always occur. Government Obligations Risks: No assurance can be given that the United States government will provide financial support to United States government-sponsored agencies or instrumentalities where it is not obligated to do so by law. As a result, there is the risk that these entities will default on a financial obligation. High Yield Securities Risks: High yield securities tend to be more sensitive to economic conditions than are higher-rated securities and generally involve more credit risk than securities in the higher-rated categories. The risk of loss due to default by an issuer of high yield securities is significantly greater than issuers of higher-rated securities because such securities are generally unsecured and are often subordinated to other creditors. Management Risk: The adviser’s strategy may fail to produce the intended results. Firm Research: When our research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, the firm is relying on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. We make every effort to determine the accuracy of the information received but it cannot predict the outcome of events or actions taken or not taken, or the validity of all information it has researched or provided, which may or may not affect the advice on or investment management of an account. Defensive Risk: To the extent that the strategy attempts to hedge its portfolio stocks or takes defensive measures, such as holding a significant portion of its assets in cash or cash equivalents, the objective may not be achieved. Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses for non-wrap fee clients and may result in the distribution of additional capital gains for tax purposes. These factors may negatively 16  affect the account’s performance. Availability of Information: Certain issuers, including municipalities, private companies, and foreign issuers may not be subject to the same disclosure, accounting, auditing, and financial reporting standards, and practices as companies publicly listed in U.S. stock markets. Thus, there may be less information publicly available about these issuers and their current financial condition. ‐ Concentration Risk: To the extent that the strategy focuses on particular asset classes, countries, regions, industries, sectors, or types of investment from time to time, the strategy may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. Private Equity Counterparty Risk: Investments in private equity involve the risk that the portfolio company in which the investments are made may not be able to achieve its objectives or meet its obligations. Legal and Regulatory Matters Risks: Legal developments which may adversely impact investing and investment-related activities can occur at any time. “Legal Developments” means changes and other developments concerning foreign, as well as U.S. federal, state and local laws and regulations, including adoption of new laws and regulations, amendment or repeal of existing laws and regulations, and changes in enforcement or interpretation of existing laws and regulations by governmental regulatory authorities and self-regulatory organizations (such as the SEC, the Commodity Futures Trading Commission, the Internal Revenue Service, the Federal Reserve and the Financial Industry Regulatory Authority). Our management of accounts may be adversely affected by the legal and/or regulatory consequences of transactions effected for the accounts. Accounts may also be adversely affected by changes in the enforcement or interpretation of existing statutes and rules by governmental regulatory authorities or self-regulatory organizations. System Failures and Reliance on Technology Risks: Our investment strategies, operations, research, communications, risk management, and back-office systems rely on technology, including hardware, software, telecommunications, internet-based platforms, and other electronic systems. Additionally, parts of the technology used are provided by third parties and are, therefore, beyond our direct control. We seek to ensure adequate backups of hardware, software, telecommunications, internet-based platforms, and other electronic systems, when possible, but there is no guarantee that our efforts will be successful. In addition, natural disasters, power interruptions and other events may cause system failures, which will require the use of backup systems (both on- and off-site). Backup systems may not operate as well as the systems that they back up and may fail to properly operate, especially when used for an extended period. To reduce the 17  impact a system failure may have, we continually evaluate our backup and disaster recovery systems and perform periodic checks on the backup systems’ conditions and operations. Despite our monitoring, hardware, telecommunications, or other electronic systems malfunctions may be unavoidable, and result in consequences such as the inability to trade for or monitor client accounts and portfolios. If such circumstances arise, the Investment Committee will consider appropriate measures for clients. Cybersecurity Risk: A portfolio is susceptible to operational and information security risks due to the increased use of the internet. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include, but are not limited to, infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks, or devices through “hacking” or other means for the purpose of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches by third-party service providers may cause disruptions and impact on service providers’ and our business operations, potentially resulting in financial losses, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement, or other compensation costs, and/or additional compliance costs. While we have established business continuity plans and risk management systems designed to prevent or reduce the impact of such cyberattacks, there are inherent limitations in such plans and systems due in part to the everchanging nature of technology and cyberattack tactics. Pandemic Risks: The novel coronavirus rapidly became a pandemic and resulted in disruptions to the economies of many nations, individual companies, and the markets in general, the impact of which was material. This created closed borders, quarantines, supply chain disruptions and general anxiety, negatively impacting global markets in an unforeseeable manner. The impact of the novel coronavirus and other such future infectious diseases in certain regions or countries may be greater or less due to the nature or level of their public health response or due to other factors. Health crises caused by the coronavirus outbreak and future infectious diseases may exacerbate other pre-existing political, social, and economic risks in certain countries. The impact of such health crises may be quick, severe and of unknown duration. These pandemics and other epidemics and pandemics that may arise in the future could result in continued volatility in the financial markets and could have a negative impact on investment performance. Emerging Technology: From time to time, we will use emerging technologies, such as artificial intelligence (“AI”), as a complement to operational and investment research processes. We can also invest in companies developing or leveraging emerging technology. Emerging technology and AI are wide-ranging terms and include a broad spectrum of technologies and applications, such as machine learning, deep learning, neural networks, and natural language processing, that are quickly evolving. Such 18  emerging technology and AI present unique risks. For example, the automation of tasks previously performed by humans can potentially lead to job displacement and economic disruption. Data privacy concerns arise when AI systems collect and analyze vast amounts of personal data, which can be misused or inadequately protected. Additionally, the rapid development of these technologies often outpaces the creation of appropriate regulations, resulting in ethical challenges such as bias in AI algorithms and the potential for misuse in surveillance, investment decisions or other biases. New security vulnerabilities can also emerge as AI tools are developed, making systems potentially more susceptible to cyberattacks when using emerging AI technologies. We will rebalance your portfolio periodically to control risk, take profits and enhance tax efficiency. We will reduce or eliminate positions due to lack of performance, to achieve certain tax benefits, to capture profits and to tactically re-allocate holdings. While we seek to take advantage of investment opportunities for our clients that will seek to balance investment returns with the risk of loss, there is no guarantee that such opportunities will ultimately benefit our client. We will change client portfolios in response to market conditions that are unpredictable and may expose our client to greater market risk than seen in previous market cycles. There is no assurance that our investment strategy will enable our client to achieve the stated investment objectives of our strategies. The above list of risk factors does not claim to be a complete list or explanation of the risks involved in an investment strategy. There are many other circumstances not described here that could adversely affect your investment and prevent you from your investment objectives. The list represents the typical risks involved. The explanation of certain risks is not exhaustive but rather highlights some of the more significant risks involved in our investment strategies. You are encouraged to consult your IAR and tax professional on an initial and continuous basis in connection with selecting and engaging in the services provided by us. In addition, due to the dynamic nature of investments and markets, strategies may be subject to additional and different risk factors not discussed above. Item 9 – Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. We do not have any legal or disciplinary events to report. 19  Item 10 – Other Financial Industry Activities and Affiliations We are not, nor are any of our management persons (except as disclosed below), registered, nor do we have an application pending to register as a broker-dealer or a registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor or as an associated person of the foregoing entities. In addition, neither we nor any of our management persons have any arrangement that is material to our advisory business or to our clients that we or any of our management persons have with any related person that is under common control and ownership, i.e., a: ● Municipal securities dealer, or government securities dealer or broker, ● Investment company or other pooled investment vehicle, ● Other investment adviser or financial planner, ● Futures commission merchant (or commodity pool operator or commodity trading advisor), ● Banking or thrift institution, ● Accountant or accounting firm, ● Lawyer or law firm, ● Insurance company or agency, ● Pension consultant, ● Real estate broker or dealer, or ● Sponsor or syndicator of limited partnerships. However, Roberto Vainrub sits on the board as a director of Mercantil Banco Universal and his duties include board meetings and the risk committee where he spends approximately on average 10 hours per month. AV Securities, Inc. & AV Asset Management, Inc. Mr. Vainrub is a passive investor/owner of AV Securities, Inc. (“AV Securities”). AV Securities is a licensed Panama Broker-Dealer that provides investment advice, securities analysis, and research services to its clients. In addition, Marcel Apeloig (a 20  client of EWA), Alan Rotter (a client of EWA), Antonino Ciulla (a client of EWA) and Alfonso Angrisano, each of whom are minority/passive owners of EWA, are also partners at AV Securities. Furthermore, Messrs. Angrisano and Ciulla own AV Aset Management, which is under common control with AV Securities. Messrs. Apeloig, Angrisano, Ciulla and Rotter do not provide investment advice and will not have control over the day-to-day management of EWA. • AV Asset Management provides research services to EWA and, indirectly, EWA’s advisory clients. EWA compensates AV Asset Management for its research. As owners of AV Asset Management, Messrs. Angrisano and Ciulla indirectly benefit from the compensation received from EWA. A conflict of interest exists in that the choice of EWA’s research vendor may be driven more by the compensation potential to Messrs. Angrisano and Ciulla than the merits of the research vendor’s research services. • EWA also provides advisory services to AV Securities under a consulting agreement. • Additionally, AV Securities and EWA have entered into a promoter agreement whereby AV Securities agreed to recommend EWA’s investment advisory services to potential clients. AV Securities also agreed to periodically contact referred clients for the purpose of assisting them in understanding EWA’s services and, if necessary, to update their information and provide it to EWA. In exchange for these services, EWA pays AV Securities a referral fee. A conflict of interest exists in that Messrs. Vainrub, Apeloig, Angrisano, Ciulla and Rotter would indirectly benefit from the fees paid to AV Securities due to their ownership interests in AV Securities. • Finally, one client has provided a limited power attorney for us to manage his account at AV Securities. EWA does not encourage or discourage its clients to use AV Securities as a qualified custodian. EWA and its affiliated individuals recognize their fiduciary responsibilities to clients and EWA has implemented a Compliance Program to address potential conflicts of interest. This program includes oversight to ensure adherence to client investment objectives, a fair allocation policy to ensure equitable distribution of investment opportunities, and to monitor and mitigate conflicts. By maintaining periodic compliance reviews transparency and oversight, EWA believes it upholds its duty to act in the best interests of all clients, independent of its affiliations with AV Securities and AV Asset Management. 21  Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Code of Ethics adopted and implemented by EWA applies to the activities of our Company. All employees of EWA are subject to this Code of Ethics. In carrying on its daily affairs, EWA, and all of our supervised persons2 shall act in a fair, lawful and ethical manner, in accordance with the rules and regulations imposed by our governing regulatory authority. The Code of Ethics sets forth standards of conduct and requires compliance with applicable state and federal securities laws. Our Code of Ethics also addresses personal trading and requires our personnel to report their personal securities holdings and transactions to our Chief Compliance Officer (“CCO”). We have created a Code of Ethics which establishes standards and procedures for the detection and prevention of certain conflicts of interest including activities by which persons having knowledge of the investments and investment intentions of EWA, its affiliates, or clients, might take advantage of that knowledge for their own benefit. EWA has in place Ethics Rules (the “Rules”), which are comprised of the Code of Ethics and Insider Trading policies and procedures. The Rules are designed to ensure that EWA’s personnel (i) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in the performance of their duties; (ii) to act in the EWA’s clients’ best interest at all times; (iii) disclose all conflicts of interest; (iv) adhere to the highest standards of loyalty, candor and care in all matters relating to its clients; (v) conduct all personal trading consistent with the Rules and in such a manner as to mitigate any conflicts of interest or any abuse of their position of trust and responsibility; and (vi) not use any material non-public information in securities trading. The Rules also establish policies regarding other matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio holdings information. Under the general prohibitions of the Rules, EWA’s personnel are prohibited from: 1) effecting securities transactions while in the possession of material, non-public information; 2) disclosing such information to others; 3) participating in fraudulent conduct involving securities held or to be acquired by any client; and 4) engaging in frequent trading activities that create or may create a conflict of interest, limit their ability to perform their job duties, or violate any provision of the Rules. 2 Supervised person means any partner, officer, director (or other person occupying a similar status or performing similar functions), or employee of an investment adviser, or other person who provides investment advice on behalf of the investment adviser and is subject to the supervision and control of the investment adviser. 22  We will provide you a copy of our Code of Ethics upon request. To request a copy, you can contact us at the address or telephone number listed on the cover page of this brochure, Attn: Chief Compliance Officer. Personal Trading Under the Code, EWA’s personnel are required to conduct their personal investment activities in a manner that EWA believes is not detrimental to its advisory clients. As discussed above, EWA personnel must conduct all personal trading in such a manner to mitigate any conflicts of interest or any abuse of their position of trust and responsibility. EWA and/or its employees buy, sell, or hold securities it also recommends to clients, subject to the requirements of its internal policies and procedures. EWA’s policies are based on the principle that EWA and its employees have a fiduciary duty to place the interests of clients ahead of their own interests. To the extent not prohibited by its policies, EWA and/or its employees hold, acquire, increase, decrease or dispose of securities or other interests at or about the same time that EWA is purchasing or selling the same securities or interests for an advisory account. EWA manages discretionary accounts on behalf of its owners, employees, and family members. EWA has created and implemented internal controls to monitor client account activity and proper allocation of investment opportunities, based on each client’s stated investment objectives and risk tolerance, to address these conflicts. Participation or Interest in Client Transactions We do not execute transactions on a principal or agency cross basis. Donations to Charities EWA makes donations to charitable organizations that are affiliated with or supported by its clients or individuals employed by its clients. Additionally, EWA waives fees for nonprofits for whom we manage accounts. In general, such donations are made in response to requests from clients, or their personnel. Because EWA’s contributions may result in the recommendation of EWA’s services or its products, such contributions may raise a potential conflict of interest. No contribution will be made if the contribution implies that continued or future business with EWA depends on making such contribution. 23  Item 12 – Brokerage Practices Broker-Dealer/Custodian Recommendations In selecting or recommending a broker-dealer, we will consider the value of research and additional brokerage products and services a broker-dealer has provided or will provide to our clients and us. We recommend or require that clients establish brokerage accounts with FINRA-registered broker-dealers, SIPC members (collectively, “custodians”) through which the custodians provide our firm with their "platform" services. The platform services can include, among others, brokerage, custodial, administrative support, record keeping and related services such as maintaining custody of clients’ assets and effecting trades for the client’s account(s). We receive benefits by selecting such custodians to execute client transactions, and the transaction compensation charged by such custodians might not be the lowest compensation we might otherwise be able to negotiate. We have not entered into a formal soft dollar arrangement, whereby, we are required to direct a certain amount of transaction activity to such custodians for specific research or brokerage services, but certain services are available to us at no charge to us so long as our clients’ assets are maintained in accounts at such custodians. These custodians’ primary brokerage services include the execution of securities transactions, custody, research, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. In addition, these custodians have negotiated with certain third-party vendors for such vendors to offer advisors that custody at such custodians a discount for their services or such custodians may pay directly for such services on our behalf. These custodians make available to us other products and services that benefit us but may not directly benefit all of its clients’ accounts or may benefit accounts not maintained at such custodians. These custodians’ products and services that assist us in managing and administering clients’ accounts may include, but not be limited to, software and other technology that (i) provide access to client account data (such as trade confirmations and account statements); (ii) facilitate trade execution and allocate aggregated trade orders for multiple client accounts; (iii) provide research, pricing and other market data; (iv) facilitate payment of our fees from its clients’ accounts; and (v) assist with back-office functions, recordkeeping and client reporting. These custodians also offer other services intended to help us manage and further develop its business enterprise. These services may include, but are not limited, to: (i) compliance, legal and business consulting; (ii) publications and conferences on practice management and business succession; and (iii) access to employee benefits providers, human capital consultants and insurance providers. These custodians may also provide other benefits such as educational events or occasional business entertainment for our personnel. 24  In evaluating whether to recommend or require that client’s custody their assets at such custodians, we take into account the availability of the foregoing products and services and other arrangements as part of the total mix of factors it considers and not solely the nature, cost or quality of custody and brokerage services provided by such custodians. Clients should be aware that the receipt of such economic benefits by us or its related persons in and of itself creates a potential conflict of interest and may indirectly influence our choice of such custodians for custody and brokerage services. To address these potential conflicts of interest, we have developed and implemented a Compliance Program, which includes a review of the services and execution quality we receive from such custodians. Schwab Advisor ServicesTM Platform We do not maintain custody of your assets that we manage or on which we advise (although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15 - Custody, below)). Your assets must be maintained in an account at a "qualified custodian," generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co" Inc. ("Schwab"), a FINRA- registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and operated and not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. For accounts below $10,000,000, we will encourage you to use Schwab as custodian/broker. You will decide whether to do so and open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you, but we will assist you in the process. [If you do not wish to place your assets with Schwab, then we might decline to manage your account.] Not all advisors require their clients to use a particular broker-dealer or other custodian selected by the advisor. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account, as described in the next paragraph. Products and Services Available to Us from our Custodians Our custodians provide our clients and us with access to its institutional brokerage-- trading, custody, reporting, and related services--many of which are not typically available to retail customers. Our custodians also make available various support services. Some of those services help us manage or administer our clients' accounts, while others help us manage and grow our business. 25  Here is a more detailed description of typical support services: Services That Benefit You Institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through our custodians include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. The services described in this paragraph generally benefit you and your account. Services That May Not Directly Benefit You Our custodians also make available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients' accounts. They include investment research, both the custodian's own and that of third parties. We may use this research to service all or some substantial number of our clients' accounts, including accounts not maintained at a particular custodian. In addition to investment research, they also may make available software and other technology that:  provide access to client account data (such as duplicate trade confirmations and  account statements) facilitate trade execution and allocate aggregated trade orders or multiple client accounts, facilitate payment of our fees from our clients' accounts, and  provide pricing and other market data,   assist with back-office functions, recordkeeping, and client reporting. Services That Generally Benefit Only Us Our custodians may also offer other services intended to help us manage and further develop our business enterprise. These services include: technology, compliance, legal, and business consulting,  educational conferences and events,   publications and conferences on practice management and business succession, and  access to employee benefits providers, human capital consultants, and insurance providers. Depending on the custodian, they may provide some of these services themselves. In other cases, they will arrange for third-party vendors to provide the services to us. A particular custodian may also discount or waive its fees for some of these services or 26  pay all or a part of a third-party's fees. In addition, they also provide us with other benefits such as occasional business entertainment for our personnel. Soft Dollars 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”) that we would consider a factor in utilizing a particular broker-dealer. However, through our relationship with any custodian, we can receive certain services and products, such as fundamental research reports, technical and portfolio analyses, pricing services, economic forecasting and general market information, historical data base information and computer software that assist with our investment management process. We may give preference to broker-dealers that provide research or other services to EWA so long as we believe the objective of best execution is not being sacrificed. These research services provide a benefit to us since we do not have to produce or pay for the services. EWA may have an incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services rather than on our clients’ interest in receiving the most favorable execution. Research services may include: 1. Advice, directly or through publications, writings, or data services, as to the value of securities and the advisability of investing in, purchasing, or selling securities and 2. The availability of securities, economic factors and trends, portfolio strategy. Thus, we may be able to supplement our own information and consider the views and information of other organizations in arriving at our investment decisions. Generally, research services are generated by third parties but are provided to EWA through broker- dealers. Brokerage for Client Referrals We do not consider, in selecting or recommending broker-dealers, whether we or a related person receive client referrals from a broker-dealer or third party. Directed Brokerage A client may direct us, in writing, to use a particular broker-dealer. In that case, it is our expectation that the client will negotiate execution terms with the broker-dealer. Should a client request that we direct execution for brokerage transactions for their account through a broker-dealer that we believe will provide reasonable service, we shall direct transactions accordingly. Such broker-dealers must enter into a prime broker agreement 27  with our firm. In such cases, we will not seek better execution services or prices from other broker-dealers or be able to “aggregate” or “batch” orders for execution through another broker-dealer. As a result, the client may pay a higher commission or other transaction costs or greater spreads, or receive less favorable net prices, on transactions than would otherwise have been the case. Clients who request directed trades may or may not receive best execution or pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs or otherwise negotiate commissions and may also receive less favorable prices and execution. As a result, we will not provide assurances that in accounts where we are instructed to direct trades that best execution will be obtained. Trade Aggregation When EWA deems it appropriate and the custodian Schwab, IBKR and StoneX allows us, EWA will aggregate the securities to be sold or purchased to obtain the most- favorable price or lower brokerage commission and efficient execution (including speed of execution and confidentiality of trades). The allocation of the securities purchased or sold, as well as the expenses incurred in the transaction, will be made by EWA in accordance with its pre-allocation policy in the manner it considers to be most equitable and consistent with its fiduciary obligations to clients. No client or account will be favored over another. Administrative Trade Errors From time-to-time we may make an error in submitting a trade order on your behalf. Trading errors include a number of situations, such as: ● The wrong security is bought or sold for a client, ● A security is bought instead of sold, or vice versa ● A transaction is executed for the wrong account, ● Securities transactions are completed for a client that had a restriction on such security, or ● Securities are allocated to the wrong accounts. When this occurs, we will place a correcting trade with the broker-dealer which has custody of your account. For errors with a gain of less than $500, Schwab will donate it (combined with other advisor trade error gains Schwab retains) to the Charles Schwab Foundation on a monthly basis. De minimis gains under $100 will be retained by Schwab to minimize and offset its own administrative time and expense to process advisor trade errors. 28  For de minimis losses of less than $100, Schwab will absorb the loss to avoid the additional expense and burden of processing small errors. Note: To limit the respective administrative expenses and burden of processing small trade errors, it should be noted that some custodians (at their own discretion) may elect not to invoice us if the trade error involves a de minimus dollar amount (usually less than $100). Generally, if related trade errors result in both gains and losses in your account, they may be netted. Item 13 – Review of Accounts Reviews and Reviewers of the Accounts Client accounts will be reviewed, at a minimum, once a year. Model portfolios are reviewed quarterly and if there are changes to the model portfolio, they will normally be executed within a month (depending on market conditions). In addition, client accounts will be reviewed within one month of receiving additional cash or assets into the client’s account. Each IAR works directly with clients to provide ongoing investment dialogue to regularly review investment approach and objectives as well as market insights. Accounts are reviewed with clients annually or as needed by each client. In addition, all accounts are reviewed annually by their IAR to ensure that they are meeting the clients’ investment objectives. The review covers evaluation of the account’s asset allocation against the recommended allocation for that particular investment objective. The process also includes evaluation of the account’s performance against benchmarks of similar investment objectives. We will discuss your current financial status, risk tolerance, and investment objectives and goals to determine whether adjustments are required to your current asset allocation and account holdings. Changes in macroeconomic and company specific events may trigger additional reviews. Nature and Frequency of Regular Reports Provided to Clients on their Accounts For all accounts, clients receive statements from the custodian, at least quarterly, with their account details of holdings, market value, and allocation of asset class. Clients who request access can review their accounts at any time through the custodian’s web portal. In addition, clients receive a detailed report during annual in-person (virtual meeting or phone) reviews with the IAR. During these reviews, the IAR discusses a range of topics related to clients’ financial needs/goals, economic and market conditions, personal tax- related investment items such as gains/losses as well as overall performance. 29  Item 14 – Client Referrals and Other Compensation Client Referrals EWA compensates third parties for client referrals. Such referral arrangements are governed by a written agreement between EWA and the particular third party (i.e., the promoter). EWA pays the promoter a portion of the fee paid by each client they refer to EWA who invests with us. This fee can range from 10% to 65% of the fee paid to EWA by the client. We do not charge higher fees to clients who were referred by a promoter than the fees charged to clients with similar portfolios managed by EWA who were not introduced by a third-party promoter. Third-party promoters who refer clients to us will provide you with a copy of our Form ADV Part 2A and will disclose to you their relationship with us, whether they receive compensation for the referral, and any material conflicts of interest. Additionally, we will enter into arrangements whereby from time to time we receive compensation, either directly or indirectly, from unaffiliated persons for client referrals. Under such arrangements, we receive a percentage of the investment advisory fee paid by such client. This fee may vary according to each agreement. Referred clients will receive a copy of this Disclosure Brochure along with disclosure (either orally or in writing) of the terms of the referral arrangement and any conflicts of interest related to the arrangement at the time of the referral. Referral arrangements are entered into in accordance with Advisers Act Rule 206(4)-1. Promoters that refer business to more than one investment adviser may have a financial incentive to recommend advisers with more favorable compensation arrangements. We will disclose to you whether multiple referral relationships exist, and those comparable services may be available from other advisers. Referral fees paid to a Promoter are contingent upon your entering into an advisory agreement. This creates a conflict of interest given that the Promoter has a financial incentive to recommend such services. However, you are not obligated to retain such advisory services. Comparable services and/or lower fees may be available through other firms. In addition, we have implemented a compliance program to monitor such conflicts, and our relationships are periodically reviewed. 30  Other Compensation We do not receive an economic benefit (other than the custodial services identified in Item 12), including sales awards or other prizes from a non-client for providing investment advice or other advisory services to our clients. As disclosed in Item 5, when EWA recommends investments in Private Funds, EWA charges a management fee and might also receive a portion of the performance/carried interest fee charged by the Fund Manager. This presents a conflict of interest in that EWA may receive compensation through the Fund Manager that is in addition to the management or consulting fee that is charged by EWA. EWA will charge a management or consulting fee on the Private Fund assets. The calculation of the management or consulting fee is disclosed in Item 5 above. In addition, EWA’s commitment to its clients, and the policies and procedures it has adopted that require the review of such arrangements by the CCO, are designed to limit any interference with EWA’s independent decision making when choosing the best investments for our clients. Refer to Items 5, 10, and 12 above for details of our compensation structure as well as any other compensation our IARs may receive. Item 15 – Custody We do not take physical possession of client funds or securities. Under government regulations, we are deemed to have custody of your assets if you authorize us to instruct Schwab, IBKR and StoneX to deduct our advisory fees directly from your account. Schwab, IBKR and StoneX maintain actual custody of your assets. However, we are also deemed to have custody of clients’ funds or securities when clients have standing letters of authorizations (“SLOAs”) with their custodian to move money from a client’s account to a third-party, and under that SLOA it authorizes us to designate the amount or timing of transfers with the custodian. The SEC has set forth a set of standards intended to protect client assets in such situations, which we follow. You will receive account statements directly from your custodian at least quarterly. The account statements will reveal the funds and securities held with the qualified custodian, any transactions that occurred in your account, and the deduction of our fee. They will be sent to the email or postal mailing address you provided to your custodian. For the wrap fee program, upon written consent from you, we will have the authority to deduct the advisory fees from your accounts. The custodian will send to you an account statement at least quarterly identifying the amount of funds and each security in the account at the end of period and setting forth all transactions in the account during that period including the amount of advisory fees paid directly to our firm. 31  Upon your request, we will prepare and provide reports to you regarding your portfolio. You are encouraged to review these reports and compare them against reports received from the independent custodians that service your advisory account. You should immediately inform our firm of any discrepancy noted. Item 16 – Investment Discretion We accept discretionary authority to manage securities accounts on your behalf. Our authority is limited to determining which securities to buy or sell on your behalf, determining the number of securities to be bought or sold on your behalf, and determining the broker dealer to be used. In managing an investment portfolio, we act in a manner in keeping with what we understand and believe to be in your best interest. In making these buy and sell decisions, we follow general guidelines established by you which may include instructions to have our firm refrain from purchasing certain securities. Any restrictions must be submitted to our firm in writing. Item 17 – Voting Client Securities (i.e., Proxy Voting) EWA has accepted the responsibility to vote proxies on behalf of Schwab advisory clients under the Wrap Fee Program. A client has the option to retain proxy voting privileges on behalf of their own account provided they have indicated as such on the Investment Advisory Agreement or in writing to EWA. Should a client choose this option, then that client will receive proxies or other solicitations directly from their custodian; however, the client may contact EWA with questions regarding solicitations by calling the telephone number listed on the cover page. Responsibility for voting proxies on securities accounts held at custodians outside of Schwab remains with the client. Such clients will receive proxies and other solicitations directly from their custodian(s). When agreed between EWA and a Schwab client, EWA will vote proxies for voting securities held in a client’s account. Proxies will be voted in the best interest of EWA’s clients in accordance with EWA’s then-current Proxy Voting Policy (the “Policy”). EWA has retained an independent proxy voting service provider, Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to assist it in connection with voting client proxies. Broadridge relies on another third-party firm, Glass, Lewis & Co., for proxy vote research, guidelines, and vote recommendations. Absent a determination by EWA to 32  override the independent provider’s guidelines and/or recommendations, client proxies will be voted in accordance with those guidelines and/or recommendations. EWA’s Policy is available upon request, in electronic or hard copy form. Clients may obtain the Policy from EWA, as well as information about how EWA voted clients’ securities, by contacting EWA at lroditi@ewadvisors.net. EWA’s proxy voting procedures are designed to ensure that proxies are voted. Our voting guidelines have been designed to promote accountability of a company's management and board of directors to its shareholders; to align the interests of management with those of shareholders; and, to encourage companies to adopt best practices in terms of their corporate governance. Since EWA has engaged a third-party proxy service provider to assist with the voting of proxies, the CCO and investment management unit have the responsibility for oversight of the third-party proxy service provider and for ensuring that proxies are voted in the best interest of clients. In voting, EWA or the third party shall vote in a prudent and timely fashion and only after a careful evaluation of the issue(s) presented on the ballot. EWA has developed guidelines to vote the proxies. Prior to voting, EWA or the third-party service provider verifies whether a conflict of interest with EWA exists in connection with the subject proposal(s) to be voted upon. The determination regarding the presence or absence of any conflict of interest is documented. EWA relies on its third-party service provider to make and retain each proxy statement and a record of each vote cast. In the event EWA makes a determination to override the independent provider’s guidelines and/or recommendations, EWA will retain a record memorializing the basis for the vote cast and any other documentation which was material to the decision voted. Clients may request a copy of how securities in their account were voted by contacting EWA at the telephone number listed on the cover page. Class Actions Sometimes securities held in the accounts of clients will be the subject of class action lawsuits. EWA has engaged Broadridge to provide a comprehensive review of our Schwab Wrap Fee clients’ possible claims to a settlement throughout the class action lawsuit process. Broadridge actively seeks out any open and eligible class action lawsuits. Additionally, Broadridge files, monitors, and expedites the distribution of settlement proceeds in compliance with SEC guidelines on behalf of our clients. Broadridge 's filing fee is contingent upon the successful completion and distribution of the settlement proceeds from a class action lawsuit. In recognition of Broadridge’s services, they receive a percentage (typically 15%) of our clients’ share of the settlement 33  distribution. When EWA receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by clients, it will work to assist clients and Broadridge in the gathering of required information and submission of claims. Item 18 – Financial Information We have no financial condition that is reasonably likely to impair our ability to meet contractual commitments to you given that we do not have custody of client funds or securities, nor do we require or solicit prepayment of fees in excess of $1,200 per client and six months or more in advance. In addition, we are not currently, nor have we been, at any time, the subject of a bankruptcy petition. Item 19 – Requirements for State-Registered Advisers We are an SEC-registered investment adviser; so, this section does not apply. 34 

ADV Part 2A Appendix 1 / Wrap Brochure Item 1 – Cover Page Evolution Wealth Advisors, LLC also known as EWA 20900 NE 30th Avenue, Suite 517 Aventura, FL 33180 (305) 921-4740 www.ewadvisors.net March 2026 This Wrap Fee program brochure provides information about the qualifications and business practices of Evolution Wealth Advisors, LLC (“EWA”, the “Company”, “us”, “we”, “our”). If you (“client”, “your”) have any questions about the contents of this brochure, please contact us at the number listed above. The information in this Wrap Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. EWA’s IARD firm number is 285142.  We are a registered investment adviser. Our registration as an investment adviser does not imply any level of skill or training. Additional information about EWA is available on the SEC’s website at www.adviserinfo.sec.gov (click on the link, select “Investment Adviser Search” and type in our firm name). The results will provide you with both Parts 1 and 2 of our Form ADV. 2  Item 2 – Material Changes Since the filing of our last annual updating amendment of Form ADV Part 2A Appendix 1 (“Wrap Brochure”), dated March 2025, there have been no material changes to note in this current Wrap Brochure. We have made the following changes: • Item 8 – We have added Legal and Regulatory Matters risks, System Failures and Reliance on Technology risks, Cybersecurity risk, Pandemic risks and Emerging Technology (e.g., Artificial Intelligence) risks. Additionally, we have made other changes that we do not consider material, solely to clarify or enhance existing disclosures. For future filings, this section of the Wrap Brochure will address only those “material changes” that have been incorporated since our last delivery or posting of this document on the SEC’s public disclosure website (IAPD) at www.adviserinfo.sec.gov. We will periodically update this Wrap Brochure and send you a copy that includes a summary of material changes. These changes may be communicated either by electronic means (email) or by mail. If you would like another copy of this Wrap Brochure, please download it from the SEC website as indicated above or contact our Chief Compliance Officer, Luciana Roditi at the number listed on this cover page or via email at lroditi@ewadvisors.net. 3  Item 3 – Table of Contents Item 1 – Cover Page .................................................................................................................................. 1 Item 2 – Material Changes ........................................................................................................................ 3 Item 3 – Table of Contents ....................................................................................................................... 4 Item 4 – Services, Fees and Compensation .......................................................................................... 5 Item 5 – Account Requirements and Types of Clients ....................................................................... 11 Item 6 – Portfolio Manager Selection and Evaluation ........................................................................ 12 Item 7 – Client Information Provided to Portfolio Managers .............................................................. 22 Item 8 – Client Contact with Portfolio Managers ................................................................................. 23 Item 9 – Additional Information .............................................................................................................. 24 Item 10 – Requirements for State-Registered Advisers ..................................................................... 31 4  Item 4 – Services, Fees and Compensation Evolution Wealth Advisors, LLC, also known as EWA, is a limited liability company organized under the laws of the State of Florida since July 28, 2016. EWA is principally owned by Roberto Vainrub through the Roberto Vainrub Revocable Trust, Alan Rotter through the Alan Rotter Revocable Trust, Marcel Apeloig through the MAHR Trust Alfonso Angrisano, Antonino Ciulla and Michael Marciano. We have been registered as an investment adviser with the SEC since September 8, 2017, and notice filed in applicable States in order to provide the investment advisory services as described within this document. As of December 31, 2025, our assets under management totaled: Discretionary Managed Accounts: ................ $1,325,111,147 Non-Discretionary Managed Accounts:............. $632,817,734 Assets Under Advisement1: ........................... $3,399,547,884 Total: .............................................................. $5,357,476,765 Individuals associated with EWA will provide investment advisory services on our behalf. Such individuals are known as Investment Advisor Representatives (“IARs”). We require IARs to be engaged in determining or offering investment advice to clients to be properly licensed and registered in the states, unless exempted, in which they provide investment advisory services. Below is a description of the services we offer. Please reference your Wrap Advisory Agreement (“WAA”) for more details or contact your IAR. We offer advisory services through a Wrap Fee Program (“Program”) administered by our custodian Charles Schwab & Co., Inc. (“Schwab”), StoneX Financial, Inc. (“StoneX”) and IBKR Securities Services, LLC (“IBKR”). The Program provides discretionary asset management services for a convenient, single fee that includes account management, brokerage, clearing, custody, and administrative services. 1 Assets under advisement represent assets in which we provide consulting and/or consolidation services and for which we have neither discretionary authority nor responsibility for arranging or effecting the purchase or sale of recommendations provided to and accepted by the ultimate client. Inclusion of these assets will make our total assets number different from assets under management disclosed in Item 5.F of our Form ADV Part 1A due to specific calculation instructions for Regulatory Assets Under Management. 5  The IAR will collect Personal Information from the client to determine client eligibility for the Program and for the investment strategy and allocation(s) the client selects. Wrap Fee Program Fee Schedule The annual fee charged for all discretionary advisory services under our Wrap Fee Program will be a percentage of assets under management. The fees for domestic accounts will be as follows: Low Range $1,000,000 $2,000,001 $5,000,001 $10,000,001 High Range $2,000,000 $5,000,000 $10,000,000 and above Annual Fee 0.95% 0.90% 0.85% TBN* Illustrative Example Assets Quarterly Fee 0.23% $7,000,000 $2,000,000 $3,000,000 $2,000,000 $ 4,750 $ 6,750 $ 4,250 AUM 1st scalar 2nd scalar 3rd scalar 4th scalar Annual Fee Average 0.90% $ 19,000 $ 27,000 $ 17,000 TBN* TBN* $ 15,750 $ 63,000 TOTAL * To be negotiated The fees for international accounts will be as follows: Low Range $1,000,000 $2,000,001 $5,000,001 $10,000,001 High Range $2,000,000 $5,000,000 $10,000,000 and above Annual Fee 1.25% 0.90% 0.85% TBN* Illustrative Example Assets Quarterly Fee 0.23% $7,000,000 $2,000,000 $3,000,000 $2,000,000 $ 6,250 $ 6,750 $ 4,250 Annual Fee (Average) 0.99% $ 25,000 $ 27,000 $ 17,000 AUM 1st scalar 2nd scalar 3rd scalar 4th scalar TOTAL TBN* $ 17,250 TBN* $ 69,000 6  Grandfathered account will keep our previous fees. We generally work with clients who will invest with EWA over $1,000,000 in investable assets which can be reached within the first twelve (12) months of entering into the WAA. If after the first year the account is below our minimum amount, we will assess a minimum yearly fee of $9,500 for domestic accounts and $12,500 for international accounts paid quarterly in advance based on the WAA. EWA has (and reserves the right to) waived its minimum advisory fee for certain Clients’ 401K Plans, children’s 529 Plans, clients with a long history with the firm, etc. However, the decision to waive the minimum fee is ours and will not be a uniform decision in each case. As noted, factors such as the client’s history with the firm, as well as the time we feel will need to be devoted to the client are considered, among other factors. Fees are negotiable for relationships over $10 million. For Schwab and StoneX accounts, fees are payable quarterly in advance and computed based on the total market value of the portfolio at the end of previous quarter as computed by EWA. Fees are directly debited from the client’s account at the custodian. Lump sum contributions or withdrawals over $100,000 made within a calendar quarter will be prorated. Please note that the balance your fee is based on may not match the statement you receive from the custodian due to dividends, incoming contributions, outgoing withdrawals, settlement issues, etc. For IBKR, fees are payable quarterly in arrears at the last day of the quarter. The quarterly fee is calculated as the sum of fees computed at the end of each month, based on the month end market value, during the calendar quarter. The first quarterly payment of the Management Fee will be prorated to cover the period from the date the account is opened through the end of the calendar quarter. Thereafter, the Management Fee shall be calculated based upon the market value of the account as of the close of business on the last business day of each month of the calendar quarter and will be due and payable on the last business day of each calendar quarter. Limited Negotiability of Advisory Fees Although EWA has established the fee schedules disclosed above, we reserve the option to negotiate the fees on a client-by-client basis. Therefore, clients with similar assets under management and investment objectives may pay significantly higher or lower fees than other clients. In determining the fees, we will consider the facts, circumstances, and needs of the clients. We will also consider the complexity of the client, assets to be managed, anticipated future additional assets, related accounts, portfolio style, account composition, and reports to be provided, among other factors. We will provide the specific annual fee schedule in the contract between the adviser and each client. Certain 7  related client accounts will be grouped for the purpose of reaching the minimum account size requirements and determining the annual fee. We do not take physical possession of client funds or securities. Upon your written consent, fees are directly debited from your account(s) at the custodian. The custodian will send to you an account statement identifying the amount of funds and each security in your account at the end of the period and setting forth all transactions in the account during that period, including the amount of advisory fees paid directly to EWA. Only upon your request, we will prepare and provide to you reports regarding your portfolio. You are encouraged to review these reports and compare them against reports received from the independent custodians that service your account(s). You should immediately inform EWA of any discrepancy noted. The WAA may be terminated at any time by either party with thirty days written notice. A pro-rata refund will be made of all fees paid in advance of the accepted termination date. Full refunds will only be made in cases where cancellation occurs within five (5) business days of signing the WAA. Termination of the WAA will not affect (i) the validity of any action previously taken by us under the agreement; (ii) liabilities or obligations of the parties initiated before termination of the WAA; or (iii) your obligation to pay advisory fees (prorated through the date of termination). Any unearned portion of the fee will be refunded to the client as determined in accordance with the terms of WAA. Any refunds due to the client shall be made as soon as possible from receipt of notice of termination. For the purposes of this provision, a contract is considered entered into when all parties to the contract have signed the contract, or, in the case of an oral contract, otherwise signified their acceptance, any other provisions of this contract notwithstanding. Detailed information on the termination terms and fees can be found in the applicable WAA. Potential Conflicts of Interest We do not charge our clients higher advisory fees based on their trading activity, but you should be aware that we will have an incentive to limit our trading activities in their account(s) because we are charged on certain types of executed trades. Transactions in advisory program accounts are placed through the custodian as the executing broker-dealer. We receive compensation as a result of a client’s participation in the Program. Depending on, among other things, the size of the account, changes in its value over time, the ability to negotiate fees or commissions, and the number of transactions, the amount of this compensation may be more or less than what we would receive if the client participated 8  in other programs, or paid separately for investment advice, brokerage, and other services. Even though we believe the custodian fees are competitive, lower fees for similar services may be available from other sources. Because mutual funds pay advisory fees to their investment advisors, such fees are, therefore, indirectly charged to all holders of mutual fund shares. Clients with mutual funds in their portfolios are effectively paying us and the mutual fund advisor for the management of their assets. Clients who place mutual fund shares under our management are therefore subject to our direct management fee and the indirect management fee of the mutual fund advisor. Mutual Fund Internal Expenses Internal advisory fees and expenses are paid by the mutual fund companies to their fund advisers, and/or sub account sponsors. These internal expenses are further outlined in the Fund Companies’ Prospectuses. General Information on Advisory Programs and Fees All fees paid to us are separate and distinct from the fees and expenses charged by mutual funds to their shareholders. These fees and expenses are described in each fund’s prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. You could invest in a mutual fund directly, without our services. In that case, you would not receive the services we provide which are designed, among other things, to assist you in determining which mutual fund or funds are most appropriate to your financial condition, goals, and objectives. Accordingly, you should review both the fees charged by the funds and the fees we charge to fully understand the total amount of fees to pay and to thereby evaluate the advisory services being provided. Advisory recommendations are based on your financial situation at the time the services are provided and are based on financial information you disclose to us. You are advised that certain assumptions may be made with respect to interest and inflation rates and the use of past trends and performance of the market and economy. Past performance is in no way an indication of future performance. As your financial situation, goals, objectives, or needs change, you must notify us promptly. We will not have custody of any of your funds or securities, as a qualified and independent custodian will be used for these asset management services. The Wrap Fee Program may cost clients more or less than purchasing such services separately, depending on the frequency of trading in the client's accounts, commissions charged at other broker/dealers for similar products and fees charged for like services by 9  other broker/dealers and other factors. Under this Program, you will pay a single fee for investment advice and all transaction related costs associated with executing transactions (except for incidental costs such as wire fees or bank charges). The wrap fee also does not cover certain fees and expenses associated with investments in mutual funds, as discussed above. Other costs that may be assessed to you and that are not part of the wrap fee include fees for portfolio transactions executed away from Broker, dealer mark-ups, electronic fund and wire transfers, spreads paid to market-makers, dealer mark-ups, market maker spreads and exchange fees, among others. We may receive compensation or other benefits in addition to the wrap fee we receive from you and, therefore, we may have an incentive to engage in such transactions. This compensation may be more than what you would receive if you participated in other programs or paid separately for investment advice, brokerage, and other services. Therefore, we may have a financial incentive to recommend the Wrap Fee Program over other programs or services. We deliver the Form ADV Part 2 to the client before or at the time we enter into an investment advisory contract with you. If the appropriate disclosure brochure was not delivered to you at least 48 hours prior to you entering into any written or oral advisory contract with us, then you have the right to terminate the contract, without penalty, within five (5) business days after the date of execution. 10  Item 5 – Account Requirements and Types of Clients We offer investment advisory services to individuals, high net worth individuals, corporations or other business entities, and foundations. We generally work with clients who will invest with EWA $1,000,000 or more in investable assets which can be reached within the first twelve (12) months of entering into the WAA. If after the first year the account is below our minimum amount, we will assess a minimum yearly fee of $9,500 for domestic accounts and $12,500 for international accounts paid quarterly in advance based on the WAA. EWA has (and reserves the right to) waived its minimum advisory fee for certain Clients’ 401K Plans, children’s 529 Plans, clients with a long history with the firm, etc. However, the decision to waive the minimum fee is ours and will not be a uniform decision in each case. As noted, factors such as the client’s history with the firm, as well as the time we feel we will need to be devoted to the client are considered, among other factors. Minimum fees may be waived, increased, or reduced at the discretion of EWA. Fees are negotiable for relationships over $10 million. 11  Item 6 – Portfolio Manager Selection and Evaluation Our associated persons providing investment advice to you under the Program will be required to meet the specific state registration examination requirements, unless exempted, in order to provide such advice. Performance-Based Fees and Side-By-Side Management We do not charge performance-based fees (i.e., advisory fees based on a share of the capital gains or capital appreciation of the client’s assets), and therefore, we do not engage in side-by-side management. Our compensation structure is disclosed in detail in Item 4 above. Methods of Analysis, Investment Strategies and Risk of Loss Method of Analysis We use several different methods of analysis and sources of information when formulating investment strategies. In addition to our own research, our recommendations may also be obtained from research sources that include financial publications, research prepared by others, annual reports, prospectuses and other regulatory filings, company press releases and other sources. In formulating our investment advice and/or managing your assets, we employ different research methods such as macroeconomic analysis, Manager analysis, fundamental analysis, charting, and technical analysis. Manager Analysis: In this type of analysis, we compare managers in the same asset categories based on extensive criteria (e.g., performance, length of time in business, risk attributes, costs etc.) in an attempt to identify a manager that we feel will help us meet our client’s investment objectives. Fundamental Analysis. We may attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and valuation measures) to determine if the investment is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors. 12  Technical Analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in poorly managed or financially unsound companies that may underperform regardless of market movement. Charting. In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict how long the trend may last and when that trend might reverse. Investment Strategies The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. We may use one or more of the following investment strategies when providing investment advice to you: • 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. • 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. • Margins Transactions – borrowing money from a broker to purchase stock. The collateral for the loan is normally securities in the investor’s account. • Option Strategies – buying or selling of one or more options that differ in one or more of the options’ variables. We generally intend to use these for hedging purposes to reduce portfolio risk. Risk of Loss, Disclosures, and other important information There are inherent risks involved for each investment strategy or method of analysis we use and the particular type of security we recommend. Investing in securities involves the risk of loss, which clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease, and your account(s) could suffer a loss. It is important that you understand 13  the risks associated with investing in the stock market and ask our firm any questions you may have. The value of your investment may be affected by one or more of the following risks, any of which could cause the portfolio’s return or the portfolio’s yield to fluctuate: Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the operational success of the issuer’s operations or its financial condition. Factors such as domestic and international economic growth and market conditions, interest rate levels, and political events affect the securities markets. Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Company Size Risks: Generally, the smaller the market capitalization of a company, the fewer the number of shares traded daily, the less liquid its stock and the more volatile its price. Companies with smaller market capitalizations also tend to have unproven track records. These factors also increase risks and make these companies more likely to fail than companies with larger market capitalizations. Foreign Investing Risks: Investments in foreign companies and markets carry a number of economic, financial and political considerations that are not associated with the U.S. markets and that could unfavorably affect account performance. Among those risks are greater price volatility; weak supervision and regulation of securities exchanges, brokers, and issuers; higher brokerage costs; fluctuations in foreign currency exchange rates and related conversion costs; adverse tax consequences; and settlement delays. Fixed Income Securities: Client accounts with all or a portion of the underlying assets invested in fixed income securities are subject to the following risks: 14  Interest Rate Risks: Prices of fixed income securities rise and fall in response to changes in the interest rate paid by similar securities. Generally, when interest rates rise, prices of fixed income securities fall. Interest rate changes have a greater effect on the price of fixed income securities with longer maturities. Credit Risks: Credit risk is the possibility that an issuer or counterparty will default on a security or repurchase agreement by failing to pay interest or principal when due. If an issuer defaults, the value of a fixed income security may decrease. Lower credit ratings correspond to higher credit risk. Bonds rated below BBB or Baa have speculative characteristics. Call Risks: If the fixed income securities are redeemed by the issuer before maturity (or “called”), the fund may have to reinvest the proceeds in securities that pay a lower interest rate, which may decrease the portfolio’s overall yield. This will most likely happen when interest rates are declining. Liquidity Risks: Liquidity risk refers to the possibility that an investor may not be able to sell or buy a security or close out an investment contract at a favorable price or time. Consequently, an investor, may have to accept a lower price to sell a security, sell other securities to raise cash or give up an investment opportunity, any of which could have a negative effect on investment performance. Infrequent trading of securities also may lead to an increase in their price volatility. ETF and Mutual Funds Risk: ETFs and mutual funds are subject to investment advisory and other expenses, which will be indirectly paid by clients. As a result, the cost of our investment strategies will be higher than the cost of investing directly in ETFs or mutual funds, as there are two levels of fees. ETFs and mutual funds are subject to specific risks, depending on the nature of the fund. ETFs are professionally managed pooled vehicles that invest in stocks, bonds, cryptocurrencies, short-term money market instruments, other mutual funds, other securities, or any combination thereof. ETF managers trade fund investments in accordance with fund investment objectives. ETF risk can be significantly increased for funds concentrated in a particular sector of the market, or that primarily invest in small cap or speculative companies, use leverage (i.e., borrow money) to a significant degree, or concentrate in a particular type of security (i.e., equities), rather than balancing the fund with different types of securities. ETFs can be bought and sold throughout the day like stocks, and their price can fluctuate throughout the day. During times of extreme market volatility, ETF pricing may lag versus 15  the actual underlying asset values. This lag usually resolves itself in a short period of time (usually less than one day); however, there is no guarantee this relationship will always occur. Government Obligations Risks: No assurance can be given that the United States government will provide financial support to United States government-sponsored agencies or instrumentalities where it is not obligated to do so by law. As a result, there is risk that these entities will default on a financial obligation. High Yield Securities Risks: High yield securities tend to be more sensitive to economic conditions than are higher-rated securities and generally involve more credit risk than securities in the higher-rated categories. The risk of loss due to default by an issuer of high yield securities is significantly greater than issuers of higher-rated securities because such securities are generally unsecured and are often subordinated to other creditors. Management Risk: The adviser’s strategy may fail to produce the intended results. Firm Research: When our research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, the firm is relying on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. We make every effort to determine the accuracy of the information received but it cannot predict the outcome of events or actions taken or not taken, or the validity of all information it has researched or provided, which may or may not affect the advice on or investment management of an account. Defensive Risk: To the extent that the strategy attempts to hedge its portfolio stocks or takes defensive measures, such as holding a significant portion of its assets in cash or cash equivalents, the objective may not be achieved. Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses for non-wrap fee clients and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. Availability of Information: Certain issuers, including municipalities, private companies, and foreign issuers may not be subject to the same disclosure, accounting, auditing, and financial reporting standards, and practices as companies publicly listed in U.S. stock markets. Thus, there may be less information publicly available about these issuers and 16  their current financial condition. ‐ Concentration Risk: To the extent that the strategy focuses on particular asset classes, countries, regions, industries, sectors, or types of investment from time to time, the strategy may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. Legal and Regulatory Matters Risks: Legal developments which may adversely impact investing and investment-related activities can occur at any time. “Legal Developments” means changes and other developments concerning foreign, as well as U.S. federal, state and local laws and regulations, including adoption of new laws and regulations, amendment or repeal of existing laws and regulations, and changes in enforcement or interpretation of existing laws and regulations by governmental regulatory authorities and self-regulatory organizations (such as the SEC, the Commodity Futures Trading Commission, the Internal Revenue Service, the Federal Reserve and the Financial Industry Regulatory Authority). Our management of accounts may be adversely affected by the legal and/or regulatory consequences of transactions effected for the accounts. Accounts may also be adversely affected by changes in the enforcement or interpretation of existing statutes and rules by governmental regulatory authorities or self-regulatory organizations. System Failures and Reliance on Technology Risks: Our investment strategies, operations, research, communications, risk management, and back-office systems rely on technology, including hardware, software, telecommunications, internet-based platforms, and other electronic systems. Additionally, parts of the technology used are provided by third parties and are, therefore, beyond our direct control. We seek to ensure adequate backups of hardware, software, telecommunications, internet-based platforms, and other electronic systems, when possible, but there is no guarantee that our efforts will be successful. In addition, natural disasters, power interruptions and other events may cause system failures, which will require the use of backup systems (both on- and off-site). Backup systems may not operate as well as the systems that they back up and may fail to properly operate, especially when used for an extended period. To reduce the impact a system failure may have, we continually evaluate our backup and disaster recovery systems and perform periodic checks on the backup systems’ conditions and operations. Despite our monitoring, hardware, telecommunications, or other electronic systems malfunctions may be unavoidable, and result in consequences such as the inability to trade for or monitor client accounts and portfolios. If such circumstances arise, the Investment Committee will consider appropriate measures for clients. Cybersecurity Risk: A portfolio is susceptible to operational and information security risks due to the increased use of the internet. In general, cyber incidents can result from 17  deliberate attacks or unintentional events. Cyberattacks include, but are not limited to, infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks, or devices through “hacking” or other means for the purpose of misappropriating assets or sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches by third-party service providers may cause disruptions and impact on service providers’ and our business operations, potentially resulting in financial losses, the inability to transact business, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement, or other compensation costs, and/or additional compliance costs. While we have established business continuity plans and risk management systems designed to prevent or reduce the impact of such cyberattacks, there are inherent limitations in such plans and systems due in part to the everchanging nature of technology and cyberattack tactics. Pandemic Risks: The novel coronavirus rapidly became a pandemic and resulted in disruptions to the economies of many nations, individual companies, and the markets in general, the impact of which was material. This created closed borders, quarantines, supply chain disruptions and general anxiety, negatively impacting global markets in an unforeseeable manner. The impact of the novel coronavirus and other such future infectious diseases in certain regions or countries may be greater or less due to the nature or level of their public health response or due to other factors. Health crises caused by the coronavirus outbreak and future infectious diseases may exacerbate other pre-existing political, social, and economic risks in certain countries. The impact of such health crises may be quick, severe and of unknown duration. These pandemics and other epidemics and pandemics that may arise in the future could result in continued volatility in the financial markets and could have a negative impact on investment performance. Emerging Technology: From time to time, we will use emerging technologies, such as artificial intelligence (“AI”), as a complement to operational and investment research processes. We can also invest in companies developing or leveraging emerging technology. Emerging technology and AI are wide-ranging terms and include a broad spectrum of technologies and applications, such as machine learning, deep learning, neural networks, and natural language processing, that are quickly evolving. Such emerging technology and AI present unique risks. For example, the automation of tasks previously performed by humans can potentially lead to job displacement and economic disruption. Data privacy concerns arise when AI systems collect and analyze vast amounts of personal data, which can be misused or inadequately protected. Additionally, the rapid development of these technologies often outpaces the creation of appropriate regulations, resulting in ethical challenges such as bias in AI algorithms and the potential for misuse in surveillance, investment decisions or other biases. New security vulnerabilities can also emerge as AI tools are developed, making systems potentially 18  more susceptible to cyberattacks when using emerging AI technologies. We will rebalance your portfolio periodically to control risk, take profits and enhance tax efficiency. We will reduce or eliminate positions due to lack of performance, to achieve certain tax benefits, to capture profits and to tactically re-allocate holdings. While we seek to take advantage of investment opportunities for our clients that will seek to balance investment returns with the risk of loss, there is no guarantee that such opportunities will ultimately benefit our client. We will change client portfolios in response to market conditions that are unpredictable and may expose our client to greater market risk than seen in previous market cycles. There is no assurance that our investment strategy will enable our client to achieve the stated investment objectives of our strategies. The above list of risk factors does not claim to be a complete list or explanation of the risks involved in an investment strategy. There are many other circumstances not described here that could adversely affect your investment and prevent you from your investment objectives. The list represents the typical risks involved. The explanation of certain risks is not exhaustive but rather highlights some of the more significant risks involved in our investment strategies. You are encouraged to consult your IAR and tax professional on an initial and continuous basis in connection with selecting and engaging in the services provided by us. In addition, due to the dynamic nature of investments and markets, strategies may be subject to additional and different risk factors not discussed above. Voting Client Securities (i.e., Proxy Voting) Proxy Voting EWA has accepted responsibility to vote proxies on behalf of Schwab advisory clients. A client has the option to retain proxy voting privileges on behalf of their own account provided they have indicated as such on the WAA or in writing to EWA. Should a client choose this option, then that client will receive proxies or other solicitations directly from their custodian; however, the client may contact EWA with questions regarding solicitations by calling at the telephone number listed on the cover page. When agreed between EWA and a client, EWA will vote proxies for voting securities held in a client’s account. Proxies will be voted in the best interest of EWA’s clients in accordance with EWA’s then-current Proxy Voting Policy (the “Policy”). EWA has retained an independent proxy voting service provider, Broadridge Investor Communication Solutions, Inc. (“Broadridge”) to assist it in connection with voting client proxies. Broadridge relies on another third-party firm, Glass, Lewis & Co., for proxy vote research, 19  guidelines, and vote recommendations. Absent a determination by EWA to override the independent provider’s guidelines and/or recommendations, client proxies will be voted in accordance with those guidelines and/or recommendations. EWA’s Policy is available upon request, in electronic or hard copy form. Clients may obtain the Policy from EWA, as well as information about how EWA voted clients’ securities, by contacting EWA at lroditi@ewadvisors.net. EWA’s proxy voting procedures are designed to ensure that proxies are voted. Our voting guidelines have been designed to promote accountability of a company’s management and board of directors to its shareholders; to align the interests of management with those of shareholders; and, to encourage companies to adopt best practices in terms of their corporate governance. Since EWA has engaged a third-party proxy service provider to assist with the voting of proxies, the CCO and investment management unit have the responsibility for oversight of the third-party proxy service provider and for ensuring that proxies are voted in the best interest of clients. In voting, EWA or the third party shall vote in a prudent and timely fashion and only after a careful evaluation of the issue(s) presented on the ballot. EWA has developed guidelines to vote the proxies. Prior to voting, EWA or the third-party service provider verifies whether a conflict of interest with EWA exists in connection with the subject proposal(s) to be voted upon. The determination regarding the presence or absence of any conflicts of interest is documented. EWA relies on its third-party service provider to make and retain each proxy statement and a record of each vote cast. In the event EWA makes a determination to override the independent provider’s guidelines and/or recommendations, EWA will retain a record memorializing the basis for the vote cast and any other documentation which was material to the decision voted. Clients may request a copy of how securities in their account were voted by contacting EWA at the telephone number listed on the cover page. Class Actions Sometimes securities held in the accounts of Schwab clients will be the subject of class action lawsuits. EWA has engaged Broadridge to provide a comprehensive review of our clients’ possible claims to a settlement throughout the class action lawsuit process. Broadridge actively seeks out any open and eligible class action lawsuits. Additionally, Broadridge files, monitors, and expedites the distribution of settlement proceeds in compliance with SEC guidelines on behalf of our clients. Broadridge’s filing fee is contingent upon the successful completion and distribution of the settlement proceeds from a class action lawsuit. In recognition of Broadridge’s services, they receive a percentage (typically 15%) of our clients’ share of the settlement distribution. When EWA 20  receives written or electronic notice of a class action lawsuit, settlement, or verdict affecting securities owned by clients, it will work to assist clients and Broadridge in the gathering of required information and submission of claims. 21  Item 7 – Client Information Provided to Portfolio Managers We have access to client information as our supervised persons act as the portfolio managers for the Wrap Fee Programs described in Item 4 above. Pursuant to applicable Federal and/or State Privacy Regulations, we are a financial institution that has determined to keep confidential the non-public personal information about each of our clients. We obtain the necessary information and review your financial situation and investment portfolio, including your risk tolerance, to determine and set the appropriate short and long-term investment goals and objectives. We encourage you to notify us if there have been any changes in your financial situation or investment objective, or if you wish to impose any reasonable restrictions, or modify any existing restrictions, on the management of your account. 22  Item 8 – Client Contact with Portfolio Managers We have not placed any restrictions on your ability to contact and consult with your portfolio manager. 23  Item 9 – Additional Information Disciplinary Information We are required to disclose all material facts regarding any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. We do not have any legal or disciplinary events to report. Other Financial Industry Activities and Affiliations Neither we nor any of our management persons (except as disclosed below), are registered, nor do we have an application pending to register as a broker-dealer or a registered representative of a broker-dealer, futures commission merchant, commodity pool operator, commodity trading advisor or as an associated person of the foregoing entities. In addition, neither we nor any of our management persons have any arrangement that is material to our advisory business or to our clients that we or any of our management persons have with any related person that is under common control and ownership, i.e., a: ● Municipal securities dealer, or government securities dealer or broker, ● Investment company or other pooled investment vehicle, ● Other investment adviser or financial planner, ● Futures commission merchant (or commodity pool operator or commodity trading advisor), ● Banking or thrift institution, ● Accountant or accounting firm, ● Lawyer or law firm, ● Insurance company or agency, ● Pension consultant, ● Real estate broker or dealer, or ● Sponsor or syndicator of limited partnerships. 24  However, Roberto Vainrub sits on the board as a director of Mercantil Banco Universal and his duties include board meetings and the risk committee where he spends approximately on average 10 hours per month. AV Securities, Inc. & AV Asset Management, Inc. Mr. Vainrub is a passive investor/owner of AV Securities, Inc. (“AV Securities”). AV Securities is a licensed Panama Broker-Dealer that provides investment advice, securities analysis, and research services to its clients. In addition, Marcel Apeloig (a client of EWA), Alan Rotter (a client of EWA), Antonino Ciulla (a client of EWA) and Alfonso Angrisano, each of whom are minority/passive owners of EWA, are also partners at AV Securities. Furthermore, Messrs. Angrisano and Ciulla own AV Aset Management, which is under common control with AV Securities. Messrs. Apeloig, Angrisano, Ciulla and Rotter do not provide investment advice and will not have control over the day-to-day management of EWA. • AV Asset Management provides research services to EWA and, indirectly, EWA’s advisory clients. EWA compensates AV Asset Management for its research. As owners of AV Asset Management, Messrs. Angrisano and Ciulla indirectly benefit from the compensation received from EWA. A conflict of interest exists in that the choice of EWA’s research vendor may be driven more by the compensation potential to Messrs. Angrisano and Ciulla than the merits of the research vendor’s research services. • EWA also provides advisory services to AV Securities under a consulting agreement. • Additionally, AV Securities and EWA have entered into a promoter agreement whereby AV Securities agreed to recommend EWA’s investment advisory services to potential clients. AV Securities also agreed to periodically contact referred clients for the purpose of assisting them in understanding EWA’s services and, if necessary, to update their information and provide it to EWA. In exchange for these services, EWA pays AV Securities a referral fee. A conflict of interest exists in that Messrs. Vainrub, Apeloig, Angrisano, Ciulla and Rotter would indirectly benefit from the fees paid to AV Securities due to their ownership interests in AV Securities. • Finally, AV Securities serves as the qualified custodian for a client whose assets we manage. EWA and Mr. Vainrub understand and take their fiduciary duty to all clients seriously, and EWA has created and implemented a Compliance Program to monitor all client 25  accounts for adherence to client investment objectives, the fair allocation of investment opportunities, and to ensure equitable client treatment in all matters. Investment Adviser Relationships We do not receive compensation directly or indirectly from other investment advisers. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics The Code of Ethics adopted and implemented by EWA applies to the activities of our Company. All employees of EWA are subject to this Code of Ethics. In carrying on its daily affairs, EWA, and all of our supervised persons2 shall act in a fair, lawful and ethical manner, in accordance with the rules and regulations imposed by our governing regulatory authority. The Code of Ethics sets forth standards of conduct and requires compliance with applicable state and federal securities laws. Our Code of Ethics also addresses personal trading and requires our personnel to report their personal securities holdings and transactions to our Chief Compliance Officer (“CCO”). We have created a Code of Ethics which establishes standards and procedures for the detection and prevention of certain conflicts of interest including activities by which persons having knowledge of the investments and investment intentions of EWA, its affiliates, or clients, might take advantage of that knowledge for their own benefit. EWA has in place Ethics Rules (the “Rules”), which are comprised of the Code of Ethics and Insider Trading policies and procedures. The Rules are designed to ensure that EWA’s personnel (i) observe applicable legal (including compliance with applicable state and federal securities laws) and ethical standards in the performance of their duties; (ii) to act in the EWA’s clients’ best interest at all times; (iii) disclose all conflicts of interest; (iv) adhere to the highest standards of loyalty, candor and care in all matters relating to its clients; (v) conduct all personal trading consistent with the Rules and in such a manner as to mitigate any conflicts of interest or any abuse of their position of trust and responsibility; and (vi) not use any material non-public information in securities trading. The Rules also establish policies regarding other matters such as outside employment, the giving or receiving of gifts, and safeguarding portfolio holdings information. Under the general prohibitions of the Rules, EWA’s personnel are prohibited from: 1) effecting securities transactions while in the possession of material, non-public 2 Supervised person means any partner, officer, director (or other person occupying a similar status or performing similar functions), or employee of an investment adviser, or other person who provides investment advice on behalf of the investment adviser and is subject to the supervision and control of the investment adviser. 26  information; 2) disclosing such information to others; 3) participating in fraudulent conduct involving securities held or to be acquired by any client; and 4) engaging in frequent trading activities that create or may create a conflict of interest, limit their ability to perform their job duties, or violate any provision of the Rules. We will provide a copy of our Code of Ethics to you upon request. To request a copy, you can contact us at the address or telephone number listed on the cover page of this brochure, Attn: Chief Compliance Officer. Personal Trading Under the Code, EWA’s personnel are required to conduct their personal investment activities in a manner that EWA believes is not detrimental to its advisory clients. As discussed above, EWA personnel must conduct all personal trading in such a manner to mitigate any conflicts of interest or any abuse of their position of trust and responsibility. EWA and/or its employees buy, sell, or hold securities it also recommends to clients, subject to the requirements of its internal policies and procedures. EWA’s policies are based on the principle that EWA and its employees have a fiduciary duty to place the interests of clients ahead of their own interests. To the extent not prohibited by its policies, EWA and/or its employees hold, acquire, increase, decrease or dispose of securities or other interests at or about the same time that EWA is purchasing or selling the same securities or interests for an advisory account. EWA manages discretionary accounts on behalf of its owners, employees, and family members. EWA has created and implemented internal controls to monitor client account activity and proper allocation of investment opportunities, based on each client’s stated investment objectives and risk tolerance, to address these conflicts. Participation or Interest in Client Transactions We do not execute transactions on a principal or agency cross basis. Donations to Charities EWA makes donations to charitable organizations that are affiliated with or supported by its clients or individuals employed by its clients. Additionally, EWA waives fees for nonprofits for whom we manage accounts. In general, such donations are made in response to requests from clients, or their personnel. Because EWA’s contributions may result in the recommendation of EWA’s services or its products, such contributions may raise a potential conflict of interest. No contribution will be made if the contribution implies that continued or future business with EWA depends on making such contribution. 27  Review of Accounts Reviews and Reviewers of the Accounts Client accounts will be reviewed, at a minimum, once a year. Model portfolios are reviewed quarterly and if there are changes to the model portfolio, they will normally be executed within a month (depending on market conditions). In addition, client accounts will be reviewed within one month of receiving additional cash or assets into the client’s account. Each IAR works directly with clients to provide ongoing investment dialogue to regularly review investment approach and objectives as well as market insights. Accounts are reviewed with clients annually or as needed by each client. In addition, all accounts are reviewed annually by their IAR to ensure that they are meeting the clients’ investment objectives. The review covers evaluation of the account’s asset allocation against the recommended allocation for that particular investment objective. The process also includes evaluation of the account’s performance against benchmarks of similar investment objectives. We will discuss your current financial status, risk tolerance, and investment objectives and goals to determine whether adjustments are required to your current asset allocation and account holdings. Changes in macroeconomic and company specific events may trigger additional reviews. Nature and Frequency of Regular Reports Provided to Clients on their Accounts For all accounts, clients receive statements from the custodian, at least quarterly, with their account details of holdings, market value, and allocation of asset class. Clients who request access can review their accounts at any time through the custodian’s web portal. In addition, clients receive a detailed report during annual in-person (or phone) reviews with the IAR. During these reviews, the IAR discusses a range of topics related to clients’ financial needs/goals, economic and market conditions, personal tax-related investment items such as gains/losses as well as overall performance. Client Referrals and Other Compensation Client Referrals EWA compensates third parties for client referrals. Such referral arrangements are governed by a written agreement between EWA and the particular third party (i.e., the promoter). EWA pays the promoter a portion of the fee paid by each client they refer to EWA who invests with us. This fee can range from 10% to 65% of the fee paid to EWA by the client. We do not charge higher fees to clients who were referred by a promoter than the fees charged to clients with similar portfolios managed by EWA who were not introduced by a third-party promoter. 28  Third-party promoters who refer clients to us will provide you with a copy of our Form ADV Part 2A and will disclose to you their relationship with us, whether they receive compensation for the referral, and any material conflicts of interest. Additionally, we will enter into arrangements whereby from time to time we receive compensation, either directly or indirectly, from unaffiliated persons for client referrals. Under such arrangements, we receive a percentage of the investment advisory fee paid by such client. This fee may vary according to each agreement. Referred clients will receive a copy of this Disclosure Brochure along with disclosure (either orally or in writing) of the terms of the referral arrangement and any conflicts of interest related to the arrangement at the time of the referral. Referral arrangements are entered into in accordance with Advisers Act Rule 206(4)-1. Promoters that refer business to more than one investment adviser may have a financial incentive to recommend advisers with more favorable compensation arrangements. We will disclose to you whether multiple referral relationships exist, and those comparable services may be available from other advisers. Referral fees paid to a Promoter are contingent upon your entering into an advisory agreement. This creates a conflict of interest given that the Promoter has a financial incentive to recommend such services. However, you are not obligated to retain such advisory services. Comparable services and/or lower fees may be available through other firms. In addition, we have implemented a compliance program to monitor such conflicts, and our relationships are periodically reviewed. Other Compensation We do not receive an economic benefit (other than the custodial services identified in Item 12 of our Form ADV Part 2A), including sales awards or other prizes, from a non- client for providing investment advice or other advisory services to our clients. By selecting or recommending a broker-dealer, we will consider the value of research and additional brokerage products and services a broker-dealer has provided or will provide to our clients and us. We recommend or require that clients establish brokerage (collectively, accounts with FINRA-registered broker-dealers, SIPC members “custodians”) through which the custodians provide our firm with their "platform" services. The platform services can include, among others, brokerage, custodial, administrative support, record keeping and related services such as maintaining custody of clients’ assets and effecting trades for the client’s account(s). We receive benefits by selecting such custodians to execute client transactions, and the transaction compensation charged by such custodians might not be the lowest compensation we might otherwise be able to negotiate. We have not entered into a formal soft dollar arrangement, whereby, we are required to direct a certain amount of transaction activity to such custodians for 29  specific research or brokerage services, but certain services are available to us at no charge to us so long as our clients’ assets are maintained in accounts at such custodians. As disclosed in Item 5 of our Form ADV Part 2A, when EWA recommends investments in Private Funds, EWA charges a management fee and might also receive a portion of the performance/carried interest fee charged by the Fund Manager. This presents a conflict of interest in that EWA may receive compensation through the Fund Manager that is in addition to the management or consulting fee that is charged by EWA. EWA will charge a management or consulting fee on the Private Fund assets. The calculation of the management or consulting fee is disclosed in Item 5 above. In addition, EWA’s commitment to its clients, and the policies and procedures it has adopted that require the review of such arrangements by the CCO, are designed to limit any interference with EWA’s independent decision making when choosing the best investments for our clients. Financial Information We have no financial condition that is reasonably likely to impair our ability to meet contractual commitments to you given that we do not have custody of client funds or securities or require or solicit prepayment of fees in excess of $1,200 per client and six months or more in advance. In addition, we are not currently, nor have we been, at any time, the subject of a bankruptcy petition. 30  Item 10 – Requirements for State-Registered Advisers We are an SEC registered investment adviser, so this section does not apply. 31