FINAMEX ASSET MANAGEMENT, LLC

Item 1: Cover Page Finamex Asset Management, LLC Client Brochure This Brochure provides information about the qualifications and business practices of Finamex Asset Management, LLC. If you have any questions about the contents of this Brochure, please contact us at 713-589-7121. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities' authority. Finamex Asset Management, LLC is a registered investment adviser. Registration of an investment adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about Finamex Asset Management, LLC is also available on the SEC’s Website at www.adviserinfo.sec.gov. 2700 Post Oak Blvd., 22nd Floor, Suite 22-122 Houston, Texas 77056 713-589-7121 April 23, 2026  Item 2: Material Changes This item discusses only specific material changes that are made to the Brochure since the Firm’s last annual update. It will also reference the date of the last update of the brochure. Since the Firm’s last update dated April 14, 2026 the Firm’s CCO changed from Pablo Andres Carrillo to Luis Suarez. We will ensure that you receive a summary of any material changes to this and subsequent Brochures within 120 days of the close of our business’ fiscal year, which is December 31. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, Finamex’s Brochure may be requested by contacting Luis Suarez, CCO, by phone at 713-589-7121 or via email at luis.suarez@finamexintl.com. Additional information about Finamex is also available via the SEC’s Website at www.adviserinfo.sec.gov. The SEC’s Website also provides information about any persons affiliated with Finamex who are registered, or are required to be registered, as investment adviser representatives of Finamex. 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, COMPENSATION AND TERMINATION OF SERVICES .................................................. 12 ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ...................................... 15 ITEM 7: TYPES OF CLIENTS ......................................................................................................................... 16 ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....................... 17 ITEM 9: DISCIPLINARY INFORMATION .................................................................................................... 23 ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ...................................... 24 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ..................................................................................................................................... 26 ITEM 12: BROKERAGE PRACTICES ............................................................................................................ 28 ITEM 13: REVIEW OF ACCOUNTS ............................................................................................................... 30 ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION ............................................................. 31 ITEM 15: CUSTODY ......................................................................................................................................... 32 ITEM 16: INVESTMENT DISCRETION ......................................................................................................... 33 ITEM 17: VOTING CLIENT SECURITIES .................................................................................................... 34 ITEM 18: FINANCIAL INFORMATION ......................................................................................................... 35 3  ITEM 4: ADVISORY BUSINESS A. Firm Description Finamex Asset Management, LLC is a Delaware limited liability company that was formed on March 12, 2019 to act as an Investment Adviser. The Firm is currently registered as an investment advisor with the SEC. Finamex Asset Management, LLC is 100 % owned by Finamex USA, LLC, a Delaware formed limited liability company, which is in turn 100 % owned by Casa de Bolsa Finamex S.A.B. de C.V. (“Finamex Casa de Bolsa”). Finamex Casa de Bolsa is a publicly traded company that was formed in Mexico and that is listed in the Mexican Stock Exchange (BMV) and the Bolsa Institucional de Valores (BIVA) in Mexico. Finamex Asset Management, LLC has a sister company, Finamex International, LLC which is 100 % owned by Finamex USA, LLC. Finamex International is a registered broker/dealer and a Member of the Financial Industry Regulatory Authority (FINRA) and is registered with the U.S. Securities and Exchange Commission (SEC). B. Types of Advisory Services Finamex Asset Management, LLC offers to its client’s discretionary and/or non-discretionary investment advisory services, and, to the extent specifically requested by a client, financial planning and related consulting services. These services are offered to individuals, families, trusts and businesses. The investment advisory services are based on Modern Portfolio Theory (“MPT”) that makes it possible for anyone who enters into a Finamex Asset Management, LLC Client Agreement (the “Advisory Client Agreement”), to access state-of-the-art investment advisory and portfolio management services. As provided in the Advisory Client Agreement, advisory clients (“Clients”) grant Finamex Asset Management, LLC discretionary authority to manage Client asset in accounts (“Client Accounts” or “Accounts”) opened and maintained at Finamex Asset Management, LLC. Finamex Asset Management’s primary investment objective is to seek maximum long-term, risk-adjusted, after-tax, net of fee returns. Account Portfolio Management Finamex Asset Management, LLC provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and consulting services. Finamex Asset Management, LLC works with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio allocation. Finamex Asset Management, LLC will then construct a portfolio, consisting of exchange-traded funds (“ETFs”), mutual funds, and individual stocks and bonds to achieve the Client’s investment goals. Finamex 4  Asset Management, LLC may also utilize other security types as necessary to meet the needs of its Clients. At Finamex Asset Management LLC, our investment philosophy is based on the belief that markets are efficient over the long-term, but can remain relatively inefficient and irrational over the shorter term. At the core of our investment management approach is a tactically managed Asset Allocation strategy that seeks to capture market inefficiencies in various asset classes over time while maintaining a below-market risk posture. This provides Clients with a longer-term core solution which is aligned with our belief that markets are efficient and rational over longer periods of time. However, in aligning with our belief that markets can operate away from the fundamentals over the shorter term, Finamex Asset Management, LLC manages a number of technically based strategies that are designed to capitalize on trends that we see developing in various markets/asset classes. The goal of these strategies is to limit losses in unfavorable market environments while attempting to outperform the broad market over longer periods of time. The firm employs technical analysis and proprietary rule-based modeling in managing these accounts. These portfolios are as follows: Shield Portfolio: • Invests in ETFs • Seeks to maximize income while reducing risk • At least 85% of the portfolio is invested in fixed income • Invests up to 15% of the portfolio in equities Diversified Portfolio: • Invests in ETFs • Seeks to balance income and capital appreciation through diversification with different return sources • At least 85% of the portfolio is invested in fixed income • Invests up to 15% of the portfolio in equities • Seeks to obtain attractive returns in fixed income through corporate and global securities 5  • Active Management: o Active fixed income management seeking assets with the best risk-benefit o Constant supervision of equity sectors seeking the best growth prospects with attractive valuations Diversified Alpha Portfolio: • Invests in ETFs • Focus on seeking to generate alpha and return stability • At least 75% of the portfolio is invested in fixed income • Invests up to 25% of the portfolio in equities • Seeks to obtain attractive returns in fixed income through corporate and global securities • Seeks to generate alpha through investment in different sectors according to market opportunities • Active Management: o Fixed Income active management: seeking the assets with the best risk-reward o Constant supervision of equity sectors seeking the best growth prospects with attractive valuations Barbell Portfolio • Invests in ETFs • At least 65% of the portfolio is invested in fixed income • Up to 35% of the portfolio is invested in equities • The core of the portfolio consists of fixed income securities, as well as equities • Active Management: o Fixed Income active management: seeking the assets with the best risk-reward o Constant supervision of equity sectors seeking the best growth prospects with attractive valuations 6  • Barbell Strategy: o The portfolio follows a Barbell strategy combining exposure in fixed income and equities o The portfolio achieves a Barbell exposure by investing in both short and long duration assets. Barbell Alpha Portfolio • Invests in ETFs • At least 45% of the portfolio is invested in fixed income • Up to 55% of the portfolio is invested in equities • The core of the portfolio consists of fixed income securities, as well as equities • Active Management: o Fixed Income active management: seeking the assets with the best risk-reward balance o Constant supervision of equity sectors seeking the best growth prospects with attractive valuations • Barbell Strategy: o The portfolio follows a Barbell strategy combining exposure in fixed income and equities o The portfolio achieves a Barbell exposure by investing in both short and long duration assets Core Equity Portfolio: Invests in ETFs • • At least 25% of the portfolio is invested in fixed income • Up to 75% of the portfolio is invested in equities • The backbone of the portfolio consists of fixed income securities, as well as equities 7  • Active Management: o Active management of fixed income, seeking assets with the best risk–return profile o Ongoing monitoring of equity sectors to identify the best growth opportunities with attractive valuations • Core Equity Strategy: o The portfolio follows a strategy with high exposure to equities o The portfolio achieves a barbell exposure by investing in both short-duration and long-duration assets Thematics Portfolio • Invests in ETFs • Invests 100% in Equities • Megatrends: seeks to capture significant changes in society and changing global habits: o Impact on consumer goods, employment, corporate strategy, and government policies o Long-term growth opportunities • Active Management: constant supervision of Megatrends with best growth potential o ETF research o Constant updating of the Megatrends ETF universe o Supervision of returns, liquidity, transaction costs, risk-return • Diversification: exposure to global companies o Reduction of stock selection risk through diversified ETFs o Exposure to trends and a variety of disruptive sectors o Focus on innovative and disruptive companies with high reinvestment levels • Long Term: Megatrends are transformations that take years; therefore, the strategy follows a long-term perspective Finamex Asset Management, LLC will construct, implement and monitor the portfolio to help ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. 8  Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to the acceptance by the Advisor. Finamex Asset Management, LLC may periodically rebalance or adjust client accounts under its management. If the client experiences any significant changes to his/her financial or personal circumstances, the Client must notify the Firm so that the Firm can consider such information in managing the Client's investments. Finamex Asset Management, LLC evaluates and selects ETFs and mutual funds for inclusion in Client portfolios only after applying their internal due diligence process. Finamex Asset Management, LLC may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Finamex Asset Management LLC may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement, which may adversely affect the portfolio. Finamex Asset Management, LLC may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. Prior to rendering investment advisory services, Finamex Asset Management, LLC will ascertain, in conjunction with the Client, the Client’s financial situation, risk tolerance, and investment objective[s]. Finamex Asset Management, LLC will provide investment advisory services and portfolio management services and will not provide securities custodial or other administrative services. All client accounts will be introduced to Finamex International, an affiliated broker-dealer and will be custodied by the clearing firm for Finamex International. At no time will Finamex Asset Management, LLC accept or maintain custody of a Client’s funds or securities. All Client assets will be managed within their designated brokerage account, pursuant to the Client Investment Advisory Agreement. Financial Planning and Consulting Services Finamex Asset Management, LLC will typically provide a variety of financial planning services to individuals, families, small businesses and other Clients, pursuant to a written Financial Planning or Consulting Agreement. Services are offered in several areas of a Client’s financial situation, depending on their goals, objectives and financial situation. Finamex Asset Management, LLC and the Client will discuss and agree upon the specific topics to be covered by the financial plan. Such topics may include investment planning, retirement planning, tax planning, insurance planning, estate planning, or business planning. Finamex Asset Management, LLC will conduct one or more meetings (in person, if possible, otherwise via telephone conference) with the Client 9  in order to understand the Client's current financial situation, financial goals, specific issues or questions, and topics to be covered by the financial plan. A financial plan developed for, or financial consultation rendered to the Client, will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Finamex Asset Management, LLC may also refer Clients to an accountant, attorney or other specialist, as appropriate for their unique situation. Finamex may be compensated for these referrals, but any such compensation will not increase the fee charged to the client by Finamex. For certain financial planning engagements, the Advisor will provide a written summary of Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. Plans or consultations are typically completed within six months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations may pose a potential conflict between the interests of the Advisor and the interests of the Client. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to effect the transaction through the Advisor. As indicated above, to the extent specifically requested by a client, Finamex Asset Management, LLC may provide consulting services regarding non-investment-related matters, such as estate planning, tax planning, insurance, etc. Finamex Asset Management, LLC, nor any of its representatives, serves as an attorney or accountant, and no portion of the services rendered by Finamex Asset Management, LLC should be construed as legal or accounting advice. To the extent of the request by a client, Finamex Asset Management, LLC may recommend the services of other professionals for certain non-investment implementation purposes (i.e., attorney, accountants, insurance agent, etc.). If the client engages any recommended professional, and a dispute arises thereafter relative to such engagement, the client agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed professional (i.e., attorney, accountant, insurance agent, etc.), and not Finamex Asset Management, LLC, shall be responsible for the quality and competency of the services provided. Clients are responsible for promptly notifying Finamex Asset Management, LLC if there is any change in their financial situation or investment objectives so that Finamex Asset Management, LLC can review, and if necessary, revise its previous recommendations or services. 10  C. Client Tailored Services and Client Imposed Restrictions Finamex Asset Management, LLC will offer its clients tailored advisory services to the individual needs of each of its Clients, in accordance with certain investment options designated by Clients, and subject to certain account limitations that prospective investors should consider. Finamex Asset Management, LLC asks each prospective Client a series of questions to evaluate both the individual’s objective capacity to take risk and subjective willingness to take risk. We ask subjective risk questions to determine both the level of risk an individual is willing to take and the consistency among the answers. For example, if an individual is willing to take a lot of risk in one case and very little in another, then the individual is deemed inconsistent and is therefore assigned a lower risk tolerance score than the simple weighted average of her answers. We ask objective questions to estimate with as few questions as possible whether the individual is likely to have enough money saved at retirement to afford her likely spending needs. The greater the excess income, the more risk the Client is able to take. D. Wrap Fee Programs Finamex Asset Management, LLC does not sponsor or manage a wrap fee program E. Amounts of Assets Under Management As of March 25, 2026, Finamex Asset Management, LLC has approximately $113.9 million in assets under management, of which $51.2 million are managed on a discretionary basis and $62.6 million on a non-discretionary basis. 11  ITEM 5: FEES, COMPENSATION AND TERMINATION OF SERVICES A. Description of Compensation and Basic Fee Schedule The client can engage Finamex Asset Management, LLC to provide discretionary advisory services and financial planning services for a fee-only basis. Finamex Asset Management, LLC’s annual investment advisory fee is based upon a percentage (%) of the market value of the assets placed under Finamex Asset Management, LLC for all portfolios as follows: Market value of Portfolio % of Assets Under Between Between Between Over $ 250,000 2.25 % * $ 250,001 and $ 500,000 1.25 % $ 500,001 and $ 1,000,000 1.00 % $ 1,000,001 and $ 2,000,000 0.75 % $ 2,000,000 0.65 % * Accounts with a balance below $10,000 will be charged a monthly fee of $25. Finamex will, in its discretion, household accounts (defined as accounts under common control or ownership, or accounts of immediate relatives) to determine the assets under management for fee billing purposes. In addition, Finamex will not use a “tiered” fee schedule, but instead will bill all assets in the household at the lowest rate available based upon assets in the household accounts. Finamex Asset Management, LLC investment advisory fee is negotiable at Finamex Asset Management, LLCs discretion, depending upon objective and subjective factors including but not limited to: the amount of assets to be managed; portfolio composition; the scope and complexity of the engagement; the anticipated number of meetings and servicing needs; related accounts; future earning capacity; anticipated future additional assets; the professional rendering the service(s); prior relationships with Finamex Asset Management, LLC and / or its representatives, and negotiations with the client. It should also be noted that, if a margin account is used to purchase securities, the Firm will bill on all assets purchased using margin In other circumstances, Finamex Asset Management, LLC may agree to a flat annual fee. As a result of these factors, similarly situated clients could pay different fees, the services to be provided by Finamex Asset Management, LLC to any particular client could be available from other advisers at lower fees, and certain clients may have fees different than those specifically set forth above. 12  Financial Planning and Consulting Services (Stand Alone) To the extent requested by a client, Finamex Asset Management, LLC may provide financial planning and / or consulting services (including investment and non-investment related matters such as estate, tax and insurance planning, etc.) on a stand-alone separate hourly rate basis, registrant´s planning and consulting fees are negotiable, but generally range from negotiable up to US$ 350.00 on an hourly basis, depending upon the scope and complexity of the service(s) required and the professional(s) rendering the service(s). B. Payment of Fees All investment advisory services fees, unless specifically agreed upon with the client will be deducted on a monthly basis from clients’ accounts. Finamex Asset Management, LLC annual investment advisory fee shall be prorated and paid monthly in arrears, based upon the market value of the assets, including cash, cash equivalents, accrued interest, if any including securities on margin or short positions in the account as of the last business day of the previous month. The advisory fee paid may be more than interest earned on Money Market accounts and/or cash balances. If the Account is closed during the month fees will be pro-rated based upon the number of days the Account was opened during the month. Finamex shall use the actual number of days in the month (or for accounts opened during the month, the actual number of days in the month that the account was funded) divided by the actual number of days in the specific calendar year. Finamex Asset Management, LLC generally requires a minimum asset base of US$ 250,000 for investment advisory services. Finamex Asset Management, in its sole discretion, may charge lower investment management fee or waive or reduce its minimum asset requirement based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client, etc.) The Investment Advisory Agreement between Finamex Asset Management, LLC and the client will continue in effect until terminated by either party by written notice in accordance with the terms of the Investment Advisory Agreement. C. Other Fees Finamex Asset Management, LLC will impose a monthly fee of $25 to retail accounts that fall below a balance of $10,000. This fee may be waived on a case-by-case basis. All Finamex clients may incur additional charges that may be imposed by the respective custodian, including, but not limited to, transaction fees and costs, margin or debit interest, costs associated with exchanging foreign currencies, transfer fees, exchange fees, foreign clearing, settlement and custodial fees, and other fees or taxes required by law. Such charges, fees and commissions are exclusive of and in addition to Finamex’s fees. Additional fees for work outside our normal services 13  may apply. (i.e., services related to divorce, estates, family office, account reconciliations and foreign transfers). D. Prepayment of Fees Finamex does not charge advisory fees in advance, therefore it will not refund any advisory fees to clients should they close their account, E. Other Compensation Finamex Asset Management, LLC expects to receive compensation in the form of asset-based sales charges or service fees (commonly known as 12b-1 fees) from the sales of Mutual Funds. Wherever Finamex believes it appropriate and in the client’s best interests, the Firm will recommend “no-load” funds. The receipt of additional fees from a mutual fund may present a conflict of interest and gives Finamex Asset Management, LLC and its advisors an incentive to recommend investment products based on the compensation received, rather than on a client’s needs. This conflict will be mitigated by the Firm’s adherence to its Code of Ethics. Finamex International, an affiliated broker-dealer, will not receive compensation for executing transactions in advisory accounts introduced to them. Mutual Fund Charges To the extent mutual funds are selected by Finamex to fill components of a client’s overall investment strategy, Finamex endeavors to purchase such mutual fund shares at net asset value or on a “no-load” basis. To the extent Finamex is successful in doing so, its clients will not be subject to any initial distribution cost (front-end sales charge) or redemption fee (back-end sales charge), if any, that might normally be incurred upon the purchase or sale of shares of mutual fund shares Clients will have the option to purchase investment products that Finamex Asset Management, LLC recommended through other brokers or agents that are not affiliated with Finamex Asset Management, LLC. Commissions and other compensation for the sale of investment products recommended by Finamex Asset Management, LLC provide the primary compensation. 14  6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE ITEM MANAGEMENT Finamex Asset Management, LLC fees associated with services are not “performance based” (based upon a share of capital gains or capital appreciation, or performance, for any portion of funds under an advisory contract). The fees noted herein represent fees for advisory services only. 15  ITEM 7: TYPES OF CLIENTS Clients to whom Finamex Asset Management, LLC will provide investment advisory services will be primarily high-net-worth individuals living in Mexico. To a lesser extent, the Firm’s clients will also consist of trusts, investment companies, pension fund managers (AFOREs) and businesses. 16  ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. Methods of Analysis and Investment Strategies Finamex Asset Management, LLC may utilize, but not limited to, the following methods of security analysis: • Charting – Analysis performed using patterns to identify current trends and trend reversals to forecast the direction of prices. • Fundamental – Analysis performed on historical and present data, with the goal of making financial forecasts of potential market valuations. • Technical – Analysis performed on historical and present data, focusing on price and trade volume, to forecast the direction of prices. • Cyclical –Analysis performed on historical relationships between price and market trends, to forecast the direction of prices. B. Material Risks Every method of analysis has its own inherent risks. To perform an accurate market analysis, Finamex Asset Management, LLC must have access to current / new market information. Finamex Asset Management, LLC has no control over the dissemination rate of market information; therefore, unbeknownst to Finamex Asset Management, LLC, certain analyses may be compiled with outdated market information, limiting the value of Finamex Asset Management, LLC analysis. Furthermore, an accurate market analysis can only produce a forecast of the direction of market values. There can be no assurances that the forecasted change in market value will materialize into actionable and / or profitable investment opportunities. Finamex Asset Management, LLC asset allocation strategies primarily allocate client investment assets among various individual equities (stocks), fixed income securities, mutual funds, cash, closed-end funds, alternative investments and exchange traded funds (ETF´s) on a discretionary basis in accordance with the clients designated investment objectives. The clients´ designated investment objective determines the allocation to each investment vehicle. In contrast to Finamex Asset Management, LLC´s asset allocation strategies, the investment strategies are designed to achieve certain strategic investment objectives and generally employ a more concentrated number of asset classes and investment vehicles and may not be as diversified across multiple assets classes as the asset allocation strategies. An investment strategy may be used as a component of an asset allocation strategy depending on the client´s designated investment objective. 17  Finamex Asset Management, LLC may employ a tactical asset allocation process, overweighting and underweighting various asset classes relative to their strategic asset allocation target based on the outlook for each asset class over the next 12 to 18 months. This tactical asset allocation process is based on valuation philosophy and framework, whereby asset class is ranked based on its relative degree of attractiveness (or unattractiveness) in terms of its valuation vis-à-vis its historical average valuation over time. In addition to the fundamental investment strategies discussed above, Finamex Asset Management, LLC may also recommend options transactions, a strategy that has a high level of inherent risk (see discussion below in Risk of Loss). If an option strategy is recommended, it will generally be delivered on a limited basis. When implementing investment advice given to the clients, Finamex Asset Management, LLC may employ methods that include long term purchases (securities held at least a year) and short- term purchases (securities sold within a year). Short term purchase may be deemed necessary due to changes in security valuations; market conditions or meet the cash needs of the client. The Firm does not utilize discretion in trading client accounts, and as a result, the timing of the trades executed as a result of the “buy/sell” signals received from an affiliate may affect each client’s performance, since the Firm is not permitted to execute trades in a client account until such client has given their authorization to the Firm to do so. The lack of the ability for the Firm to execute block transactions may have an effect on the Best Execution and performance received by each client. C. Certain Risk Factors Investing in securities involves risk of loss that clients should be prepared to bear. Finamex Asset Management, LLC method of analysis and investments strategies do not present any significant or unusual risks, however, every investment strategy has its own inherent risks and limitations. The risk involved for different client accounts will vary based in the client´s investment strategy and the type of securities or other investment held in the client´s account. The following are descriptions of various primary risks related to the investment strategies used by Finamex Asset Management, LLC. Not all possible risks are described below: Credit Risks – The risk that the portfolio could lose money if the issuer of guarantor of a fixed- income security, or the counter-party to a derivative contract, is unable or unwilling to meet its financial obligations. Counter-Party Risks – A portfolio may incur a loss if the other party to an investment contract, such as a derivative, fails to fulfill its contractual obligation. 18  Currency Risks – The risk that foreign currencies will decline in value relative to the US dollar and affect a portfolio’s investments in foreign (non-US) currencies or in securities that trade in, and receive revenues in, or in derivatives that provide exposure to, foreign (non-US) currencies. Debt Securities Risks – The issuer of a debt security may fail to pay interest of principal when due, and changes in market interest rates may reduce the value of debt securities or reduce the portfolio’s returns. Derivatives Risks – The use of derivatives such as futures, options and swap agreements can lead to losses, including those magnified by leverage, particularly when derivatives are used to enhance return rather than offset risk. Emerging-Markets Risk – Foreign investment risks are typically greater for securities in emerging markets, which can be more vulnerable to recessions, currency volatility, inflation and market failure. Equity Risks – The risk that the value of equity securities, such as common stocks and preferred stocks, may decline due to general market conditions which are not specifically related to a particular company or to factors affecting a particular industry or industries. Equity securities generally have greater price volatility than fixed income securities. ETF Risks – A portfolio will be exposed indirectly to all of the risks of securities held by an ETF. External Strategy Implementation Risk - In implementing the various strategies outlined in Section 4 of this brochure, Finamex will receive buy/sell "signal" from an affiliate in Mexico. Our results may differ from what is reported by the affiliate due to the timing of our trade execution and potential differences between the version of the strategy we have implemented versus what the manager runs internally. As a result, performance may differ from the performance of the strategies as reported by our Mexican affiliate Fixed Income Risks: Fixed income investments are generally less volatile than equities but are subject to risks. The risks include, without limitation, interest rate risks (risks that changes in the interest rate will devalue the investment), credit risk (risk of default by borrowers), or maturity risk (risk that bonds or notes will change from time of issuance to maturity). Foreign Investment Risk – Foreign investments face the potential of heightened illiquidity, greater price volatility and adverse effects of political, regulatory, tax, currency, economic or other macroeconomic developments. High-Yield Securities Risk – High-yield securities have a much greater risk of default or of not returning principal and tend to be more volatile than higher-rated securities of similar maturity. Interest-Rate Risk – The risk that fixed income securities will decline in value because of an increase in interest rates. 19  Issuer Risk – The value of a security may decline because of adverse events or circumstances that directly relate to conditions at the issuer or any entity providing it credit or liquidity support. Issuer Non-Diversification Risk – The risks of focusing investments in a small number of issuers, industries, or foreign currencies, including being more susceptible to risks associated with a single economic, political or regulatory occurrence than a more diversified portfolio might be. Leverage Risk – The risk that certain portfolio transactions may give rise to leverage, causing the portfolio to be more volatile than if it had not been leveraged. Liquidity Risk – A security may not be able to be sold at the time desired or without adversely affecting the price. Management Risks - There is risk that the investment techniques and risk analysis applied by Finamex Asset Management, LLC may not produce the desired results. There is no guarantee that a client´s investment objective will be achieved. Market Risk – The market price of securities held by a portfolio may rapidly or unpredictably decline due to factors affecting securities markets generally or particular industries. Mortgage- and Asset-Backed Securities Risk – These securities may decline in value when defaults on the underlying mortgage or assets occur and may exhibit additional volatility in periods of changing interest rates. When interest rates decline, the prepayment of mortgages or assets underlying such securities may require the reinvestment of money at lower prevailing interest rates, resulting in reduced returns. Mutual Funds: Investing in mutual funds carries the risk of capital loss. Mutual funds are not guaranteed or insured by the FDIC or any other government agency. You can lose money investing in mutual funds. All mutual funds have costs that lower investment returns. They can be of bond “fixed income” nature (lower risk) or stock “equity” nature (mentioned above). Regulatory Risk – The risk that changes in government regulations may adversely affect the value of a security. An insufficiently regulated industry or market might also permit inappropriate practices that adversely affect an investment. Short Sale Risk – The risk of entering into short sales includes the potential loss of more money than the actual cost of the investment, and the risk that the third party to the short sale may fail to honor its contract terms, causing a loss to a portfolio. Private Securities Risk – Private securities contain the risks of their respective public securities, but these risks can be magnified due to their illiquidity and lack of public knowledge on the business. These securities are inherently riskier. Real Estate Risk – The real estate market has experienced some large swings recently. Due to changes in interest rates, the lending market, economic policy, and supply and demand, in addition to illiquidity, real estate investments can carry a great deal of risk. 20  Material risks of fundamental analysis: Vulnerability to wrong data, including assumptions: Fundamental analysis is heavily based in fact. But if a company incorrectly reports data or it is misinterpreted, it will probably lead to a false conclusion. Miscalculations are especially likely when making assumptions about things like a company’s future growth rate, future interest rates, or profits. Overreliance on past data: Perhaps the biggest risk against fundamental analysis is how much weight it puts in a company’s past performance. This may be correct because numbers companies report can be a month or more old. However, true fundamental analysis uses historical numbers to make an educated guess about the future. Bad timing: Fundamental analysts often have to be wrong for a long time before making money. Betting against the market: When a stock may appear to be an obvious buy, there may be cases that the market overall does not share the same view and may result in losses. Concentrated positions: Investors who use fundamental analysis may have large exposure to individual companies. This concept contradicts the idea of diversification, which is owning hundreds and hundreds of small pieces of many companies. With diversification, risk is spread over many companies so if one has a problem, it doesn’t affect so much. Fundamental analysts, though, think that owning just a few well-known investments is actually safer than owning everything. Material risks of chartists and technical analysis: Failure to properly use stock charts - In its most basic form, a stock chart helps read what the majority of investors are doing in the market. Without a stock chart, there is no way of getting the market's opinion. Technicals are essential to navigating the market. Lack of attention to detail / historical perspective - Providing comprehensive and objective technical research requires the analyst to consider market history and enough current charts to get a feel for the market's tone (bullish, bearish or neutral). Looking at a few charts per week and ignoring market history will only help to miss important details about the market's health. Individual / Firm Biases - Personal opinions are harmful in the stock market if they aren't backed up with objective market facts (what is known). Many seek advice on the stock market, but if they are getting advice from a biased (bullish or bearish) source, they will be misled if their guidance is not aligned with the market. The market represents the majority opinion and individual or group research may only be reflective of a minority opinion because of biases, etc. Getting too far ahead of the current data can be detrimental to reliable market analysis. Predicting instead of reading/interpreting the market is not a sound way to use technical analysis – Anticipate what may occur based on human emotion/common behaviors of price, but predicting and sticking to an outcome when the market is saying otherwise is not very helpful in technical research. 21  Unwillingness to change despite changing markets - Having rigid rules that govern your behavior/emotions is critical in investing, but believing/insisting that the market must always do one thing can be a bad habit that clouds your market/stock outlook. History tends to repeat itself, but you must also be open to new ideas and outcomes because market dynamics change. Material risks of cyclical analysis: Inflation - The incremental price increase of goods and services in an economy is highly cyclical and can pose its own risk to investors, while also causing cyclical risks in the economy. That is why commonly used inflation indexes, such as the Consumer Price Index (CPI) and the Wholesale Price Index (WPI), are closely monitored. Interest Rates - When inflation surges, central banks seek to encourage people to spend less by hiking interest rates. Eventually, this leads demand to taper off and company revenues and share prices to fall. Investors regularly focus on the yield curve to determine whether interest rates are likely to rise in the future. Signs that higher borrowing costs are forthcoming often lead cyclical stocks to fall out of favor and defensive, cash-rich firms to soar in popularity. Capital Expenditure - Companies often become greedy when times are good. Capacity is ramped up and competition intensifies until supply outstrips demand and profits vanish. Investors can look at capital expenditure (CapEx) to depreciation ratios to identify signs of excessive investment. Capital spending efficiency across entire nations can also be tracked by checking out capacity utilization rates. 22  ITEM 9: DISCIPLINARY INFORMATION Finamex Asset Management, LLC has no disciplinary events. A. Criminal or Civil Action Neither Finamex Asset Management, LLC, nor any of our employees, has had any civil or criminal actions brought against them. B. Administrative Procedure Finamex Asset Management, LLC has not had any administrative proceedings before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority. C. Self-Regulatory Organization Neither Finamex Asset Management, LLC, nor any of our employees, has had any proceedings before a self-regulatory organization. 23  INDUSTRY ACTIVITIES AND ITEM 10: OTHER FINANCIAL AFFILIATIONS A. Registration as a Broker/Dealer or Broker/Dealer Representative Pablo Andres Carrillo (CRD # 7977483) – President of Finamex Asset Management, LLC is also CAO for Finamex International, LLC, a fully introduced broker dealer that is an affiliated company of Finamex Asset Management, LLC. Finamex Asset Management (“FAM”) has a relationship with Finamex International, (“FI”), a related broker/dealer. Finamex International is registered with the Securities and Exchange Commission and is a member firm of FINRA. This affiliation creates a conflict in that FI will be used to execute portfolio transactions for investment advisory clients of FAM. In order to mitigate this conflict, FAM and FI will conduct these transactions subject to proper and customary disclosure regarding the two firms’ affiliation. Further, the Firm currently only uses FI International for the execution of transactions. Finamex International executes all equity trades on an Agency basis and all fixed income trades (corporate, and government bonds of both US and foreign entities) on a “Riskless Principal” basis with neither Finamex International nor the Firm receiving any compensation (in the form of commissions or markup/markdowns) as compensation for executing trades on either an Agency or “Riskless Principal” basis with the Firm’s clients. In addition, Finamex International will pass through the charges from its clearing broker. The only additional compensation that might be received by FAM based upon advisory account activities relates to money-market funds. This compensation is addressed below. Currently, Finamex International is designated by the client as the sole broker/dealer for the execution of securities transactions to be directed by FAM. If FAM utilizes a broker/dealer designated by the client other than FI to execute brokerage transactions, FAM may not have the authority to negotiate commissions or obtain volume discounts, thus best execution may not be achieved. If the client does utilize FI, a disparity in commission charges may exist in comparison to commission charges to clients of other portfolio managers not utilizing FI. Additionally, while FI will seek to obtain the best combination of price and execution for such transactions, lower commissions or better execution may be available elsewhere, for example, by the execution of the transaction through a so-called “discount broker." However, FI strives to seek the best combination of price and execution for transactions. If an investment advisory client utilizes FI as the broker/dealer, FAM’s selection of money-market mutual funds or comparable investments in which to hold cash reserves in the client's account is limited to certain investments. The selection includes money-market, municipal money-market and government money-market funds, and the issuers of funds pay FI a distribution fee in its capacity as a broker/dealer. FI may also receive additional compensation based on client account balances being held in the money-market funds. Additionally, cash balances arising from the sales of securities, redemption of debt securities, dividend and interest payments and funds received from clients are so invested automatically on a daily basis. When securities are sold, funds are deposited on the first business day after settlement date. Funds placed in a client's account by personal check usually will not be invested until the second business day following the day that 24  the deposit is credited to the client's account. Due to the foregoing practices, FI may obtain federal funds prior to the date that deposits are credited to client accounts and thus may realize some economic benefit because of the delay in investing these funds. Where an unaffiliated broker/dealer or other entity acts as custodian of the client's account assets, FAM has no control over the manner in which the cash reserves will be handled. The client and/or custodian will make that determination. Based upon the similarity of investments among client accounts having similar investment objectives and the fact that FAM may direct the purchase of securities for more than one account simultaneously, and the possible appearance of similarity in the treatment of clients, all client accounts are handled under the following basic conditions designed to prevent pooling of assets and/or the management of accounts on a de facto pooled basis resulting in the existence of an investment company. The custody of accounts held by the custodian on behalf of FI is structured such that each client’s securities are held in nominee name only for ministerial purposes and each client’s account is maintained as a separate account. The client’s beneficial interest in a security does not represent an undivided interest in all the securities held by the custodian but rather represents a direct and beneficial interest in the securities in the account. FI maintains a sole custodial arrangement with Stone-X Financial Inc., whereby FI clears securities transactions on a fully disclosed basis as an introducing broker. FAM and FI are also under common ownership with Casa de Bolsa Finamex, a Mexican registered securities broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator or a Commodity Trading Adviser Neither Finamex Asset Management, LLC nor its representatives are registered as a FCM, CPO or a CTA. C. Registration Relationships Material to This Advisory Business and Conflicts of Interest Pablo Andres Carrillo (CRD # 7977483) – President of Finamex Asset Management, LLC is also CAO for Finamex International, LLC, a fully introduced broker dealer that is an affiliated company of Finamex Asset Management, LLC. D. Selection of Other Advisors of Managers and How This Adviser is Compensated for Those Selections Finamex does not refer clients to any other advisors (such as sub-advisors) and thus does not pay or receive payment from other advisors. 25  ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. Code of Ethics Finamex Asset Management, LLC maintains an investment policy relative to personal securities transactions. This investment policy is part of Finamex Asset Management, LLC´s overall Code of Ethics, which serves to establish a standard of business conduct for all of Finamex Asset Management, LLC Representatives that is based upon fundamental principles of openness, integrity, honesty and trust, a copy of which is available upon request. Finamex endeavors at all times to put the interest of its clients first as part of our fiduciary duty as a registered investment adviser; we take the following steps to address this conflict: • Finamex discloses to clients the existence of all material conflicts of interest, including the potential for F i n a m e x and our employees to earn compensation from advisory clients in addition to advisory fees; • Finamex discloses to clients that they are not obligated to purchase recommended investment products from employees or the investment managers or investment funds; • Finamex collects, maintains and documents accurate, complete and relevant client background information, including the client’s financial goals, objectives and risk tolerance; • Finamex conducts regular reviews of each client account to verify that all recommendations made to a client are suitable to the client’s needs and circumstances; • Finamex requires that its employees seek prior approval of any outside employment activity so that we may ensure that any conflicts of interests in such activities are properly addressed; • Finamex periodically monitors these outside employment activities to verify that any conflicts of interest continue to be properly addressed by Finamex; and Finamex educates our employees regarding the responsibilities of a fiduciary, including the need for having a reasonable and independent basis for the investment advice provided to clients. B. Recommendations Involving Material Financial Interests Finamex Asset Management, LLC does not recommend that clients buy or sell any security in which a related person to Finamex Asset Management LLC has a financial interest. 26  C. Investing in the Same Securities as Clients Finamex Asset Management, LLC and / or its representatives may buy or sell securities that are also recommended to clients. This practice creates a situation where Finamex Asset Management, LLC and its representatives are in a position from the sale or purchase of those securities. Therefore, this situation creates a conflict of interest. Practices such as “scalping” (i.e., the practice whereby the owner of shares of a security recommends that security for investment and immediately sells it a profit upon the rise in the market price which follows the recommendation) could take place if Finamex Asset Management, LLC did not have adequate policies to detect such activities. In addition, this requirement can help detect insider trading, “front-running” (i.e., personal trades executed prior to those of Finamex Asset Management, LLC´s clients) and other potentially abusive practices. D. Trading the Same Securities as Clients’ Securities Finamex Asset Management, LLC has a personal securities transaction policy in place to monitor the personal securities transactions and securities holdings of each of Finamex Asset Management, LLC “Access Persons”. Finamex Asset Management, LLC securities transaction policy requires that an “Access Person” must provide the Chief Compliance Officer or his / her designee with a written report of their current securities holdings within ten (10) days after becoming an “Access Person”. Additionally, each “Access Person” must provide the Chief Compliance Officer or his/her designee with a written report of the “Access Person´s” current holdings at least once quarterly as well as each twelve (12) month period thereafter on a date Finamex Asset Management, LLC selects. 27  ITEM 12: BROKERAGE PRACTICES A. Selecting Brokerage Firms In the event that the client requests that Finamex Asset Management, LLC recommended a broker dealer / custodian for execution and / or custodial services, Finamex Asset Management, LLC recommends that investment advisory accounts be maintained at Finamex International, LLC. Prior to engaging Finamex Asset Management, LLC to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with Finamex Asset Management, LLC setting forth the terms and conditions under which Finamex Asset Management, LLC shall advise on the client´s assets, and a separate custodial/clearing agreement with Finamex International, LLC. There is no minimum client number or dollar number that Finamex Asset Management, LLC must meet in order to receive free research from the custodian or broker/dealer. There is no incentive to for Finamex Asset Management, LLC to direct clients to this particular broker-dealer over other broker-dealers who offer the same services. The first consideration when recommending broker/dealers to clients is best execution. 1. Research and Other Soft Dollar Benefits Finamex Asset Management, LLC receives no research, product, or services other than execution from Finamex International, LLC or third-party in connection with client securities transactions (“soft dollar benefits”). 2. Brokerage for Client Referrals Finamex Asset Management, LLC will not pay compensation to affiliates in Mexico for referrals that open accounts with the Firm. The Firm does not use promoters for referrals to the Firm. 3. Directed Brokerage Finamex Asset Management, LLC allows clients to direct brokerage. Finamex Asset Management, LLC may be unable to achieve most favorable execution of client transactions if clients choose to direct brokerage. This may cost clients’ money because without the ability to direct brokerage Finamex Asset Management, LLC may not be able to aggregate orders to reduce transactions costs resulting in higher brokerage commissions and less favorable prices. Not all investment advisers allow their clients to direct brokerage. 28  B. Aggregation of Securities for Multiple Client Accounts Finamex Asset Management, LLC maintains the ability to block trade purchases across accounts. Block trading may benefit a large group of clients by providing Finamex Asset Management, LLC the ability to purchase larger blocks resulting in smaller transaction costs for the client. Declining to block trade can cause more expensive trades for clients. 29  ITEM 13: REVIEW OF ACCOUNTS A. Periodic Reviews Client accounts are reviewed daily by the Chief Compliance Officer. The client specific advisors are instructed to review clients’ accounts with regard to their investment policies and risk tolerance levels on a regular basis, but no less than annually. All accounts at Finamex Asset Management, LLC are assigned to these reviewers. B. Factors that Will Trigger Non-Periodic Reviews Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Reports Provided to Clients Each client will receive at least quarterly from the custodian, a statement that details the client’s account including assets held and asset value which will come from the custodian. 30  ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION A. Third Party Compensation Finamex Asset Management, LLC does not receive any economic benefit, directly or indirectly from any third party for advice rendered to Finamex Asset Management, LLC clients. B. Referrals Finamex Asset Management, LLC will not pay compensation to affiliates in Mexico for referrals that open accounts with the Firm. The Firm does not use promoters for referrals to the Firm. 31  ITEM 15: CUSTODY Finamex Asset Management, LLC will not have custody of client assets, with the exception of the ability to deduct its advisory fee from the client´s custodial account. Clients are provided with written transaction confirmation notices, and a written summary account statement directly from the custodian at least quarterly. 32  ITEM 16: INVESTMENT DISCRETION For those client accounts where Finamex Asset Management, LLC provides ongoing supervision, and as designated in the client’s specific investment advisory agreement, clients may provide Finamex Asset Management, LLC written discretionary authority over the client’s accounts with respect to securities to be bought or sold and the amount of securities to be bought or sold. Details of this relationship are fully disclosed to the client before any advisory relationship has commenced. The client provides Finamex Asset Management, LLC discretionary authority via a limited power of attorney in the Investment Advisory Contract and in the contract between the client and the custodian. Any limitations regarding discretion over a client’s account will be handled on a case-by-case basis. 33  ITEM 17: VOTING CLIENT SECURITIES Finamex Asset Management, LLC does not take any action or render any advice with respect to the voting of proxies solicited by, or with respect to, the issuers of any securities held in the client accounts. The Firm’s clients will receive their proxy materials directly from their respective custodian or transfer agent and may contact the Firm for any questions about such proxy materials, The Firm will not provide advice to its clients as to how to vote the respective proxies. 34  ITEM 18: FINANCIAL INFORMATION A. Balance Sheet Finamex Asset Management, LLC does not require a client to pay advisory fees six months in advance. As such, the Firm is not required to provide clients with the Firm’s balance sheet. B. Financial Conditions Neither Finamex Asset Management, LLC nor its management have any financial conditions that are likely to reasonably impair the Adviser’s ability to meet contractual commitments to clients. 35