Geneva Partners, LLC

Part 2A of Form ADV: Firm Brochure Geneva Partners, LLC 820 Geneva Parkway North Suite 106 Lake Geneva, Wisconsin 53147 Telephone: 262-248-1350 Email: schwefel@genevapartnersllc.com Web Address: www.genevapartnersllc.com March 26, 2026 This brochure provides information about the qualifications and business practices of Geneva Partners, LLC. If you have any questions about the contents of this brochure, please contact us at 262-248-1350 or schwefel@genevapartnersllc.com. 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. Registration with the SEC does not imply a certain level of skill or training. Additional information about Geneva Partners, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Our firm's CRD number is 130768.  Item 2 Material Changes This Firm Brochure is our new disclosure document prepared according to the SEC’s new requirements and rules. Since the last annual update of our brochure on March 11, 2025, we note the following material changes: Geneva Partners moved its office location to 820 Geneva Parkway North, Suite 106, Lake Geneva, WI 53147, effective December 15, 2025. 2  Item 3 Table of Contents Page 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 ................................................................................. 5 Item 6 Performance-Based Fees and Side-By-Side Management ............................ 7 Item 7 Types of Clients .............................................................................................. 7 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ....................... 8 Item 9 Disciplinary Information ................................................................................. 10 Item 10 Other Financial Industry Activities and Affiliations ........................................ 11 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................................................................................... 11 Item 12 Brokerage Practices ...................................................................................... 13 Item 13 Review of Accounts ...................................................................................... 15 Item 14 Client Referrals and Other Compensation .................................................... 15 Item 15 Custody ......................................................................................................... 15 Item 16 Investment Discretion ................................................................................... 16 Item 17 Voting Client Securities ................................................................................. 16 Item 18 Financial Information ..................................................................................... 16 3  Item 4 Advisory Business Geneva Partners, LLC is an SEC-registered investment adviser with its principal place of business located in Wisconsin. Geneva Partners, LLC (“Geneva Partners”) began conducting business in 2010. Steven Schwefel is the Managing Member and sole owner of Geneva Partners. Geneva Partners offers the following advisory services to our clients: INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Our investment recommendations are not limited to any specific product or service offered by a broker-dealer or insurance company and will generally include advice regarding the following securities: • Exchange-listed securities • Securities traded over-the-counter • Foreign issuers • Corporate debt securities (other than commercial paper) • Certificates of deposit • Municipal securities • Mutual fund shares • United States governmental securities 4  Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. AMOUNT OF MANAGED ASSETS As of December 31, 2025, we were actively managing $423,600,852 of clients' assets on a discretionary basis. Item 5 Fees and Compensation INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT FEES The maximum annualized fee for Investment Supervisory Services is charged quarterly in advance, as a percentage of assets under management (including cash), valued as of the last day of the preceding quarter, according to the following schedule. The Firm will bill all assets at one fee level for whatever range in which the client’s assets fall with the following schedule: Assets Under Management Annual Fee $100,000 - $500,000 1.50% $500,001 - $2,000,000 1.25% $2,000,001 - $5,000,000 1.00% $5,000,001 - $10,000,000 .75% Over $10,000,000 Negotiable Certain legacy clients are billed at a fee rate different than the standard fee rate included above. A minimum of $100,000 of assets under management is required for this service. This account size is negotiable under certain circumstances. From time to time, Geneva Partners groups certain related client accounts for the purposes of achieving the minimum account size and determining the maximum annualized fee. For those clients whose fees are calculated as a percentage of assets under management, to the extent that clients authorize the use of margin, and thus employ margin in their investment portfolios, Geneva Partners will bill on the gross market value of the portfolio, and not net of any margin debt. Limited Negotiability of Advisory Fees: Although Geneva Partners has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Client facts, circumstances and needs are considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; 5  portfolio style, account composition, reports, among other factors. The specific annual fee schedule is identified in the contract between the adviser and each client. From time to time, we group certain related client accounts for the purposes of achieving the minimum account size requirements and determining the maximum annualized fee. Discounts, not generally available to our advisory clients, are sometimes offered to family members and friends of associated persons of our firm. GENERAL INFORMATION Termination of the Advisory Relationship: A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days written notice. An advisory client has a right to terminate the contract without penalty within five (5) business days after entering into the contract. As disclosed above, fees are paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a client's reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the billing period. Mutual Fund Fees: All fees paid to Geneva Partners for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs 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. If the fund also imposes sales charges, a client will pay either an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Additional Fees and Expenses: In addition to our advisory fees, clients are also responsible for the fees and expenses charged by custodians and imposed by broker dealers, including, but not limited to, any transaction charges imposed by a broker dealer with which an independent investment manager effects transactions for the client's account(s). Please refer to the "Brokerage Practices" section (Item 12) of this Form ADV for additional information. Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to Geneva Partners’ minimum account requirements and advisory fees in effect at the time the client enters into the advisory relationship. Therefore, our firm's minimum account requirements will differ among clients. 6  ERISA Accounts: Geneva Partners is deemed to be a fiduciary to advisory clients that are employee benefit plans or individual retirement accounts (IRAs) pursuant to the Employee Retirement Income and Securities Act ("ERISA"), and regulations under the Internal Revenue Code of 1986 (the "Code"), respectively. As such, our firm is subject to specific duties and obligations under ERISA and the Internal Revenue Code that include among other things, restrictions concerning certain forms of compensation. To avoid engaging in prohibited transactions, Geneva Partners will only charge fees for investment advice about products for which our firm and/or our related persons do not receive any commissions or 12b-1 fees, or conversely, investment advice about products for which our firm and/or our related persons receive commissions or 12b-1 fees, however, only when such fees are used to offset Geneva Partners’ advisory fees. As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any non-waivable rights you possess. Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1200 more than six months in advance of services rendered. Item 6 Performance-Based Fees and Side-By-Side Management Geneva Partners does not charge performance-based fees. Types of Clients Item 7 Geneva Partners provides advisory services to the following types of clients: • Individuals (other than high net worth individuals) • High net worth individuals • Charitable organizations • Pension and Profit-Sharing Plans • Other As previously disclosed in Item 5, our firm has established certain initial minimum account requirements, based on the nature of the service(s) being provided. For a more detailed understanding of those requirements, please review the disclosures provided in each applicable service. 7  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss METHODS OF ANALYSIS We use the following methods of analysis in formulating our investment advice and/or managing client assets: Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company 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 considered in evaluating the stock. 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 that a poorly managed or financially unsound company may underperform regardless of market movement. Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. INVESTMENT STRATEGIES We use the following strategy(is) in managing client accounts, provided that such strategy(ies) are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. We purchase securities with the idea of holding them in the client's account for a year or longer. Typically, we employ this strategy when: • we believe the securities to be currently undervalued, and/or • we want exposure to a particular asset class over time, regardless of the current projection for this class. A risk in a long-term purchase strategy is that by holding the security for this length of 8  time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Short-term purchases. When utilizing this strategy, we purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy, and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. Risk of Loss. Securities investments are not guaranteed, and you may lose money on your investments. Investors face the following investment risks: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. • 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. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • 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 9  company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy or a declining market value. • Cybersecurity Risk: The computer systems, networks and devices used by Geneva Partners and service providers to us and our clients to carry out routine business operations employ a variety of protections designed to prevent damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches. Despite the various protections utilized, systems, networks, or devices potentially can be breached. A client could be negatively impacted as a result of a cybersecurity breach. Cybersecurity breaches can include unauthorized access to systems, networks, or devices; infection from computer viruses or other malicious software code; and attacks that shut down, disable, slow, or otherwise disrupt operations, business processes, or website access or functionality. Cybersecurity breaches may cause disruptions and impact business operations, potentially resulting in financial losses to a client; impediments to trading; the inability by us and other service providers to transact business; violations of applicable privacy and other laws; regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs; as well as the inadvertent release of confidential information. Similar adverse consequences could result from cybersecurity breaches affecting issuers of securities in which a client invests; governmental and other regulatory authorities; exchange and other financial market operators, banks, brokers, dealers, and other financial institutions; and other parties. In addition, substantial costs may be incurred by these entities in order to prevent any cybersecurity breaches in the future. Item 9 Disciplinary Information We are required to disclose 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. Our firm and our management personnel have no reportable disciplinary events to disclose. 10  Item 10 Other Financial Industry Activities and Affiliations Some of Geneva Partners’ investment advisory representatives are also licensed as insurance agents with the States of Illinois or Wisconsin. They sell insurance products or fixed annuities to advisory clients of Geneva Partners, but the clients are under no obligation to purchase their insurance products or annuities through them. The advisory representatives earn the usual and customary compensation for the sale of any insurance or annuity products, which is in addition to advisory fees advisory clients pay to Geneva Partners. The advisory representatives also receive trails for legacy variable annuities. Receiving compensation creates an incentive to recommend insurance or annuity products based on the compensation to be received rather than a client’s needs. Clients are free to accept or reject the recommendations, as they wish. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal securities laws. Geneva Partners and our personnel owe a duty of loyalty, fairness and good faith towards our clients, and have an obligation to adhere not only to the specific provisions of the Code of Ethics but to the general principles that guide the Code. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports as well as initial and annual securities holdings reports that must be submitted by the firm’s access persons. Among other things, our Code of Ethics also requires the prior approval of any acquisition of securities in a limited offering (e.g., private placement) or an initial public offering. Our code also provides for oversight, enforcement and recordkeeping provisions. Geneva Partners’ Code of Ethics further includes the firm's policy prohibiting the use of material non-public information. While we do not believe that we have any particular access to non-public information, all employees are reminded that such information may not be used in a personal or professional capacity. A copy of our Code of Ethics is available to our advisory clients and prospective clients. You may request a copy by email sent to schwefel@genevapartnersllc.com, or by calling us at 262-248-1350. Our Code of Ethics is designed to assure that the personal securities transactions, activities and interests of our employees will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Our firm and/or individuals associated with our firm may buy or sell for their personal account’s securities identical to or different from those recommended to our clients. In 11  addition, any related person(s) may have an interest or position in a certain security(ies) that are recommended to clients. In certain situations, we aggregate our employee trades with client transactions where possible and when compliant with our duty to seek best execution for our clients. In these instances, participating clients will receive an average share price and transaction costs will be shared equally and on a pro-rata basis. In the instances where there is a partial fill of a particular batched order, we will allocate all purchases pro-rata, with each account paying the average price. Our employee accounts will be included in the pro-rata allocation. As these situations represent actual or potential conflicts of interest to our clients, we have established the following policies and procedures for implementing our firm’s Code of Ethics, to ensure our firm complies with its regulatory obligations and provides our clients and potential clients with full and fair disclosure of such conflicts of interest: 1. No principal or employee of our firm may put his or her own interest above the interest of an advisory client. 2. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is a result of information received as a result of his or her employment unless the information is also available to the investing public. 3. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account. This prevents such employees from benefiting from transactions placed on behalf of advisory accounts. 4. Our firm requires prior approval for any IPO or private placement investments by related persons of the firm. 5. We maintain a list of all reportable securities holdings for our firm and anyone associated with this advisory practice that has access to advisory recommendations ("access person"). These holdings are reviewed on a regular basis by our firm's Chief Compliance Officer or his/her designee. 6. We have established procedures for the maintenance of all required books and records. 7. All of our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices. 8. We require delivery and acknowledgement of the Code of Ethics by each supervised person of our firm. 12  9. We have established policies requiring the reporting of Code of Ethics violations to our senior management. 10. Any individual who violates any of the above restrictions may be subject to termination. Item 12 Brokerage Practices Directed Brokerage Geneva Partners requires that clients provide us with written authority to determine the broker-dealer to use and the commission costs that will be charged to our clients for these transactions. Clients must include any limitations on this discretionary authority in this written authority statement. Clients may change/amend these limitations as required. Such amendments must be provided to us in writing. Clients who have directed brokerage away from Geneva Partners’ standard custodian may pay higher costs and may not be able to be included in client block trades to achieve average price and possibly lower cost of execution. Trade Aggregation Geneva Partners will block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client accounts, so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. In certain situations, block trading allows us to execute equity trades in a timelier, more equitable manner, at an average share price. Geneva Partners will typically aggregate trades among clients whose accounts can be traded at a given broker, and generally will rotate or vary the order of brokers through which it places trades for clients on any particular day. Research and Other Soft Dollar Benefits Geneva Partners has an arrangement with National Financial Services LLC, and Fidelity Brokerage Services LLC (together with all affiliates, "Fidelity") through which Fidelity provides our firm with their "platform" services. The platform services include, among others, brokerage, custodial, administrative support, record keeping and related services that are intended to support intermediaries like Geneva Partners in conducting business and in serving the best interests of our clients but that also benefit us. Fidelity charges brokerage commissions and transaction fees for effecting certain securities transactions (i.e., transactions fees are charged for certain no-load mutual funds, commissions are charged for individual equity and debt securities transactions). In addition, Fidelity will charge a “trade-away” fee if client trades are placed with other brokers, generally for fixed income trades. Fidelity enables Geneva Partners to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Fidelity’s commission rates are generally considered discounted from customary retail 13  commission rates. However, the commissions and transaction fees charged by Fidelity may be higher or lower than those charged by other custodians and broker-dealers. As part of the arrangement, Fidelity also makes available to our firm, at no additional charge to us, certain research and brokerage services, including research services obtained by Fidelity directly from independent research companies, as selected by Geneva Partners (within specified parameters). These research and brokerage services presently include services such as administrative support, record keeping and related services and are used by our firm to manage accounts for which we have investment discretion. Geneva Partners also receives additional services which include software and technology to provide access to client data, facilitate trade execution, assist with back office support, record keeping and client reporting. Without this arrangement, we might be compelled to purchase the same or similar services at our own expense. As a result of receiving such services for no additional cost, we have an incentive to continue to use or expand the use of Fidelity's services. We examined this potential conflict of interest when we chose to enter into the relationship with Fidelity and have determined that the relationship is in the best interests of Geneva Partners’ clients and satisfies our client obligations, including our duty to seek best execution. A client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, while Geneva Partners will seek competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest possible commission rates for specific client account transactions. Although the investment research products and services that we obtain will generally be used to service all of our clients, a brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client’s account. Geneva Partners and Fidelity are not affiliated. Brokerage for Client Referrals Geneva Partners does not direct brokerage for client referrals. Trade Errors Geneva Partners corrects all trade errors made through its Trade Error Account, except for those which resulted from an unsolicited trade made on behalf of the client. Gains and losses resulting from trade errors settled in the Trade Error Account are netted and reset at the end of each quarter. Geneva Partners shall be responsible for any losses in the accounts. Any gains are generally donated to charity. Client shall be responsible for any trade error which results from an unsolicited trade made on behalf of the client. 14  Item 13 Review of Accounts INVESTMENT SUPERVISORY SERVICES ("ISS") INDIVIDUAL PORTFOLIO MANAGEMENT REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed at least monthly. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are reviewed by Steven P. Schwefel, Managing Member of Geneva Partners, LLC. REPORTS: In addition to the monthly statements and confirmations of transactions that clients receive from their broker-dealer, we seek to provide quarterly reports summarizing account performance, balances and holdings at client meetings or by request of the client. Item 14 Client Referrals and Other Compensation Geneva Partners does not compensate any third parties for referring clients to the Firm. Any such arrangement that Geneva Partners enters into in the future will comply with the requirements of Rule 206(4)-1 relating to testimonials and endorsements. One of Geneva Partners’ representatives, Scott Farrow, has an outside accounting firm which provides accounting services to some of Geneva Partners’ clients. On occasion, Geneva Partners pays Farrow & Associates for tax preparation services provided to certain advisory clients of Geneva Partners. Mr. Farrow earns the usual and ordinary compensation from his accounting business activity. Item 15 Custody We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. Our firm has custody pursuant to its ability to transfer funds via a customer signed 15  Standing Letters of Authorization. These transfer authorizations meet the requirements of the SEC’s interpretative guidance re: custody in its No-Action letter to the Investment Advisors Association dated February 21, 2017. Item 16 Investment Discretion Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: • determine the security to buy or sell; and/or • determine the amount of the security to buy or sell Clients give us discretionary authority when they sign a discretionary agreement with our firm and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. Geneva Partners requires that it be provided with written authority to determine which securities and the amounts of securities that are bought or sold in a client's account. Item 17 Voting Client Securities As a matter of firm policy, we do not vote proxies on behalf of clients. Clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Clients are responsible for instructing each custodian of the assets, to forward to the client copies of all proxies and shareholder communications relating to the client’s investment assets. From time to time, we provide clients with consulting assistance regarding proxy issues if they contact us with questions at our principal place of business. Item 18 Financial Information Under no circumstances do we require or solicit payment of fees in excess of $1200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. As an advisory firm that maintains discretionary authority for client accounts, we are also required to disclose any financial condition that is reasonable likely to impair our ability to meet our contractual obligations. Geneva Partners has not been the subject of a bankruptcy petition at any time during the past ten years. 16