GENTRUST

Form ADV Part 2A -Brochure Document GenTrust, LLC March 2026 1450 Brickell Avenue Suite 3050 Miami, Florida 33131 Telephone: (305) 677-6688 Email: info@gentrustwm.com www.gentrustwm.com This Brochure (the “Brochure Document”) provides information about the qualifications and business practices of GenTrust, LLC (hereinafter “GenTrust”). If you have any questions about the contents of this Brochure Document, please contact us at (305) 677-6688 or by email at info@gentrustwm.com. information about GenTrust is available on GenTrust is an SEC registered investment adviser. Registration does not imply any level of skill or training. The information in this Brochure Document has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional the SEC’s website at www.adviserinfo.sec.gov  Item 2 Material Changes This Brochure provides information about a variety of topics relating to the Adviser’s business practices, compliance policies and procedures, and conflicts of interest. The Adviser routinely updates the Brochure to improve and clarify the description of such information or in response to evolving industry or firm practices. Since the last annual amendment that was filed on March 26, 2025, in addition to formatting, clarifying, and editing changes we have made the following updates: Item 4-Senior Management Changes. Since the Firm’s most recent annual amendment, the duties once overseen by the President and Chief Operating Officer have been assigned to current senior management team members. Item 4- Assets Under Management. The Firm has updated its assets under management information to reflect current figures as of December 31, 2025. Item 5- Fees and Compensation. We provide disclosure of a conflict of interest regarding a performance-based incentive compensation arrangement with one of the Firm’s principals related to the performance of fixed income investments in client portfolios. Consistent with SEC requirements, we will ensure that you receive a summary of any material changes to this and subsequent Firm Brochures within 120 days of the close of our business’ fiscal year. Furthermore, we will provide you with other interim disclosures about material changes, as appropriate. A copy of GenTrust’s complete Form ADV Brochure Document and Brochure Supplement is available without charge by contacting GenTrust at (305) 677-6688. Additional information about GenTrust is also available on the SEC’s website at: www.adviserinfo.sec.gov 2  Item 3 Table of Contents Item 4 Advisory Business ..................................................................................................................... 4 Item 5 Fees and Compensation ............................................................................................................. 8 Item 6 Performance-Based Fees and Side-by-Side Management ....................................................... 14 Item 7 Types of Clients....................................................................................................................... 14 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 14 Item 9 Disciplinary Information ......................................................................................................... 21 Item 10 Other Financial Industry Activities and Affiliations .............................................................. 21 Item 11 Code of Ethics ......................................................................................................................... 22 Item 12 Brokerage Practices ................................................................................................................. 23 Item 13 Review of Accounts ................................................................................................................ 27 Item 14 Client Referrals and Other Compensation ............................................................................... 28 Item 15 Custody .................................................................................................................................... 28 Item 16 Investment Discretion .............................................................................................................. 29 Item 17 Voting Client Securities .......................................................................................................... 29 Item 18 Financial Information .............................................................................................................. 30 3  Item 4 Advisory Business GenTrust, LLC is a limited liability company organized under the laws of the State of Delaware and registered with the Securities and Exchange Commission as an investment adviser. The Firm is a majority‑owned James Besaw, George Perez, Guillermo Socarras, and Eli Cohen. Kudu Investment US, LLC, (“Kudu”) a Delaware limited liability company, owns a passive, non- controlling minority stake in GenTrust. The President and COO resigned, with their responsibilities reassigned to senior management. The Firm's advisory services, investment authority, and client service continue unchanged. GenTrust provides wealth management, investment management, financial planning, and consulting services. Before engaging GenTrust to provide any of the foregoing investment advisory services, clients are required to enter into a written agreement with GenTrust setting forth the terms and conditions under which GenTrust renders its services (an “Agreement”). GenTrust does not participate in wrap fee programs by providing portfolio management services; accordingly, this item is not applicable. As of December 31,2025, GenTrust managed $ 5,202,073,997 in assets, of which $3,875,243,125 are on a discretionary basis and $1,326,830,872 are on a non-discretionary basis. Financial Planning, Consulting, and Concierge Services GenTrust offers clients a broad range of comprehensive financial planning, consulting, and concierge services. These services are tailored to the individual needs of the client, but may include among other services, income planning, cash flow analysis, and budgeting. GenTrust’s concierge services include assistance with the essential lifestyle needs of high-net-worth clients, such as coordinating bill pay, travel planning. In addition, clients may engage GenTrust to provide consulting and advisory services regarding assets not managed by GenTrust. In such circumstances, GenTrust reviews and analyzes client assets held away, provides advice, opinions, and investment recommendations, and may assist with asset allocation or strategy considerations; however, GenTrust does not have the authority to implement transactions or exercise investment discretion over such assets. Services to Financial Intermediaries GenTrust also provides, on a fee basis, research, consulting, research reports, and support services to investment advisory firms (“Financial Intermediaries”) to assist such firms in providing manager recommendations, monitoring, and reporting services to the Financial Intermediary’s Clients (“Financial Intermediary Clients”). Depending on the scope of the agreement, Financial Intermediaries may receive model portfolios, third-party manager due diligence, reporting, marketing, training, and other services or support from GenTrust, including the use of GenTrust’s 4  office space at market rates. Depending on the applicable agreement and client mandate, portfolios may be managed on a discretionary basis, a non-discretionary basis, or pursuant to a specific investment strategy, model portfolio, or set of guidelines provided by GenTrust or agreed upon with the Financial Intermediary or its clients. In non-discretionary arrangements, GenTrust provides investment recommendations only and does not have authority to implement transactions without prior approval. Financial Intermediaries and their clients retain ultimate authority over investment decisions unless discretionary authority has been expressly granted in writing. GenTrust may recommend the services of other investment professionals to implement investment recommendations. Clients and Financial Intermediary Clients are under no obligation to act upon any of the recommendations made by GenTrust under a financial planning or Financial Intermediary engagement or to engage the services of any such recommended professional, including GenTrust itself. Clients and Financial Intermediaries retain discretion to determine whether to grant GenTrust discretionary investment authority and may impose reasonable investment restrictions at the outset of the engagement or from time to time thereafter. Once discretionary authority is granted, GenTrust is responsible for the day-to-day implementation of investment decisions in accordance with the agreed-upon mandate, without prior approval from the client or Financial Intermediary. Clients and Financial Intermediaries may modify restrictions or terminate discretionary authority in accordance with the applicable agreement. Clients and Financial Intermediaries are responsible for promptly notifying GenTrust if there is any change in their financial situation or investment objectives to review, evaluate, or revise GenTrust’s previous recommendations and/or services. Investment Management Services Clients can engage GenTrust to manage all or a portion of their assets on a discretionary or non- discretionary basis, which may include all or part of the financial planning, concierge, or consulting services discussed above. GenTrust generally allocates clients’ assets to mutual funds, equities, exchange-traded funds (“ETFs”), individual debt and equity securities, options, independent managers, and other securities in accordance with their individual investment objectives. In addition, when consistent with the clients’ investment objectives, GenTrust may recommend that clients who are “accredited investors” as defined under Rule 501 of the Securities Act of 1933 (“Securities Act”) or “qualified purchasers” as defined under Section 2(a)(51) of the Investment Company Act of 1940 (“Investment Company Act”), as amended, invest in strategies offered through private placement securities, which may include debt, equity, and/or pooled investment vehicles (e.g., hedge funds), including private investments of GenTrust’s affiliate, Catenary Alternatives Asset Management, LLC (“CAAM”). GenTrust may also provide advice concerning positions or investments held in clients’ portfolios. GenTrust may also be engaged to provide these services as a sub-adviser to clients of Financial Intermediaries (“Sub-advisory Clients”). 5  GenTrust tailors its advisory services to the individual needs of clients. GenTrust consults with clients initially and periodically to determine risk tolerance, time horizon, and other factors that can affect a client’s investment needs and, together with the client, to select an appropriate benchmark. The benchmark, which consists primarily of widely recognized market indexes, allows the client to track GenTrust’s returns relative to the broader investible universe and evaluate the portfolio’s performance against the client’s agreed-upon goals and risk level. The client’s benchmark is updated as needed, typically when there is a material change in the client’s risk profile or when a predetermined asset allocation strategy gradually shifts the investment portfolio's allocation over time (“glidepath”). Clients should promptly notify GenTrust of any changes in their financial situation or investment objectives. Clients may request reasonable restrictions or mandates on the management of their account if, in GenTrust’s sole discretion, the conditions will not materially impact the performance of a portfolio strategy or prove overly burdensome to its management efforts. Retirement Account Rollovers We offer recommendations and advice concerning employer retirement plans or other qualified retirement accounts. Our recommendations may include that the client consider withdrawing assets from his/her employer’s retirement plan or other qualified retirement account and rolling them over into an individual retirement account (IRA) or another qualified investment vehicle. If a client elects to roll assets into an IRA subject to our management, we will charge an asset-based fee as described in Item 5 of this Brochure Document. This poses a conflict of interest because we have an incentive to recommend a rollover to generate compensation rather than solely based on the client’s needs. As a fiduciary, we are required to always act in the client’s best interests. Clients are under no obligation, contractually or otherwise, to roll over their retirement assets or to have their assets rolled into an IRA managed by us. Clients need to understand that many employer retirement plan sponsors permit former employees to keep their retirement assets in their company plan, even after they terminate employment or retire. When deciding whether to roll over employment retirement plan assets into an IRA or another investment vehicle, clients should consider the costs and benefits of each option. Employees will typically have the following options:  Leave the funds in the employee's (or former employee’s) plan.  Move the funds to their new employee's retirement plan.  Withdraw the funds from the plan, which results in a taxable distribution and a taxable event.  Roll over the funds into an IRA or other qualified plan. Before making any changes to their plan, we encourage clients to carefully consider the tax implications with their accountant or tax advisor. Below is some general information on the differences and features between an employer 401(k) plan and an IRA. Clients should consider these differences and features before deciding to roll over plan assets to an IRA. Although employer retirement plans may have a more limited investment menu than the options available in an IRA, the plan could also offer unique investment opportunities not available to the public, such 6  as the ability to invest in the employer’s securities if the employer is publicly traded. The employer retirement plan may offer financial advice, guidance, and/or model management or portfolio options at no additional cost or at a fee that may be lower than our advisory fee. Clients should understand the various investments available in an IRA, as well as the associated costs. For information regarding our fees and expenses, please refer to Item 5 of this Brochure Document. In some cases, the employer retirement plan may allow participants to hire us as managers and keep the assets titled in the plan’s name. Clients interested in investing only in mutual funds should understand the cost structures of the share classes available in the employee’s retirement plan and how those costs compare with those in an IRA. It may be possible to take out a loan on 401k Plan assets. This option is not available for IRAs. It may be possible to delay taking minimum distributions from the 401 (k) Plan or retirement account beyond age 73. A 401 (k) plan may offer more liability protection than an IRA. Although IRA assets are generally protected from creditors in bankruptcy, depending on state law, there may be exceptions to the general rule. IRA distributions are subject to ordinary income tax and may also be subject to a 10% early distribution tax penalty unless they qualify for an exception. There are certain exceptions available based on age, disability, or if the assets are used to pay for higher education expenses or to purchase a home. Clients must understand the differences and options available, as well as the cost and tax implications, to determine whether an IRA rollover is appropriate. Use of Independent Managers and CAAM As mentioned above, GenTrust may, when appropriate, recommend independent third-party investment managers (“Independent Managers”) to manage all or a portion of a client’s assets. Additionally, GenTrust may also recommend investments managed by its affiliate, CAAM. The terms and conditions under which a client engages an Independent Manager are outlined in a separate written agreement between GenTrust or the client and the designated Independent Manager. GenTrust provides services to the client in connection with the discretionary selection of Independent Managers. GenTrust also monitors and reviews the account performance and the client’s investment objectives. Generally, GenTrust receives an annual advisory fee based on a percentage of the market value of the assets managed by the designated Independent Managers, but it does not receive additional compensation from CAAM. When recommending an Independent Manager for a client, GenTrust reviews information about the Independent Manager, such as its disclosure Brochure Document and/or material supplied by the Independent Manager or independent third parties, for a description of the Independent Manager’s investment strategies, past performance, and risk results, to the extent available. Factors that GenTrust considers in recommending an Independent Manager include the client’s stated investment objectives, management style, performance, reputation, financial strength, reporting, pricing, and research. The investment management fees charged by the designated Independent Managers, together with the fees charged by the corresponding designated broker-dealer/custodian of the client’s assets, are exclusive of, and in addition to, GenTrust’s investment advisory fee. Although GenTrust does not receive compensation from CAAM for recommending that clients invest in CAAM’s funds, such recommendations pose a conflict for GenTrust because (i) CAAM benefits from managing a larger portfolio of assets, (ii) certain owners of GenTrust are also owners 7  of CAAM, and therefore, they receive economic benefit from fees charged by a CAAM fund to a GenTrust investor. However, if GenTrust clients pay a management fee to a CAAM fund, the fund will be excluded from GenTrust’s advisory fee calculations. GenTrust manages this conflict through disclosure, so that clients can make an informed decision, and through policies and procedures that require it to act in its clients' best interests. In addition to GenTrust’s Form ADV Part 2A Brochure Document, clients also receive the Brochure Document from the designated Independent Manager or from CAAM. Certain Independent Managers may impose more restrictive account requirements and different billing practices than GenTrust. In such instances, GenTrust may alter its account requirements and/or billing practices to align with those of the Independent Managers. We also recommend that certain clients, if suitable, invest in Versus Capital Funds (VCM”), or Fund V, private funds that are beneficially owned and controlled by GenTrust clients. Kudu, one of our shareholders, is an investor in VCM. Additionally, GenTrust employees and management personnel are permitted to invest in the VCF and of Fund V. This represents a conflict of interest because investments made by our advisory clients in VCM or Fund V benefit other clients of the firm. We manage this conflict through disclosure so that investors can make an informed decision and agree to the conflict and through policies and procedures that require us to always act in our clients’ best interest, that all clients be treated fairly and equitably, and that employees or other clients do not receive preferential treatment in the management of their accounts. Item 5 Fees and Compensation GenTrust provides services to clients and financial intermediaries on a fee basis, which may consist of fixed fees, fees calculated as a percentage of assets under management, and/or fees based on portfolio performance. Investment Management Fees GenTrust provides investment management services for an annual fee, billed quarterly in advance on a pro-rata basis. GenTrust clients are charged a base fee, a fixed fee, or a combination of a base and a performance fee, as indicated in the GenTrust Client Agreement. GenTrust’s annual fees do not include brokerage commissions, transaction fees, and other related costs and expenses that may be incurred by a client. GenTrust’s investment advisory fee is agreed upon individually with each client, Financial Intermediaries and Financial Intermediary Clients. In general, GenTrust’s annual base fee (“base fee”) is prorated and charged quarterly in advance, based on the market value of the assets (including cash balances) managed by GenTrust on the last day of the previous quarter. Account 8  values are determined by the client’s custodian or other independent third-party sources. The annual base fee varies (up to 1.50%) depending upon the market value of the assets under management and the type of investment management services to be rendered. The Base Fee in the first quarter of any new account shall be prorated from the inception date to the end of the first quarter. After this initial period, no adjustment to the quarterly Base Fee will be made for any contributions or withdrawals of assets in the account[s] during each quarter. To the extent clients invest in products managed by GenTrust or its affiliates, the base fee may be waived for those assets. Assets are initially designated to GenTrust for management under the GenTrust Client Agreement. Accounts maintained solely for operating, bill payment, or other administrative purposes are not designated for investment management and are not subject to GenTrust’s investment advisory fees. Fees from Financial Intermediary Clients are paid to GenTrust under the terms of each Financial Intermediary Client’s investment management agreement. The Financial Intermediaries may have different billing practices than GenTrust. Such billing practices are disclosed in the Financial Intermediaries’ Disclosure Document. As appropriate and practicable, GenTrust may alter its billing practices to accommodate the Independent Managers' billing practices. Upon termination of an account, any investment management fees paid in advance will be refunded on a pro-rata basis based on the number of days remaining in the billing period. Performance Fees GenTrust may charge a performance-based fee to Qualified Clients as defined in Rule 205-3 of the Investment Advisers Act of 1940. For clients with performance fee arrangements, GenTrust charges a fee based on a percentage of the market value of the assets it manages, in addition to a fee based on the account's performance (“performance fee”). GenTrust may charge a performance fee of up to thirty-five percent (35%) of the net profits in certain accounts, as outlined in the client’s investment management agreement. GenTrust’s performance fee is charged annually, in arrears, based on the net gains of the client’s portfolio at the end of the calendar period (fiscal year-end) or as otherwise outlined in the client’s investment management agreement with GenTrust. GenTrust, in its sole discretion, may charge a lesser management or performance fee 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, pre-existing client, account retention, etc.). Performance-based fees may lead to increased payments to GenTrust and may encourage GenTrust to pursue investments with higher risks or speculative characteristics compared to those undertaken absent such compensation. GenTrust addresses this potential conflict by 9  providing full disclosure, enabling clients to make informed decisions, and by implementing policies and procedures that require it to act in the best interests of its clients. Performance Based Incentive Compensation One of the Firm’s principals receives incentive-based compensation paid by that is tied, in part, to the performance of fixed income investments within client portfolios managed by the Firm. This compensation is based on the aggregate relative performance (“alpha”) of fixed income assets across multiple client accounts, rather than the performance of any individual client account. In addition, this principal may also receive a portion of the performance -based fees earned by the Firm in connection with certain client accounts that are subject to performance -fee arrangements for fixed -income investments. Such arrangements may lead to conflicts of interest by incentivizing preferences for fixed-income allocations, performance-fee accounts, or investment decisions aimed at enhancing measured performance or alpha—including through the assumption of additional risk to obtain economic benefit—rather than adhering strictly to each client's unique investment objectives and risk tolerance. The Firm seeks to mitigate these conflicts through disclosure, and through its fiduciary duty and policies and procedures that require all GenTrust staff to act as fiduciaries and in the best interests of the clients. Additionally, the strategies are overseen by the Chief Investment Officer and Investment Committee that is designed to promote fair and equitable treatment of clients, including oversight of asset allocation and portfolio construction, risk management practices, and ongoing compliance supervision. Financial Planning, Reporting, and Consulting Services Fees To the extent not included as part of the firm’s investment management services, GenTrust may charge a fixed fee for financial planning, expense and budget reporting, and consulting services. These fees are negotiable but generally range from $1,000 to $150,000 per quarter, depending on the level and scope of services and the professional providing financial planning and/or consulting services. If the client engages GenTrust for additional investment advisory services, GenTrust may offset all or a portion of its fees for those services based upon the amount paid for the financial planning and/or consulting services. Before engaging GenTrust to provide financial planning, reporting, and/or consulting services, clients must enter into a written agreement with GenTrust that sets forth the terms and conditions of the engagement. Financial Intermediaries Fees GenTrust’s compensation for services rendered to Financial Intermediaries is generally a percentage of assets under management or a fixed fee. Investment Reporting Fees 10  Clients can engage GenTrust to provide investment reporting services for investments and/or accounts that are not managed by GenTrust or for which GenTrust does not provide investment advice (“Reported Assets”). The fee for this service is negotiable but is generally not greater than 0.25% of the Reported Assets, billed quarterly in advance and based on the market value of the Reported Assets as of the last day of the previous quarter. Additionally, GenTrust may offset all or a portion of its fees for investment reporting services based on the amount paid for the investment management services. Fees Charged by Financial Institutions As further discussed in response to Item 12 below, GenTrust generally recommends that clients utilize the brokerage, custodial, and clearing services of various broker-dealers, trust companies, or banks (collectively, “Financial Institutions”) for investment management accounts. GenTrust may only implement its investment management recommendations after a client has arranged for and furnished GenTrust with all information and authorization regarding accounts with appropriate Financial Institutions. Clients will generally incur certain charges imposed by Financial Institutions and other third parties, such as custodial fees, charges imposed directly by a mutual fund or ETF, deferred sales charges, odd-lot differentials, trade away fees, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Clients will also incur brokerage commissions and other transaction costs in connection with the management of their accounts; please refer to Item 12 of this Brochure for a detailed discussion of GenTrust's brokerage practices. The Financial Institutions, executing broker(s) and/or their affiliates may have distribution or similar arrangements with fund families and receive distribution fees and other compensation in the form of management fees, placement fees, sales charges, redemption fees, structuring fees, due diligence fees and trailer fees from products they issue, manage, and/or distribute, or from third-party providers. GenTrust’s clients may purchase fund shares directly from the funds without using GenTrust’s services or incurring our advisory fee. Clients may obtain share classes that are less expensive than those available through GenTrust. Please refer to the fund’s prospectus or offering documents for additional information. GenTrust does not receive trail commissions or 12b-1 fees. When investing in funds for a client’s portfolio, GenTrust generally seeks to invest in the share class that is most advantageous to the client under the circumstances. Mutual fund companies typically offer multiple share classes of the same fund. Share classes are described in the mutual fund's prospectus. Each share class charges different fees and internal expenses. Depending on the class selected, fees and internal expenses charges may be higher or lower. Certain funds do not charge a transaction fee but have higher internal expenses. Selecting 11  funds that charge higher fees and expenses may adversely impact an account’s long‐term performance. Clients will pay their proportionate share of the mutual fund’s management and administrative fees and sales charges, as set forth in the mutual fund prospectus. Such advisory fees are compensation to the mutual fund manager and are not shared with GenTrust. GenTrust generally recommends institutional or advisor share classes when available, which typically have the lowest expense ratios and are more beneficial than other share classes. Institutional or advisor share classes are usually available to investors in qualified fee‐based advisor programs, or accounts that meet certain minimum investment requirements. When deemed appropriate for a client’s specific situation, GenTrust may at times recommend selecting or holding a mutual fund share class that charges higher internal expenses than other available share classes for the same family. GenTrust will conduct periodic testing to ensure that the appropriate recommended share class has been selected for its clients. For share classes transferred in from other financial institutions, GenTrust will as soon as practicable, evaluate whether more beneficial share classes may be available for the client to exchange at no cost and recommend that the client switch to a different lower cost share class, or may recommend liquidating the existing mutual fund holdings, which could result in tax consequences, or the client having to pay contingent deferred sales charges, or other redemption fees. In addition to all other fees and expenses incurred in managing advisory accounts, client accounts that use margin strategies will incur interest charges. While the clients’ margin debit balance is typically not included when calculating GenTrust's fees, securities purchased and held on margin are included in GenTrust’s advisory fee calculations. This poses a conflict of interest for GenTrust, and we manage this risk through disclosure so that clients can make an informed decision, and through policies and procedures that require us to act in the client’s best interest. GenTrust’s Agreement and/or the agreement between a client and a Financial Institution typically authorizes GenTrust or an Independent Manager to debit the client’s account for the amount of GenTrust’s fee and to directly remit that management fee to GenTrust or the Independent Manager. Financial Institutions recommended by GenTrust offer clients online access to their accounts and have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account, including the amount of management fees paid directly to GenTrust. Alternatively, clients may elect to have GenTrust send an invoice for payment. Fees for Management during Partial Periods of Service Generally, for the initial period of investment management services, fees are calculated based on the inception date on a pro rata basis. An Agreement between GenTrust and a client will remain in effect until terminated by either party under its terms. GenTrust’s fees are prorated until the date GenTrust receives notice of termination, and any remaining balance is charged or refunded to the client. 12  Clients may make additions to and withdrawals from their accounts at any time, subject to GenTrust’s right to terminate an Agreement. Additions may be in cash or securities, provided that GenTrust reserves the right to liquidate any transferred securities or decline to accept management of particular securities in a client’s account. Clients may withdraw account assets on notice to GenTrust, subject to the usual and customary securities settlement procedures. However, GenTrust designs its portfolios for long-term investment, and withdrawing assets may impair the achievement of a client’s investment objectives. GenTrust may consult with its clients about the options and ramifications of transferring securities. However, clients are advised that when transferred securities are liquidated, they are subject to transaction fees, fees assessed at the mutual fund level (i.e., contingent deferred sales charge), and/or tax ramifications. Commissions or Sales Charges for Recommendations of Securities One of GenTrust’s investment adviser representatives (“IAR”) is dually registered as a registered representative of Old City Securities, LLC (“OCS”), an unaffiliated SEC-registered broker-dealer and FINRA member. In his capacity as a registered representative of OCS, this individual may receive commissions for the sale of certain private placement securities. A conflict of interest exists to the extent that GenTrust recommends the purchase of private placement securities to GenTrust’s clients, and GenTrust IAR receives commissions or other additional compensation as a result of implementing GenTrust’s recommendations for OCS brokerage clients. GenTrust’s policies and procedures always require that any recommendations made by this dually registered IAR are in the client’s best interest. Compensation for the Sale of Other Investment Products A GenTrust Supervised Person, licensed as an insurance broker, will earn commissions for selling insurance products, including those sold to GenTrust clients. A portion of the commissions earned by this insurance broker will be paid to GenTrust. In addition, insurance commissions earned are separate and in addition to our advisory fees. This practice presents a conflict of interest because, as a Supervised Person and insurance broker who provides investment advice on behalf of our firm, this individual has an incentive to recommend insurance products to clients for the purpose of generating commissions; however, we always endeavor to place our clients’ interests first when making recommendations regarding insurance and investments. We mitigate this conflict through disclosure and require that each client who desires to purchase a commission-generating insurance product receive an insurance disclosure statement and acknowledges such receipt. Insurance products may be available at lower or higher costs from other providers, and clients are under no contractual or other obligation to purchase insurance products through any person affiliated with our firm. Material conflicts of interest between GenTrust and our employees and our clients are generally disclosed in this Disclosure Brochure Document. If at any time, additional material conflicts of interest develop, as deemed appropriate, we will provide clients with written notification of the material conflicts of interest or an updated Disclosure Brochure Document. 13  Item 6 Performance-Based Fees and Side-by-Side Management As discussed in response to Item 5 above, GenTrust may render investment management services to qualified clients for a performance-based fee. Such fees may create an incentive for GenTrust to make riskier or more speculative investments than would be the case, absent a performance fee. In addition, when GenTrust charges performance-based fees while providing similar services to accounts that do not pay performance-based fees, there is an incentive to favor accounts that pay performance-based fees. As described in Item 5, one of the Firm’s principals receives incentive-based compensation tied, in part, to the performance of fixed income investments within client portfolios and, in some cases, to performance-based fees earned by the Firm. These arrangements may create incentives to favor certain allocations or performance-fee accounts. The Firm has adopted policies and procedures designed to ensure fair treatment of all clients and that investment decisions are made in clients’ best interests. GenTrust has procedures in place to ensure that all clients are treated fairly and that any recommendations are in clients' best interests, regardless of the client’s fee structure. Item 7 Types of Clients GenTrust provides its services to individuals, banks or thrift institutions, trusts, estates, charitable organizations, corporations, pooled investment vehicles, and other business entities, including other registered investment advisers. GenTrust generally requires clients to have a minimum account size of $10 million. However, GenTrust may waive this requirement at its discretion. Family members' accounts may be aggregated to meet the minimum portfolio size. In addition, the minimum requirement will be waived for employees or employee-related accounts. Certain Independent Managers may impose more restrictive account requirements than GenTrust. In such instances, GenTrust may adjust its account requirements to align with those of the Independent Managers. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis GenTrust relies upon a proprietary combination of fundamental, technical, and macroeconomic methods of analysis. Fundamental analysis involves assessing the financial value of an asset. GenTrust generally 14  analyzes the financial condition, expected cash flows, uncertainty, and risks to those cash flows and cash flows of other investment alternatives to determine the recommendations made to clients. The primary risk in using fundamental analysis is in assessing the uncertainty of the financial conditions and cash flows of various assets. Technical analysis involves examining past market data rather than valuation metrics when determining recommendations for clients. Technical analysis generally involves the use of charts and/or mathematical metrics to identify market patterns and trends that may be driven by investor sentiment rather than the fundamentals of an asset. GenTrust uses a proprietary technology platform that seeks to streamline and digitize investment analysis processes and incorporates client management and reporting functions. The primary risk in using technical analysis is that spotting historical trends may not help predict future ones. Even if the trend will eventually recur, there is no guarantee that GenTrust will be able to accurately predict such a recurrence. Macroeconomic analysis involves assessing market conditions at a macroeconomic level (the entire market/economy, sectors, and asset classes), rather than the overall fundamental analysis of the health of a particular asset that GenTrust is recommending. The risks with macroeconomic analysis are similar to those of both fundamental and technical analysis. In addition to its proprietary investment analysis, GenTrust may consider model portfolios or investment frameworks provided by unaffiliated third parties as one of several research inputs. GenTrust is not required to follow any such model portfolios and retains full discretionary authority to determine whether, how, and to what extent any third‑party models are used in client portfolios. Investment decisions are made in accordance with each client’s investment objectives, restrictions, and risk tolerance. Investment Strategies GenTrust’s investment approach seeks to make institutional-quality investment design and risk management accessible to high-net-worth individuals and families. In developing client portfolios, GenTrust seeks to incorporate the latest academic research, complemented with extensive primary research, to design its approach. GenTrust’s investment approach is based on the following guidelines, which guide the firm’s investment decisions:  Focus on Asset Allocation –Our approach focuses on designing the optimal asset allocation for each client.  Diversification – Diversification creates portfolios with attractive reward/risk characteristics.  Macro Risk Factor Driven Allocations – Core asset allocation is based on the expected performance of each asset class during various macroeconomic scenarios positioning the portfolio to be more stable across market environments. 15   Scenario-Based Risk Management – Backward-looking risk measures rely on history repeating itself; GenTrust utilizes forward-looking scenario analysis to evaluate the risk in portfolios and optimize allocations.  Valuation – GenTrust examines the fundamental links between asset classes to determine their relative value and adjust allocations over time. GenTrust does not employ frequent trading as a primary investment strategy; the firm's long-term, asset-allocation driven approach is designed with the goal of minimizing unnecessary transaction costs and tax consequences for clients. Risks of Loss Equities An investment in equity securities involves risk, including the possible loss of principal. Equity securities represent ownership interests in issuers and are subject to market risk, issue-specific risk, and economic and financial conditions that may cause their market value to fluctuate, sometimes significantly and unpredictably. The value of equity securities may be affected by factors including, but not limited to, the issuer’s financial condition, management performance, competitive position, earnings prospects, interest rates, investor sentiment, and general market and economic conditions. Equity markets may experience periods of increased volatility or decline, which may adversely affect the value of equity holdings regardless of the underlying financial performance of individual issuers. Common stock generally entitles holders to voting rights and, if declared, dividends; however, dividends are not guaranteed and may be reduced or eliminated at any time. In the event of an issuer’s liquidation, common stockholders are subordinate to creditors and preferred stockholders. Preferred stock may pay fixed or variable dividends but may be subject to interest rate risk and may have limited participation in an issuer’s growth. There can be no assurance that an active or liquid market for any equity security will exist at all times. Under certain market conditions, it may be difficult to sell an equity position at a favorable price or within a desired time frame. Clients should be prepared to bear the risks associated with equity investing, including potentially substantial fluctuations in portfolio value. Mutual Funds and ETFs An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual funds and ETF shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s underlying portfolio securities. Such shareholders are also liable for taxes on any fund- level capital gains, as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for a profit that cannot be offset by a corresponding loss. 16  Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholders’ fees (e.g., sales loads, purchase fees, redemption fees). The per-share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for index-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares in creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market for shares of a particular ETF ceases to exist, a shareholder may have no way to dispose of those shares. Fixed Income Securities Investments in fixed income securities involve risk, including the possible loss of principal. Fixed income securities are subject to interest rate risk, credit risk, liquidity risk, and market risk, among other factors. Changes in interest rates generally have an inverse relationship with the value of fixed-income securities; as interest rates rise, the market value of fixed-income securities typically declines, and vice versa. Credit risk is the risk that an issuer may be unable or unwilling to meet its interest or principal payment obligations when due. Securities with lower credit ratings generally offer higher yields to compensate for increased credit risk but may be more volatile and subject to greater risk of loss. Changes in an issuer’s credit rating or financial condition may adversely affect the value of fixed income security. Fixed income securities may also be subject to liquidity risk, particularly during periods of market stress, when it may be difficult to sell a security at a favorable price or within a reasonable time frame. Certain fixed-income securities may be callable, meaning the issuer may redeem the security prior to maturity, which could limit potential returns or require reinvestment at less favorable interest rates. Inflation risk may reduce the real value of fixed-income investments by eroding purchasing power over time. Clients should be prepared to bear the risks associated with fixed income investing, including fluctuations in market value and the potential loss of principal. Options 17  Options allow investors to buy or sell a security at a specified “strike” price (not necessarily the current market price) within a specific period of time. Clients may pay or collect a premium for buying or selling an option. Investors transact in options to either hedge (limit) losses to reduce risk or speculate on the performance of the underlying securities. Option transactions carry several inherent risks, including the partial or total loss of principal if the value of the underlying security or index does not reach or exceed the strike price. Holders of options contracts are also subject to default by the option writer, which may be unwilling or unable to fulfil their contractual obligations. Market Risks The profitability of a significant portion of GenTrust’s recommendations may depend to a great extent upon correctly assessing the future course of price movements of stocks and bonds. There can be no assurance that GenTrust will be able to predict those price movements accurately. Use of Independent Managers GenTrust may recommend Independent Managers for certain clients. GenTrust will continue to conduct ongoing due diligence on such managers, but such recommendations rely to a great extent on the Independent Managers’ ability to successfully implement their investment strategy. In addition, GenTrust cannot supervise the Independent Managers on a day-to-day basis other than as previously described in Item 4, above. Additionally, in managing certain accounts, GenTrust may consider investment recommendations/signals from one or more investment managers. Use of Private Collective Investment Vehicles GenTrust may recommend that certain clients invest in privately placed collective investment vehicles (typically referred to as hedge funds, private placements, and private equity investments). The managers of these vehicles will have broad discretion in selecting the investments. There are a few limitations on the types of securities or other financial instruments that may be traded, and no requirement to diversify. These investment vehicles may trade on margin, leverage positions, use derivatives, and engage in short-selling strategies, thereby potentially increasing risk to investors. In addition, because the vehicles are not registered as investment companies, they are not subject to the regulatory protections in the Investment Company Act. There are numerous other risks in investing in these securities. The client will receive a private placement memorandum and/or other documents explaining such risks. Real Estate Investment Trusts (REITs) GenTrust may recommend an investment in, or allocate assets among, various REITs, the shares of which exist in the form of either publicly traded or privately placed securities. REITs are collective investment vehicles with portfolios comprised primarily of real estate and mortgage- related holdings. Many REITs hold heavy concentrations of investments in commercial and/or residential developments, which inherently subject REIT investors to the risks associated with a real estate market downturn. Investments linked to certain regions that experience greater 18  volatility in the local real estate market may give rise to large fluctuations in the value of REIT’s shares. Mortgage-related holdings may raise additional concerns about interest rates, inflation, liquidity, and counterparty risk. Use of Margin To the extent that a client authorizes the use of margin, and margin is thereafter employed by GenTrust in the management of the client’s investment portfolio, the market value of the client’s account and corresponding fee payable by the client to GenTrust will be increased. As a result, in addition to understanding and assuming the additional principal risks associated with the use of margin, clients authorizing margin are advised of the potential conflict of interest whereby the client’s decision to employ margin shall correspondingly increase the management fee payable to GenTrust. Accordingly, the decision on whether to use margin is left entirely to the client's discretion. While the use of margin borrowing can substantially improve returns, such use also increases the adverse impact on a client’s portfolio. Borrowings will usually be from brokers-dealers, banks, or similar financial institutions and will typically be secured by the client’s securities and/or other assets. Under certain circumstances, the lending broker-dealer, bank, or financial institution may demand an increase in the collateral that secures the client’s obligations, and if the client is unable to provide additional collateral, the lending financial institution will typically liquidate assets held in the account to satisfy the client’s obligations. Liquidation in that manner could have extremely adverse consequences. In addition, the amount of the client’s borrowings and the interest rates on those borrowings, which will fluctuate, will have a significant effect on the client’s profitability. Proprietary Investment Process, Systematic Errors, and Trading Methods Risk GenTrust’s investment strategies rely on proprietary models. The models utilize various assumptions, based on the historical correlation and volatility structure of the market, to predict the effects of market movements on a portfolio. There is no assurance that the results will be as the model forecasts, particularly during significant market events. Due to the proprietary nature of GenTrust’s methodologies, investors will not be able to fully evaluate all details of GenTrust’s processes. The models may have hidden biases, flaws, or errors, and investors should be aware that this is an inherent risk in GenTrust’s models. GenTrust has no control over systematic errors in third-party software or systems, and there is no assurance that, once an error is discovered, it will be resolved promptly or favorably. Systematic errors may increase trading risks and expose investors to significant losses. Software Technology and System Failure Risks GenTrust relies on software or technology licenses and service agreements with third parties. GenTrust’s ability to trade, manage, or monitor accounts may be substantially impaired if any of the systems, analytical tools, data, or software becomes unavailable or fails to operate properly. While GenTrust seeks to ensure, whenever possible, that it has adequate backups in place, there is no guarantee that its efforts will be successful. Backup systems may fail to operate properly, 19  particularly when used for extended periods. These failures would impair GenTrust’s ability to trade for or monitor client accounts and would likely cause investors to incur significant losses. Cyber Risk Investment advisers, including GenTrust, must rely in part on digital and network technologies (“cyber networks”) to maintain substantial computerized data about activities for client accounts and otherwise conduct their businesses. Such cyber networks might in some circumstances be subject to a variety of possible cybersecurity incidents or similar events that could potentially result in the inadvertent disclosure of confidential computerized data or client data to unintended parties, or the intentional misappropriation or destruction of data by malicious hackers seeking to compromise sensitive information, corrupt data, or cause operational disruption. Cyber-attacks might be carried out by persons using techniques ranging from efforts to electronically circumvent network security or overwhelm websites to intelligence-gathering and social-engineering functions aimed at obtaining information necessary to gain access. GenTrust maintains policies and procedures on information technology security. It has certain technical and physical safeguards intended to protect the confidentiality of its internal data and takes other reasonable precautions to limit the potential for cybersecurity incidents and to protect data from inadvertent disclosure or wrongful misappropriation or destruction. Nevertheless, despite reasonable precautions, the risk remains that cybersecurity incidents could potentially occur, and such incidents, in some circumstances, might result in unauthorized access to sensitive information about GenTrust or its clients or their investors and/or cause damage to client accounts or GenTrust’s activities for clients or their investors. GenTrust will seek to promptly notify affected clients and investors of any known cybersecurity incident that may pose a substantial risk of exposing confidential personal data about such clients or investors to unintended parties. Effects of Health Crises and Other Catastrophic Events Health crises, such as pandemic and epidemic diseases, as well as other catastrophes that interrupt the expected course of events, such as natural disasters, war, or civil disturbance, acts of terrorism, power outages and other unforeseeable and external events, and the public response to or fear of such diseases or events, have and may in the future have an adverse effect on clients' investments and GenTrust's operations. For example, any preventative or protective actions that governments may take in respect of such diseases or events may result in periods of disruption, inability to obtain raw materials, supplies, and parts, and reduced or disrupted operations for client portfolio companies. In addition, under such circumstances, the operations, including certain functions of GenTrust and other service providers, could be reduced, delayed, suspended, or otherwise disrupted. Further, the occurrence and pendency of such diseases or events could adversely affect the economies and financial markets either in specific countries or worldwide. General Risk of Loss Investing in securities involves the risk of loss. Clients should be prepared to bear such loss. 20  Item 9 Disciplinary Information GenTrust is required to disclose the facts of any legal or disciplinary events that are material to a client’s evaluation of its advisory business or the integrity of management. GenTrust does not have any required disclosures to this Item. Item 10 Other Financial Industry Activities and Affiliations GenTrust is required to disclose any relationship or arrangement that is material to its advisory business or its clients. Catenary Alternative Asset Management, LLC CAAM is affiliated, as a result of common ownership, with GenTrust. CAAM’s relationship with GenTrust is immaterial to its business. As noted previously, CAAM and GenTrust share office space. GenTrust has in the past and may in the future recommend that its advisory clients invest in CAAM funds. GenTrust clients may pay a management fee to CAAM funds. CAAM and GenTrust manage this conflict through disclosure and thorough policies and procedures that require it to make recommendations that are in the client’s best interests. Kudu Investment US, LLC Kudu Investment US, LLC, is a Delaware limited liability company that owns a passive, non- controlling minority stake in GenTrust. Kudu has no influence or control on the day-to-day management of GenTrust. Registered Representative of a Broker-Dealer A GenTrust IAR is dually registered as a registered representative of OCS, an unaffiliated FINRA registered broker-dealer. In his capacity as a registered representative, he is entitled to receive transaction-based compensation for the sale of certain private placements of securities. This relationship and the related conflicts are described in Item 5 (above) and the IAR’s Form ADV Part 2B Brochure Supplement. Independent Insurance Agent A GenTrust IAR is licensed to sell insurance products. In this role, the IAR acts as an independent insurance agent and receives commission-based compensation for the sale of these products. GenTrust receives a portion of the commissions. This arrangement and the related conflicts are described in Item 5 (above) and the IAR’s Form ADV Part 2B Brochure Supplement. 21  Item 11 Code of Ethics GenTrust, its employees, and persons associated with GenTrust (“Supervised Persons”) are permitted to buy or sell securities that are also recommended to clients consistent with GenTrust’s policies and procedures and Code of Ethics. GenTrust has adopted a Code of Ethics that sets forth the standards of conduct expected of its associated persons and requires compliance with applicable securities laws. In accordance with Section 204A of the Advisers Act, the Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material, non-public information by GenTrust or any of its Supervised Persons. The Code of Ethics also includes provisions relating to reporting of certain gifts, business entertainment items and political contributions; restrictions on the acceptance of significant gifts. The Code of Ethics requires that Supervised Persons report their personal securities holdings and transactions, and obtain pre-approval for certain investments, including private investments, private placements, and limited offerings. The Code of Ethics does not prohibit Supervised Persons from trading and investing in securities that GenTrust recommends to its clients. At times, the sale or purchase of a security for a Supervised Person may precede or occur simultaneously with a client trade. Supervised Person’s trades may also be combined with client trades as part of an aggregated or block transaction, where all accounts receive the same price. Although the policy to allow employees to trade in the same securities as clients poses a potential conflict and the possibility for abuse in that, for example, the Supervised Person may seek to benefit by trading in advance of client activity, the Code of Ethics provides that Supervised Persons must always act in the client’s best interest and avoid actual or the appearance of conflict of interest or impropriety. Failure to abide by the Code of Ethics may subject the Supervised Person to sanctions, including termination of employment. Clients and prospective clients may contact GenTrust at the telephone number on the front of this Brochure Document to request a copy of its Code of Ethics. GenTrust, its employees, and persons associated with GenTrust (“Supervised Persons”) are permitted to buy or sell securities that are also recommended to clients consistent with GenTrust’s policies and procedures and Code of Ethics. GenTrust has adopted a Code of Ethics that sets forth the standards of conduct expected of its associated persons and requires compliance with applicable securities laws. In accordance with Section 204A of the Advisers Act, the Code of Ethics contains written policies reasonably designed to prevent the unlawful use of material, non-public information by GenTrust or any of its Supervised Persons. The Code of Ethics also includes provisions relating to reporting of certain gifts, business entertainment items and political contributions; restrictions on the 22  acceptance of significant gifts. The Code of Ethics requires that Supervised Persons report their personal securities holdings and transactions, and obtain pre-approval for certain investments, including private investments, private placements, and limited offerings. The Code of Ethics does not prohibit Supervised Persons from trading and investing in securities that GenTrust recommends to its clients. At times, the sale or purchase of a security for a Supervised Person may precede or occur simultaneously with a client trade. Supervised Person’s trades may also be combined with client trades as part of an aggregated or block transaction, where all accounts receive the same price. Although the policy to allow employees to trade in the same securities as clients poses a potential conflict and the possibility for abuse in that, for example, the Supervised Person may seek to benefit by trading in advance of client activity, the Code of Ethics provides that Supervised Persons must always act in the client’s best interest and avoid actual or the appearance of conflict of interest or impropriety. Failure to abide by the Code of Ethics may subject the Supervised Person to sanctions, including termination of employment. Clients and prospective clients may contact GenTrust at the telephone number on the front of this Brochure Document to request a copy of its Code of Ethics. Item 12 Brokerage Practices As discussed above in Item 5, GenTrust recommends that clients use the brokerage and clearing services of various Financial Institutions with which GenTrust has custody and clearing arrangements. GenTrust will typically use the custodian’s brokers to execute securities transactions. GenTrust believes that using its custodian broker relationships is in the best interest of its clients. The executing brokers may act on an agency or riskless principal basis for a variety of securities and other investments. In selecting third-party execution brokers, GenTrust may consider research among many other factors. In such cases, Clients may pay higher commissions or markups/markdowns than if GenTrust selected a broker that does not provide research. This poses a conflict, as GenTrust has an incentive to select the broker that provides research rather than obtain the most favorable price or the lowest commission for Clients. GenTrust’s policy is to act in the client’s best interest. To the extent GenTrust receives research, GenTrust will use it to benefit all clients. Although GenTrust will seek to obtain competitive rates for the benefit of all clients, it may not necessarily obtain the lowest possible commission rates for specific client account transactions. Factors that GenTrust considers when recommending a Financial Institution to clients include its financial strength, reputation, execution, pricing, research, and service. Some of these Financial Institutions provide GenTrust with access to mutual funds and a wide range of securities, with no transaction charges or nominal or reduced transaction charges. The commissions and/or transaction fees charged by the Financial Institutions we recommend may be higher or lower than 23  those charged by other Financial Institutions. GenTrust seeks to obtain the best price and execution for all trades and to exercise diligence and care throughout the trading process. Clients may pay commissions that are higher than other financial institutions might charge to effect the same transaction. GenTrust may select an executing broker that imposes higher commission charges if GenTrust determines that the overall commissions are 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 Financial Institution’s services, including, among others, the value of research provided, execution capability, commission rates, and responsiveness. GenTrust seeks competitive rates but may not necessarily obtain the lowest possible commission rates for client transactions. GenTrust periodically reviews its policies and procedures regarding its recommendations of Financial Institutions, in light of its duty to seek best execution. When placing trades for all clients on an ongoing basis, GenTrust will determine whether to reinvest dividends for each investment unless the client specifies otherwise. Any trade errors will be rectified to make the client whole as if the error did not occur. GenTrust will not seek to offset the cost of trade errors with soft dollars. It is GenTrust’s policy not to engage in principal transactions. However, GenTrust may use an unaffiliated broker-dealer to cross securities and/or cash between client accounts when such a transaction is advantageous for each participant. A “cross trade” generally refers to a transaction in which an advisor crosses the purchase and sale of a particular security between two or more advisory client accounts without charging a fee for effecting the transaction. Employee accounts managed by GenTrust and client accounts subject to ERISA do not participate in cross trades. GenTrust has policies and procedures to ensure that cross trades are conducted at market prices and that appropriate documentation is maintained. Directed Brokerage A client may direct GenTrust in writing to use a particular Financial Institution to execute some or all of the client's transactions. In that case, the client will negotiate terms and arrangements for the account with that Financial Institution, and GenTrust will not seek better execution services or prices from other Financial Institutions or be able to “aggregate” client transactions for execution through other Financial Institutions with orders for other accounts managed by GenTrust (as described below). As a result, the client may pay higher commissions or other transaction costs, or greater spreads, or receive less favorable net prices on transactions for the account than would otherwise be the case. Subject to its duty of best execution, GenTrust may decline a client’s request to direct brokerage if, in GenTrust’s sole discretion, such directed brokerage arrangements would result in additional operational difficulties or violate restrictions imposed by other broker-dealers (as further discussed below). Trade Aggregation and Allocation 24  Transactions for each client generally will be executed independently unless GenTrust decides to purchase or sell the same securities for several clients at approximately the same time. GenTrust may (but is not obligated to) combine or “batch” such orders to seek to obtain best execution, to negotiate more favorable commission rates, or to allocate equitably among GenTrust’s clients differences in prices and commissions or other transaction costs that might have been obtained had such orders been placed independently. Under this procedure, transactions will generally be averaged as to price and allocated among GenTrust’s clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that GenTrust determines to aggregate client orders for the purchase or sale of securities, including securities in which GenTrust’s Supervised Persons may invest, GenTrust generally does so in accordance with applicable regulatory rules and guidance. GenTrust does not receive any additional compensation or remuneration as a result of trade aggregation. In the event that GenTrust determines that a prorated allocation is not appropriate under the particular circumstances, the allocation will be made based upon other relevant factors, which may include: (i) when only a small percentage of the order is executed, shares may be allocated to the account with the smallest order or the smallest position or to an account that is out of line with respect to security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given to one account when one account has limitations in its investment guidelines that prohibit it from purchasing other securities that are expected to produce similar investment results and can be purchased by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de minimis allocation in one or more accounts, GenTrust may exclude the account(s) from the allocation; the transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts on a random basis. Commissions or Sales Charges for Recommendations of Securities As discussed above, a GenTrust IAR who is dually registered as a registered representative of OCS, will earn commissions for the sales of private placements offered through OCS. Neither GenTrust nor the IAR will earn advisory fees on any brokerage accounts or private placement transactions in which the IAR earns a commission. Investors in private placement offerings receive an Offering Memorandum that describes fees and expenses. Soft Dollars Consistent with its obligation to seek best execution, GenTrust may direct brokerage transactions to broker-dealers in exchange for investment research products and/or services that assist GenTrust in its investment decision-making process. Such research will generally be used to serve all GenTrust’s clients, but brokerage commissions paid by one client may be used to pay for research 25  that is not used to manage that client’s portfolio. The receipt of investment research and other benefits, as well as the allocation of the benefits of such products and services, poses a conflict of interest because GenTrust does not have to produce or pay for them. Thus, GenTrust may have an incentive to select or recommend broker-dealers based on GenTrust’s interest in receiving research or other services and benefits rather than clients’ interest in receiving the most favorable execution. To address this conflict, GenTrust conducts periodic best execution reviews to ensure that broker- dealer selection is based primarily on execution quality, operational capabilities, and cost- effectiveness, with soft dollar benefits being an incidental consideration. GenTrust has an arrangement with Fidelity Brokerage Services LLC (“Fidelity”), whereby Fidelity allocates a portion of commissions generated by client trades to a pool of soft dollar credits maintained by Fidelity. Fidelity pays independent research providers for research products and services using this pool of soft-dollar credits. This type of arrangement is called a commission- sharing arrangement because Fidelity shares its commissions with independent research providers to pay for research products and services. Currently, GenTrust uses the soft dollars credits generated at Fidelity to help offset the current costs of some research and research services. Regarding soft dollar arrangements, GenTrust will rely on the “safe harbor” guidance provided by Section 28(e) of the Securities Exchange Act of 1934, as amended, which permits the use of soft dollars to obtain brokerage and research services that provide lawful and appropriate assistance to the investment adviser in the performance of its investment decision-making responsibilities. Benefits and Support Provided by Financial Institutions GenTrust renders investment management services to clients that maintain assets custodied at various Financial Institutions. Specifically, these Financial Institutions include Fidelity, JP Morgan, Pershing Advisor Solutions (“Pershing”), Northern Trust, (“Northern Trust”), Interactive Brokers (“IB”), and Charles Schwab & Co., Inc (“Schwab”), Citibank N.A. (“Citi”). GenTrust receives certain benefits from some of these Financial Institutions, including, but not limited to, computer software, research tools and platforms, and related systems support, at no cost or at a reduced cost to GenTrust. These services enable GenTrust to more effectively monitor client accounts held at the respective Financial Institutions. The software and related systems support generally benefits GenTrust but not its clients directly. Additionally, GenTrust typically receives the following benefits from these Financial Institutions: access to its institutional trading desk that exclusively services; access to block trading, which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; and access to an electronic communication network for client order entry and account information. The Financial Institutions also offer other services intended to help GenTrust manage and further develop its advisory practice. Such services may be offered at no cost, or at a reduced cost, and may include, but are not limited to, third party research, publications, access to educational conferences, roundtables, and webinars, practice management resources, and other third-party service providers who provide a wide array of business-related services and technology with whom 26  GenTrust may contract directly. GenTrust receives an economic benefit from Schwab in the form of the support products and services it makes available to other independent investment advisors whose clients maintain their accounts at Schwab and us. In addition, Schwab has agreed to pay for certain products and services that GenTrust would otherwise have to pay for once the value of our clients’ assets in accounts at Schwab reaches a certain size. Clients do not pay more for assets maintained at Schwab as a result of these arrangements. However, GenTrust benefits from the arrangement because the cost of these services would otherwise be borne directly by us. In fulfilling its duties with its clients, GenTrust endeavors at all times to put their interests first. Clients should be aware, however, that GenTrust’s receipt of economic benefits from a Financial Institution creates a conflict of interest since these benefits may influence GenTrust’s choice of one Financial Institution over another that does not furnish similar software, systems support, or services. GenTrust manages this conflict through disclosure so that clients can make an informed decision and through policies and procedures that require it to act in the client’s best interests. Item 13 Review of Accounts For those clients to whom GenTrust provides investment management services, GenTrust monitors those portfolios as part of an ongoing process, while regular account reviews are generally conducted periodically. Accounts may be reviewed more frequently in response to events such as changes in market conditions, a client meeting, or a client life event. For those clients to whom GenTrust provides financial planning and/or consulting services, reviews are conducted on an “as needed” basis. Such reviews are conducted by one of GenTrust’s Supervised Persons. All investment advisory clients are encouraged to discuss their needs, goals, and objectives with GenTrust and to keep GenTrust informed of any changes thereto. GenTrust IARs contact their investment advisory clients at least annually to review services provided and investment strategies. They also discuss any changes in the client’s financial situation, investment objectives, or risk tolerance. The client’s custodians and executing brokers generally provide clients with transaction confirmation notices and periodic account statements. Those clients to whom GenTrust provides investment advisory services can also receive a consolidated report from GenTrust containing relevant account- and/or market-related information, such as details of account holdings and balances. Client reports may present account performance relative to specific indices or benchmarks. Any benchmarks shown are for informational purposes only and do not constitute a promise or guarantee that an account will meet or exceed them. GenTrust reports may differ from custodial account statements due to differences in accounting procedures, reporting dates, or valuation methodologies for certain securities. Clients should carefully review and compare the account statements received from the custodian to the reports received from GenTrust and promptly inform GenTrust of any discrepancies. 27  In some cases, clients may provide GenTrust with pricing for securities or assets that GenTrust has not independently verified. For example, investment in private placements of securities that do not trade in the secondary market and for which pricing is not available, or the value of the client’s real estate holdings or art collections. As an accommodation for the client, these assets will be shown separately in client reports and will not be used in calculating the client’s management fees for the quarter. From time to time, GenTrust may manage an account that includes managed and non-managed assets. Under such circumstances, GenTrust will have no authority or responsibility regarding non- managed assets, and the client shall be solely responsible for monitoring such assets and for any losses incurred in connection with the investment and disposition of such assets. Those clients to whom GenTrust provides financial planning and/or consulting services will receive reports from GenTrust summarizing its analysis and conclusions as requested by the client or otherwise agreed to in writing by GenTrust. Unless specifically agreed to in writing, GenTrust will not provide updates to the financial planning or consulting reports. Item 14 Client Referrals and Other Compensation As disclosed under Item 5, the Fees and Compensation section in this Brochure Document, one of GenTrust’s Supervised Persons provides investment advice on behalf of our firm and is also a licensed insurance broker. In his capacity as an insurance broker, he may sell insurance products, including, but not limited to, life, health, and long-term care products, and receive additional compensation in the form of commissions on the sale of such products to our firm's clients. For information on the conflicts of interest these presents and how we address these conflicts, please refer to the Fees and Compensation section in Item 5 above. GenTrust receives economic benefits from non-clients for providing advice or other advisory services to clients. This type of relationship poses a conflict of interest, and any such relationship is disclosed in response to Item 12 above. In addition, GenTrust will compensate third parties for client referrals. All referral fees are paid in accordance with the requirements of Rule 206(4)-1 of the Advisers Act and any corresponding state securities law requirements. Generally, the third-party referral agent (also known as solicitor, finder. or promoter) receives a portion of the management fees collected by GenTrust. Such fees are paid solely by GenTrust’s fees and do not result in any additional charges to clients. Item 15 Custody Client accounts are held in custody by unaffiliated broker/dealers or banks, which is typically selected by the client. GenTrust has an open architecture and manages accounts at financial institutions selected by the Client or Financial Intermediary, provided that the financial institution undergoes GenTrust’s due diligence. GenTrust does not hold client funds or securities; these assets are held at the client’s custodian. However, GenTrust is deemed to have custody of client assets under Rule 206(4)-2 of the Advisers Act (the "Custody Rule") due to the following factors: 28   GenTrust has the limited ability to instruct the client’s custodian to debit their investment advisory fees directly from the client’s account at the Qualified Custodian.  GenTrust’s clients have Standing Letters of Authorization (“SLOA”) arrangements under which the client authorizes recurring bill payments to third parties. GenTrust relies on the guidance in the SEC’s no-action letter to the Investment Advisers Association dated February 2017 regarding these types of arrangements.  GenTrust provides certain concierge services to clients as noted under Item 4. The accounts of clients that receive concierge services are also subject to an annual surprise asset audit by an independent accountant registered with the Public Company Accounting Oversight Board (PCAOB). Clients generally have online access to their accounts and should receive account statements at least quarterly from the broker-dealer, bank, or financial institution that holds and maintains client assets. GenTrust urges clients to carefully review the custodial account statements, which are the official account records, and compare them with the reports and other information prepared by GenTrust. Clients are requested to promptly notify GenTrust of any discrepancies or of not receiving quarterly account statements from their custodians. Item 16 Investment Discretion For discretionary accounts, the client Agreement provides us with limited authority to determine, without obtaining the client’s specific consent, the securities to be bought or sold, the amount of securities to be bought or sold, the selection of the Independent Manager(s) to be hired or fired, and the broker to execute transactions. Clients may limit our discretionary authority by imposing reasonable investment restrictions, limiting the types of securities that can be purchased for their accounts. We will exercise this discretionary authority in a manner consistent with each client’s stated investment objectives. For non-discretionary clients, GenTrust does not make investment decisions, including buying or selling securities, for the client without prior consultation with and the client's consent. In a non- discretionary arrangement, clients should understand that they may forego a particular transaction if GenTrust is unable to contact them to obtain their consent. Item 17 Voting Client Securities GenTrust votes client securities (proxies) or oversees proxy voting on behalf of its clients. Proxy votes must be cast in the best interests of clients, in accordance with guidelines outlined in GenTrust’s Proxy Voting Policies and Procedures, which may be updated periodically. Clients may request a copy of our Proxy Voting policies at any time. In situations where there is a conflict of interest in the voting of proxies due to business or personal 29  relationships that GenTrust maintains with persons having an interest in the outcome of certain votes, GenTrust will take appropriate steps to ensure that its proxy voting decisions are made in the best interest of its clients and are not the product of such conflict. GenTrust has engaged Broadridge Financial Solutions, Inc. (“Broadridge”), an independent third party, to administer electronic proxy voting on behalf of GenTrust’s clients. Using Broadridge's services provides GenTrust with proxy reports, ballot recommendations, and research tools. GenTrust maintains relevant records through Broadridge, including but not limited to, electronic ballots and reports. Clients will, upon request, receive a history of our proxy voting record. For those clients who do not retain GenTrust for proxy-voting authority, GenTrust has no responsibility to receive, vote, or otherwise advise on voting. Item 18 Financial Information GenTrust has never filed for bankruptcy and is not aware of any financial condition that is expected to affect its ability to manage client accounts. 30