GOALVEST ADVISORY LLC

GoalVest Advisory LLC Firm Brochure - Form ADV Part 2A sev This brochure provides information about the qualifications and business practices of GoalVest Advisory LLC. If you have any questions about the contents of this brochure, please contact us at (646) 941-8458 or by email at: asti@goalvestadvisory.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. Additional information about GoalVest Advisory LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. GoalVest Advisory LLC’s CRD number is: 285374. 4 World Trade Center, Suite 2908 New York, NY 10007 (646) 941-8458 sevasti@goalvestadvisory.com https://goalvestadvisory.com Registration does not imply a certain level of skill or training. Version Date: 09/22/2025 i  Item 2: Material Changes In addition to non-material changes intended to clarify disclosures in this brochure of GoalVest Advisory LLC (hereinafter “GVA”), this is an other than annual update to this brochure, including the following material changes to GVA’s policies, practices or conflicts of interests, since the last annual updating amendment on 03/28/2025: • GVA has clarified that fees are charged based on the market value of securities, cash and other property held in a separately managed account, and that accounts of family members may be included together for calculation of advisory fee breakpoints, at GVA’s sole discretion. (Item 5) investment • GVA has added a description of the circumstances under which certain members to act as registered team have been authorized of GVA’s representatives of a non-affiliated broker dealer, First Liberties Financial (CRD# 14432) to offer investments directly in private companies, and the resulting conflicts of interest that this activity presents, as well as the policy and procedures by which GVA seeks to mitigate these conflicts of interest. (Item 10) • GVA has added a description of its trade error resolution procedures, including certain special procedures that will be followed for advisory accounts held at Charles Schwab & Co. that include “netting” of gains and losses under certain circumstances. (Item 12) • GVA updated its description of its proxy voting policy to note that when Clients choose not to have GVA vote proxies, Clients may receive proxies directly from the issuer of the security, or the custodian. (Item 17) 2  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ................................................................................................................... 2 Item 3: Table of Contents ................................................................................................................... 3 Item 4: Advisory Business .................................................................................................................. 4 Item 5: Fees and Compensation ........................................................................................................ 7 Item 6: Performance-Based Fees and Side-By-Side Management ............................................... 9 Item 7: Types of Clients ...................................................................................................................... 10 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .......................................... 10 Item 9: Disciplinary Information ..................................................................................................... 17 Item 10: Other Financial Industry Activities and Affiliations ...................................................... 17 Item 11: Code of Ethics, Participation or Interest in Client Transactions, Personal Trading ... 19 Item 12: Brokerage Practices 23 Item 13: Review of Accounts ........................................................................................................... 23 Item 14: Client Referrals and Other Compensation .................................................................... 23 Item 15: Custody ................................................................................................................................ 25 Item 16: Investment Discretion......................................................................................................... 25 Item 17: Voting Client Securities (Proxy Voting) ........................................................................... 25 Item 18: Financial Information .......................................................................................................... 27 3  Item 4: Advisory Business A. Description of the Advisory Firm GoalVest Advisory LLC (hereinafter “GVA”) is a Limited Liability Company organized in the State of Delaware. GVA was formed in March 2016, and the principal owner is Sevasti Balafas. B. Types of Advisory Services Portfolio Management Services GVA offers ongoing portfolio management services primarily to high-net-worth individuals. GVA may also provide investment advisory services to partnerships, private investment vehicles, trusts, estates, charitable organizations, educational institutions retirement accounts, pension and profit-sharing plans, corporations and other types of business entities and other institutional Clients from time to time. Direct Separately Managed Account Advisory Clients For direct separately managed account advisory Clients, services are based on the individual goals, objectives, time horizon, and risk tolerance of each Client. GVA creates an Investment Policy Statement or similar documentation for each Client, which outlines the Client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each Client’s specific situation. Portfolio management services include, but are not limited to, the following: Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring. • • • GVA evaluates the current investments of each Client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, or other similar documentation, which is based on information provided by the Client and given to each Client. GVA will generally request discretionary authority from Clients in order to select securities and execute transactions without permission from the Client prior to each transaction. From time to time, GVA may act as a non-discretionary investment adviser to a Client. In the case of non-discretionary investment advisory accounts, Clients make the ultimate decisions regarding each sale or purchase of securities in such accounts. GVA’s obligations to monitor investments in non-discretionary advisory accounts will be set out in the investment advisory agreement. Client Subadviser Services 4  GVA may also act as a subadviser to advisers unaffiliated with GVA. These third-party advisers outsource portfolio management services to GVA and communicate the underlying Client’s investment policy or objectives to GVA, as communicated to the adviser by the underlying Client, and GVA will construct portfolios that are designed to meet those objectives in conjunction with the adviser. This relationship will be memorialized in each contract between GVA and the third-party advisor. References to “Clients” refers to both direct separately managed advisory clients and subadvised clients, unless the context otherwise provides. Private Funds GVA also sponsors and advises GoalVest Pre-IPO Growth Fund LP I, GoalVest Pre-IPO Growth Fund II, Dataminr SPV, a Series of GoalVest Master 2021, LLC and Klarna SPV, a Series of GoalVest Master 2021, LLC, each a private fund (the “Funds"). The Funds are offered to investors who meet minimum requirements, including that they are an “accredited investor” within the meaning of Regulation D promulgated under the Securities Act of 1933 (as amended), or a “qualified purchaser” as such term is defined under the Investment Company Act (as amended), and a “Qualified Client” within the meaning of the rules and regulations promulgated under the Investment Advisers Act (as amended). Fiduciary Duties GVA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of GVA’s economic, investment or other financial interests. To meet its fiduciary obligations, GVA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain Client portfolios, and accordingly, GVA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its Clients to avoid favoring one Client over another over time. It is GVA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings (“IPOs”) and other investment opportunities that might have a limited supply, among its Clients on a fair and equitable basis over time. Financial Planning Financial plans and financial planning may include but are not limited to an investment review, cash flow planning, tax considerations; retirement planning, college planning, life insurance planning, and debt/credit planning. 5  Services Limited to Specific Types of Investments GVA generally limits its investment advice to securities that are predominantly public, but also private, including equities, fixed income, exchange traded funds, mutual funds, real estate funds (including REITs), structured notes, and private investment vehicles. On the other hand, GVA may use other securities as well to help diversify a portfolio when applicable and suitable for the account, and in that way, the investment universe is not limited. The Funds that GVA currently sponsors and advises generally limit themselves to private equity securities or private equity funds. Funds with other investment strategies may be offered in the future. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions GVA will tailor a program for each individual Client. This will include an interview session to get to know the Client’s specific needs and requirements as well as a plan that will be executed by GVA on behalf of the Client. For subadvised advisory accounts, the program may be developed based on an investment profile or similar information provided by the Client’s adviser. GVA may use model allocations together with a specific set of recommendations for each Client based on their personal restrictions, needs, and targets. Clients may impose restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent GVA from properly servicing the Client account, or if the restrictions would require GVA to deviate from its standard suite of services, GVA reserves the right to end the relationship. 6  D. Wrap Fee Programs GVA does not sponsor or act as a portfolio manager for any wrap fee program in which Clients pay one stated fee that includes advisory services and transaction fees. E. Assets Under Management GVA had $ 628,348,337 in assets under management as of December 31, 2024. Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Annual Fees Total Assets Under Management $1,000,000 - $2,999,000 1.00% $3,000,000 - $5,000,000 0.90% $5,000,001 - $10,000,000 0.80% $10,000,001 - $20,000,000 0.70% $20,000,000 and above 0.60% The advisory fee is calculated using the value of the assets on the last business day of the prior quarter to calculate the fee for the quarter in advance. Our custodian feeds our portfolio management and reporting software (Black Diamond) and fees are calculated there based on quarterly market values of the securities, cash or other property held in the advisory account. There may be slight differences between custodian and reporting software based on accrued interest which is earned during the quarter. The final fee schedule is attached as an exhibit to the Investment Advisory Contract. Accounts of family members may be included together for calculation of advisory fee breakpoints, at GVA’s sole discretion. Clients may terminate the agreement without penalty for a full refund of GVA’s fees within five business days of signing the Investment Advisory Contract. Thereafter, Clients may terminate the Investment Advisory Contract generally with 1 days’ written notice. Fees are negotiable in some cases. Financial Planning Fees The fixed fee for creating Client financial plans is between $5,000 and $15,000, depending 7  on the complexity of a Client’s situation. Clients may terminate the agreement without penalty, for full refund of GVA’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, Clients may terminate the Financial Planning Agreement generally upon written notice. Subadviser Services Fees GVA also acts as a subadviser to unaffiliated third-party advisers and GVA would receive a share of the fees collected from the third-party adviser’s Client. The fees charged are negotiable and will not exceed any limit imposed by any regulatory agency. This relationship is memorialized in a contract between GVA and the third-party adviser. Private Fund Fees The Funds that GVA sponsors and advises each have offering documents that will detail the fees that an investor will pay to GVA, as well as other fund expenses, and the frequency with which these fees and expenses are charged, and how they are accounted for by the Funds and reported to investors. These fees differ from the fees that are typically charged to Client accounts, and an important difference is further described below in Item 6 of this brochure. When the Funds are offered to direct separately managed account advisory Clients of GVA, the Client will not pay account level management fees on the Fund assets reflected in their direct separately managed advisory account. Although the waiving of direct separately managed advisory account level fees is a substantial mitigant, fees for the Funds may be higher than the fees charged to separately managed accounts, and therefore GVA may have a conflict when offering or recommending the Funds to such direct separately managed advisory account Clients. Advisers for whom GVA serves as subadviser can and do often recommend investments in GVA’s Funds, and they may and do recommend them to the underlying Clients whose accounts the adviser has delegated investment authority to GVA. In these instances, GVA may earn both an account level fee for the subadvised advisory account on the value of the Fund interests, and fees disclosed in the governing documents of the Funds which are deducted from Fund assets. Underlying Clients acknowledge the fee structure of the Funds when making investments in the Funds. B. Payment of Fees Payment of Portfolio Management Fees Pursuant to the investment advisory agreement that direct advisory account Clients enter into with GVA, Clients grant permission for fees to be deducted directly from their investment advisory accounts. With this written authorization, asset-based portfolio management fees are withdrawn directly from the direct separately managed advisory Client’s accounts, quarterly, in advance. Fees for subadvised Client accounts may be 8  deducted and operate similarly to the direct advisory Client accounts, or alternatively, GVA may bill the Client’s primary adviser. Payment of Financial Planning Fees Financial planning fees are paid via check or electronic fund transfer through our payment processor. Financial Planning Fees are paid either with an upfront fee and ongoing monthly fee or quarterly in advance. C. Client Responsibility for Third Party Fees Client accounts are responsible for the payment of all third-party fees (i.e., custodian fees, commissions, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by GVA. Please see Item 12 of this brochure regarding broker/custodian. D. Prepayment of Fees GVA collects fees in advance. Refunds for fees paid in advance will be returned within fourteen days to the Client via check or return deposit back into the Client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. E. Outside Compensation for the Sale of Securities to Clients Neither GVA nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds or insurance products. GVA does not earn any other compensation besides portfolio management fees or financial planning fees. See Form ADV Part 2B for each relevant supervised person for a description of certain investment advisory fees that may be earned from approved outside activities of the respective person. Item 6: Performance-Based Fees and Side-By-Side Management For the Funds, fees include performance-based fees (carried interest) as well. Direct separately managed advisory accounts and subadvised advisory accounts, are generally NOT charged performance-based fees.i Managing both kinds of accounts at the same time presents a conflict of 9  interest because GVA or its supervised persons have an incentive to favor the Funds due to receipt of carried interest. GVA addresses the conflicts by only recommending private fund investments when appropriate and suitable, and disclosures regarding our conflict of interest are also made in the Form CRS, proposal, and investment management agreement. GVA seeks best execution and upholds its fiduciary duty for all Clients and Funds. Clients or Funds that are paying a performance-based fee (or carried interest) should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes. More information about potential conflicts can be found in Item 11 of this Brochure. Item 7: Types of Clients GVA generally provides advisory services to the following types of Clients: Individuals High-Net-Worth Individuals Charitable Organizations ❖ ❖ ❖ There is a $2,000,000 minimum for portfolio management services, which may be waived by GVA at its discretion. Exceptions are reviewed case by case. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis GVA’s methods of analysis primarily include fundamental research for stock selection and quantitative analysis and modern portfolio theory for portfolio construction. Technical analysis is also considered. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, the analysis of management and a company’s competitive advantages in order to determine a security’s intrinsic value and to make a decision on the undervaluation or over valuation of a stock. Modern portfolio theory is a theory of investment that attempts to maximize the expected portfolio return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with quantifying factors such as financial ratio calculations, market capitalization, growth or value metrics, etc. to make decisions on securities in the portfolio. 10  Technical analysis involves the analysis of past market data, primarily price and volume. Investment Strategies GVA uses long term trading in individual securities, primarily stocks and bonds, and may use options trading. Investing in securities involves a risk of loss that you, as a Client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk- expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies GVA’s use of options trading generally holds greater risk, and Clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its 11  nature, the long-term investment strategy can expose Clients to various types of risk that will typically surface at various intervals during the time the Client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investment Risks Associated with GVA’s investment strategies: General: Investing in securities involves a risk of loss that you, as a Client, should be prepared to bear. Risks Associated with Non-Diversification: GVA intends to hold diversified positions; however, unless otherwise provided in a Client contract or Fund governing document, it is not subject to any formal policies regarding diversification. GVA may sometimes concentrate holdings in industries, geographic regions, or companies which, in light of investment considerations, market risks and other factors, that it believes will provide the best opportunity for attractive risk-adjusted returns. The concentration of assets in a single or small number of issuers, in any one industry or a small number of industries, or in a single industry would subject Clients or Funds to a greater degree of risk with respect to the failure of one or a few investments or with respect to economic variations in relation to such industry or industries. Epidemic or Serious Public Health Event Risk: GVA’s business activities, as well as its operations and investments, could be materially adversely affected by outbreaks of disease, epidemics and public health issues in Asia, Europe, North America, the Middle East and/or globally, such as COVID-19 (and other novel coronaviruses), Ebola, H1N1 flu, H7N9 flu, H5N1 flu, Severe Acute Respiratory Syndrome, or SARS, or other epidemics, pandemics, outbreaks of disease or public health issues. An outbreak or recurrence of any kind of epidemic, communicable disease, virus, or major public health issue could cause a slowdown in the levels of economic activity generally (or push the world or local economies into recession), which would be reasonably likely to adversely affect the business, financial condition and operations of GVA. Should these or other major public health issues, including pandemics, arise, spread farther or worsen, GVA and the value of Client accounts could be adversely affected by more stringent travel restrictions (such as mandatory quarantines and social distancing), limitations on GVA’s operations and business activities and governmental actions limiting the movement of people and goods between regions and other activities or operations. failures, computer and telecommunication failures, Cyber Security Breaches and Identity: The information technology systems of GVA and its third-party service providers may be vulnerable to damage or interruption from computer viruses, network infiltration by unauthorized persons and security breaches, usage errors by its professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes, and earthquakes. Although GVA and its third-party service providers have implemented various measures to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time, or cease to function properly, GVA may have to make 12  a significant investment to fix or replace them. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in GVA’s operations and result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information relating to account holders, beneficial owners, or investors. Such a failure could harm GVA’s reputation, subject any such entity and its respective affiliates to legal claims and otherwise affect its business and financial performance. Risk of Default or Bankruptcy of Third Parties: Client accounts may engage in transactions in securities and other financial instruments and assets that involve counterparties. Under certain conditions, the Client could suffer losses if a counterparty to a transaction were to default or if the market for certain securities or other financial instruments or assets were to become illiquid. In addition, the Client could suffer losses if there were a default or bankruptcy by certain other third parties, including brokerage firms and banks with which the Client does business, or to which securities or other financial instruments or assets have been entrusted for custodial purposes. Market Disruption and Geopolitical Risk. Each Client account is subject to the risk that war, terrorism, country-specific sanctions, and related geopolitical events may lead to increased short-term market volatility and have adverse long-term effects on the U.S. and world economies and markets generally, as well as adverse effects on issuers of securities and the value of the Client’s investments. War, terrorism, related geopolitical events, and natural and other disasters have led, and in the future may lead, to increased short-term market volatility and may have adverse long-term effects on U.S. and non-U.S. economies and markets generally. Those events as well as other changes in U.S. and non-U.S. economic and political conditions also could adversely affect individual issuers or related groups of issuers, securities markets, futures markets, interest rates, credit ratings, inflation, investor sentiment and other factors affecting the value of a Client’s investments. At such times, a Client’s exposure to a number of other risks described elsewhere in this section can increase. It should also be noted that in February 2022, Russia launched a largescale invasion of Ukraine. The extent and duration of Russian military action in the Ukraine, resulting economic sanctions and resulting future market disruptions, including declines in stock markets in Russia and elsewhere, decline in the value of the ruble against the U.S. dollar, or the rise in the price of oil, are impossible to predict, but could be significant. Any disruptions caused by the invasion of Ukraine or other actions (including cyberattacks and espionage) or disruptions resulting from actual or threatened responses to the invasion of Ukraine or other actions could cause disruptions to companies and markets globally. Any such disruptions could have a material adverse effect on Client accounts. As of March 2025, there are ongoing military conflicts in the Middle East which, in a relatively short period of time, have caused and are likely to cause in the future disruption to the global financial system and trade and transport, among other things. In response to the conflicts, multiple countries have and may in the future put in place global sanctions and other severe restrictions or prohibitions on the activities of individuals and businesses related to the countries engaging in the conflicts. However, the ultimate impact of these conflicts and their effect on global economic and commercial activity and conditions, and on the operations, financial condition and performance of investment vehicles or any particular industry, business or investee country and the duration and severity of those effects, 13  is impossible to predict. Any conflict around the globe may have a significant adverse impact and result in significant losses to investments. This impact may include reductions in revenue and growth, unexpected operational losses and liabilities and reductions in the availability of capital. It may also limit the ability of GVA to source, diligence and execute new investments and to manage, finance and exit investments in the future. Developing and further governmental actions (military or otherwise) may cause additional disruption and constrain or alter existing financial, legal and regulatory frameworks and systems in ways that are adverse to GVA and/or Client accounts or which they intend to pursue, any or all of which could adversely affect GVA’s ability to fulfill its investment objectives. Additional Counterparty Risk: Some of the markets in which the securities or other investments trade may be “over-the-counter” or “interdealer” markets. The participants in such markets are typically not subject to credit evaluation and regulatory oversight as are members of “exchange based” markets. This exposes the Client to the risk that a counterparty will not settle a transaction in accordance with its terms and conditions because of a dispute over the terms of the relevant contract or because of a credit or liquidity problem, thus causing the Client to suffer a loss. Such risk may be accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where the Client has concentrated its transactions with a single or small group of counterparties. C. Risks of Specific Securities Utilized GVA’s use of options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, 14  similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real estate funds (including REITs) face several kinds of risks that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs which lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirements or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Private placements carry substantial risks. These investments are subject to less regulatory oversight than publicly offered securities and often lack transparency. They are typically illiquid, with limited or no secondary market, and may be subject to resale restrictions under applicable securities laws. As a result, liquidation may require a substantial discount to fair value—or may not be possible at all—potentially resulting in a total loss of the investment. Additional risks include limited financial disclosures, reliance on the management or issuer’s representations, and the potential for higher volatility due to concentrated or speculative strategies. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a 15  well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which help limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Structured notes are debt obligations that also contain an embedded derivative component that is linked to the performance of an underlying asset, group of assets, or index. Structured notes involve risks not associated with an investment in ordinary debt securities. Selected Risks Associated with any of these structures include: - No principal protection. Notes are not principal protected and investors can lose some or all their initial principal if the underlying asset falls below the Principal Barrier Level. - Contingent coupon payments. Investors may not receive periodic interest payments if the performance of the underlying assets falls below the Coupon Barrier Level. It is possible that investors will not receive any coupon payments over the life of the Note. - Potential for early redemption and reinvestment risk. Notes may be automatically called if the performance of the underlying asset is at or above the Initial Strike Price on the defined Observation Date. If called, investors may not be able to reinvest their proceeds in a product with a comparable coupon. - Returns are limited to the coupon payments, if any. Investors will not participate in any price appreciation of the underlying asset. Additionally, investors will not receive dividend payments generated by the underlying asset. - Potentially limited secondary market. While liquidity may be available when necessary, notes should be considered buy and hold investments. - Issuer credit risk. Notes are senior, unsecured debt obligations of the issuer and all payments of income and principal are therefore subject to the creditworthiness of the issuer. - Complex investments. Notes may have complex features and may not be suitable for all investors. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk 16  of loss that you, as a Client, should be prepared to bear. The foregoing list of risk factors does not purport to be a complete analysis or explanation of the risks associated with GVA’s investment strategies and with an investment in a Fund. Prospective investors in Funds should also read the governing documents for a more detailed explanation of the investment strategy and risk factors associated with investments in a Fund. Clients may consult with their own advisors before deciding whether to invest. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative GVA is not registered as, and GVA (or any affiliated entity) does not have pending applications to become, a broker/dealer . Under our current structure, several members of the GVA investment team have been approved by GVA to act as registered representatives of a broker dealer, First Liberties Financial (CRD# 14432), which is not affiliated with GVA. These individuals have become so registered in order to offer investors, some of whom may also be clients of GVA, the opportunity to make investments in private companies directly, rather than through a Fund offered by GVA. You should be aware that this dual-hatted role of GVA investment team members and transacting in securities purchases for clients through this non-affiliated broker-dealer, results in conflicts of interest because the GVA Team members can be compensated more or realize compensation more quickly when paid in the form of a brokerage commission (for example), than were the same investment offered through or as part of a Fund structure or portfolio. To the extent an investor in a brokerage transaction is also a client of GVA, the investment team member involved in the brokerage transaction may earn revenue from both the GVA investment advisory relationship and from the brokerage 17  transactions. Moreover, there will be a financial incentive to increase assets held in advisory accounts or determine to make investments through a Fund structure for the investment team when the investments may take a long time to materialize and therefore the fees earned over time may be more profitable. So, in particular cases, the commission on a particular brokerage transaction, and in other cases the fee structures applicable to a Fund, depending on the transaction, may be more profitable to GVA or the GVA investment team member. To manage this conflict, GVA investment team members have adopted a policy that they will only engage in offering investments in private companies via brokerage transactions with clients of GVA under circumstances where the investment being contemplated is not suitable to be offered via a Fund structure offered by GVA, or where the investment is only possible or available to be made as a direct investment by the investor into the company and not via an intermediary Fund offered by GVA. Circumstances where this policy applies include where the private companies do not wish to have intermediary entities like Funds offered by GVA as investors, and where investors desire to be direct investors in private companies. GVA requires all GVA investment team members who are also registered representatives of First Liberties Financial to uphold their fiduciary duties and to act in GVA’s Client’s best interest; and they are prohibited from considering their own compensation or compensation of GVA when making recommendations to clients. They are required to recommend accounts, products, investments, and services that are appropriate for clients of GVA based on investment objectives, goals, strategies, risk tolerance, financial situation, time horizon, and financial needs. GVA maintains policies, procedures, and a Code of Ethics and all employees receive annual training. Additionally, GVA and its investment team members perform advisory and/or brokerage services for various other clients. As a result of differences in client investment objectives, goals, strategies, risk tolerance, financial situations, time horizons, and financial needs, GVA and the investment team members may provide advice or recommendations and/or take actions for other clients that differ from the advice or recommendations given to you and/or actions taken in your account. The timing of any advice or recommendation provided or action taken for you and your account may also be different. To help manage any conflicts of interest that may arise, we have implemented certain controls including periodic reviews of accounts to identify performance outliers, periodic reviews of account-specific guidelines, and other policies and procedures that seek to manage and, if possible, minimize the effects of any conflicts. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither GVA nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests 18  None of GVA’s supervised persons are currently registered as a representative of a broker dealer. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections GVA does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics High ethical standards are essential for the success of GVA and to maintain the confidence of Clients. GVA’s long-term business interests are best served by adherence to the principle that the interests of Clients come first. To this end, and as required by Rule 204A- 1 under the Investment Advisers Act of 1940 (as amended), GVA has a adopted a written Code of Ethics and associated compliance procedures that cover the following areas: (a) fiduciary duties and ethical conduct of and by GVA and its supervised persons, (b) compliance with applicable law, (c) permitted and prohibited personal securities transactions and reporting of same by certain supervised persons, (d) certain conflicts of interest that must be avoided, (d) confidentiality, among other topics. Compliance with the Code of Ethics and associated compliance manual and procedures is required to be acknowledged by all supervised persons and GVA’s CCO and other supervisory staff maintain procedures to help assure that supervised persons adhere to the Code and associated policies and procedures. A copy of GVA’s Code of Ethics is available free upon to any Client or prospective Client by contacting Sevasti Bafalas request (sevasti@goalvestadvisory.com). B. Recommendations Involving Material Financial Interests GVA sponsors and advises GoalVest Pre-IPO Growth Fund LP I, GoalVest Pre-IPO Growth Fund II, Dataminr SPV, a Series of GoalVest Master 2021, LLC and Klarna SPV, a Series of GoalVest Master 2021, LLC each a private fund (the “Funds"). GVA will recommend investments in Funds to those Clients for which investment in the fund is suitable. This presents a conflict of interest in that GVA, or its related persons may receive more compensation from investment in the fund than from other investments. Nevertheless, GVA acts in the best interests of the Client consistent with its fiduciary duties and Clients are not required invest in the Funds if they do not wish to do so. GVA and/or individual portfolio managers of the Funds GVA receive carried interest from respective Funds, meaning they receive a share of profits upon the sale of a Fund’s asset. Carried interest in a Fund may create an incentive for the GVA and the Fund’s General Partner 19  to make more speculative investments for the Fund than it would otherwise make in the absence of such performance-based compensation. However, conflicts of interest associated with carried interest are mitigated by: (a) the requirement that invested capital and related expenses be returned to investors before the general partner of a Fund becomes entitled to receive any carried interest; (b) the requirement that the General Partner make a capital commitment to the Fund; and (c) a general partner clawback obligation under dissolution of the Fund. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of GVA may buy or sell securities for themselves that they also recommend to Clients. This may provide an opportunity for representatives of GVA to buy or sell the same securities before or after recommending the same securities to Clients resulting in representatives profiting off the recommendations they provide to Clients. Such transactions may create a conflict of interest. GVA maintains a Code of Ethics that prohibits its supervised persons from placing their own interests ahead of those of Clients and as a result GVA’s supervised persons will not engage in trading that operates to the Client’s disadvantage when similar securities are being bought or sold. GVA’s supervisory personnel maintain procedures to review and document transactions that could be construed as conflicts of interest. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of GVA may buy or sell securities for themselves at or around the same time as Clients. This may provide an opportunity for representatives of GVA to buy or sell securities before or after recommending securities to Clients resulting in representatives profiting off the recommendations they provide to Clients. Such transactions may create a conflict of interest; however, as noted above GVA’s Code of Ethics prohibits engaging in trading that operates to the Client’s disadvantage if representatives of GVA buy or sell securities at or around the same time as Clients, and GVA’s supervisory personnel maintain procedures to review and document transactions that could be construed as conflicts of interest. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers the market expertise and research access provided by including but not Custodians/broker-dealers will be recommended based on GVA’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a Client on the most favorable terms for the Client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and GVA may also consider the broker- limited to access to written research, oral dealer/custodian, communication with analysts, admittance to research conferences and other resources 20  provided by the brokers that may aid in GVA’s research efforts. GVA will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. GVA recommends Charles Schwab for its direct separately managed advisory Clients. GVA uses Carta Securities as custodian for Funds as well. 1. Research and Other Soft-Dollar Benefits GVA does not receive soft dollar benefits, in which it receives benefits from a broker- dealer tied to commissions generated for the broker-dealer in advisory accounts. 2. Brokerage for Client Referrals GVA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use GVA may permit Clients to direct it to execute transactions through a specified broker- dealer. If a Client directs brokerage, then the Client will be required to acknowledge in writing that the Client’s direction with respect to the use of brokers supersedes any authority granted to GVA to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; the Client may be unable to participate in block trades (unless GVA is able to engage in “step outs”); and trades for the Client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their Clients to direct brokerage. 4. Principal and Cross Transactions GVA does not typically effect transactions as principal (i.e., where GVA or any of its supervised persons, or affiliates, were to, for their own account, buy from or sell securities to or from a Client account). If GVA wishes to effect any transactions as principal, GVA will obtain Client consent before the completion of each such transaction. GVA may also engage in cross transactions for certain Clients whereby GVA is acting as an investment adviser for one or more advisory Clients and sells or buys securities from or to one or more advisory Clients, and where all such Clients provide a blanket consent in the investment advisory contract, or otherwise in writing, to GVA’s entering into cross transactions. When cross transactions are engaged in, a potentially conflicting division of loyalties and responsibilities may arise for GVA, and GVA maintains policies and procedures to help assure that GVA is acting in the best interests of each advisory Client whose account participates in the cross transaction. Clients may revoke their consent for GVA to engage in cross transactions upon written notice to GVA. GVA will effect cross-transactions only when we deem the practice to be advantageous for each participating account, and the 21  terms of any such transaction are fair and reasonable. GVA will ensure it, or the relevant custodian or broker provides confirmation of principal or cross-transactions in accordance with applicable law. Due to regulatory restrictions, GVA does not include any accounts governed by the Employee Retirement Income Security Act (”ERISA”), in any cross transactions. B. Aggregating (Block) Trading for Multiple Client Accounts If GVA buys or sells the same securities on behalf of more than one Client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple Clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, GVA would place an aggregate order with the broker on behalf of all such Clients that GVA intends to receive an allocation in order to ensure fairness for all Clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. GVA would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). If securities sought to be purchased are limited in quantity, GVA seeks to allocate securities that can be obtained in a fair and equitable manner. Depending on timing, GVA may, but generally do not, aggregate the purchase and sale of securities for non-discretionary investment advisory accounts with discretionary accounts and instead will execute trades for non-discretionary accounts as needed. As a result our Clients with non-discretionary investment advisory accounts may receive different pricing on transactions for the purchase or sale of the same securities as compared to Clients with discretionary accounts for which GVA applies the aggregation method to Client orders. C. Trade Errors From time to time, GVA makes errors that cause trades to be entered incorrectly for direct separately managed and sub-advised advisory accounts. In such infrequent instances, GoalVest first seeks to have the broker cancel the trade. Sometimes, this will not be possible. As a general matter, as set forth in GVA’s investment management contract for the overwhelming majority of directly managed Clients, GVA will be liable to direct advisory clients for any errors or mistakes in placing or executing securities transactions carried out as a result of the negligence of GVA. Other Client contracts may have different standards of care. In most instances, the cost of such errors will be borne by GVA and any incidental benefit will be enjoyed by the Client, subject to the below process that is followed by Charles Schwab & Co. Inc. (“Schwab”). The overwhelming majority of GVA’s client accounts are held by Charles Schwab & Co. If an investment gain results from correcting a trade error in a Schwab account, the gain will remain in Client accounts unless the same error involved other client account(s) that should have received the gain, it is not permissible for the client to retain the gain, or GVA confers with clients and Clients decide to forego the gain (e.g., due to tax reasons). If the gain does not remain in the Client’s account and Schwab is the custodian, Schwab will donate the 22  amount of any gain $100 and over to charity. If a loss occurs greater than $100, GVA will pay for the loss. Schwab will maintain the loss or gain (if such gain is not retained in the client’s account) if it is under $100 to minimize and offset its administrative time and expense. Generally, if related trade errors result in both gains and losses in your account, they may be netted, typically by Schwab, but GVA may determine to net them independently. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those All Client accounts for GVA’s advisory services provided on an ongoing basis are reviewed at least quarterly by Sevasti Balafas, CEO, with regard to Clients’ respective investment policies and risk tolerance levels. All accounts at GVA are assigned to this reviewer, and she is assisted in these endeavors by GVA’s investment staff. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Sevasti Balafas, CEO. Financial planning Clients are provided a one-time financial plan concerning their financial situation. Ms. Balafas is assisted in her financial planning by GVA’s financial planning staff. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts GVA can be said to monitor the issuers it invests in on a daily basis across its Client accounts. Reviews of accounts may be triggered by material market, economic or political events (and), or by changes in a Client’s financial situations (such as retirement, termination of employment, physical move, or inheritance) as communicated by Clients. Clients are requested to keep GVA informed of such changes as soon as practicable when they occur. C. Content and Frequency of Regular Reports Provided to Clients Each Client of GVA’s advisory services provided on an ongoing basis will receive a monthly report detailing the Client’s account, including assets held, asset value, and fees. This written report will come from the custodian. GVA will also provide at least quarterly a separate written statement to the Client. Clients are encouraged to compare the written statements provided by GVA with those provided by the custodian and bring any discrepancies to GVA’s attention. In the event of such discrepancy, the custodian provided statement shall govern. Each financial planning Client may receive the financial plan upon completion, upon request. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) 23  Charles Schwab & Co., Inc. Advisor Services provides our firm with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s Clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For our Client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. information technology, business succession, Charles Schwab & Co., Inc. Advisor Services also makes available to our firm other products and services that benefit our firm but may not benefit its Clients’ accounts. These benefits may include national, regional or specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of our firm by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist our firm in managing and administering Clients’ accounts. These include software and other technology (and related technological training) that provide access to Client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple Client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of our firm’s fees from its Clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and Client reporting. Many of these services generally may be used to service all or some substantial number of our firm’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to our firm other services intended to help our firm manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to our firm by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to our firm. Our firm is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. 24  B. Compensation to Non – Advisory Personnel for Client Referrals GVA does not compensate non-advisory personnel (solicitors/promoters) for Client referrals. Item 15: Custody As described in Item 14 above, GVA generally introduces direct separately managed account advisory Clients to Charles Schwab and Co., Inc. Advisor Services, which is a qualified custodian within the meaning of Rule 206(4)-2 under the Investment Advisers Act of 1940, as amended (the “Custody Rule”) to provide custodian services for such Clients. Subadvised advisory Clients may use other qualified custodians. When advisory fees are deducted directly from Client accounts at a Client's custodian, GVA will be deemed to have limited custody of Client's assets and must have written authorization from the Client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Clients will also receive statements from GVA and are urged to compare the account statements they received from their custodian with those they received from GVA. GVA may be deemed to have custody over the funds and securities invested in the Funds that GVA sponsors and advises. GVA is deemed to have custody of the assets of each Fund for which GVA, or an affiliate serves as general partner or managing member, and GVA must meet the applicable conditions of the Custody Rule as they apply to the Funds. Item 16: Investment Discretion GVA primarily provides discretionary investment advisory services to Clients. The advisory contract established with each Client sets forth the discretionary authority for trading. Where investment discretion has been granted, GVA generally manages the Client’s account and makes investment decisions without consultation with the Client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, GVA’s discretionary authority in making these determinations may be limited by conditions imposed by a Client (in investment guidelines or objectives, or Client instructions otherwise provided to GVA). From time to time, GVA may act as a non-discretionary investment adviser to a Client. In the case of non-discretionary investment advisory accounts, Clients make the ultimate decisions regarding each sale or purchase of securities in such accounts. GVA’s obligations to monitor investments in non-discretionary advisory accounts will be set out in the advisory contract. Item 17: Voting Client Securities (Proxy Voting) 25  Under the terms of GVA’s standard investment advisory contract, Clients will choose whether they would like to vote securities on their own behalf, or provide that GVA or, in the cased of Subadvised accounts, their primary adviser, will vote proxies. Clients typically choose to ask GVA to vote proxies, and GVA will typically accept voting authority for Client securities. When that is the case, Clients may receive proxies directly from the issuer of the security or the custodian but GVA will vote on their behalf. When Clients choose not to have GVA vote, Clients may receive proxies directly from the issuer of the security, or the custodian. GVA has adopted and implemented policies and procedures that are reasonably designed to ensure that when proxies are voted for Clients, they are voted in the best interests of investment advisory Clients, in accordance with GVA’s fiduciary obligations under applicable law. For advisory Clients where GVA has accepted proxy voting responsibility, GVA generally has the right to vote on all matters pertaining to the securities in a Client’s portfolio except as specifically provided otherwise. It is GVA’s policy to vote all proxies generally in line with management recommendations, as we generally believe that company management and boards are best positioned to make decisions that impact long-term shareholder value. Exceptions to this policy may be made in rare circumstances where; (a) a management proposal is clearly against shareholders' interests and is not a routine and non-controversial matter; or (b) GVA has discretion for more than 5% of outstanding shares and our vote could be consequential. GVA’s policies and procedures are designed to ensure that proxy voting decisions are made in the best interests of our Clients. In fulfilling our proxy voting responsibilities, we recognize the individually tailored account nature of our investment advisory business, the variety of securities held for Clients and the responsibility for investment decisions vested in GVA for each account under supervision. Although not typically required, accordingly, GVA may determine that the specific circumstances of such accounts require that their proxies be voted differently from the way proxies are voted with respect to other accounts under GVA’s supervision, or from GVA’s investment staff’s own accounts. GVA believes that generally there are no material conflicts between our Clients’ interests and our own insofar as proxy voting is concerned. In the event a material conflict arises, the GVA will determine how to provide disclosure of such conflict and, if appropriate, how to obtain Client consent to the proxy vote. It is our policy to resolve all conflicts of interest in the best interests of the Client. Although the potential is extremely rare, GVA has identified the following potential conflicts of interest: (i) where GVA manages any assets of a publicly traded company and also hold the securities of that company or an affiliated company in the account of a Client; (ii) where GVA has a Client relationship with an individual who is a (A) corporate director or a candidate for a corporate directorship of a public company or (B) senior executive of a public company, and the securities of that public company are held in the account of such Client; and (iii) where GVA’s employee is a (A) senior executive or (B) director or a candidate for a corporate directorship of a public company, the securities of which are held in the account of a Client which is managed by GVA. GVA maintains records to monitor these items. If any of the conflicts described above should arise, either GVA will vote the applicable securities proxies pursuant to our proxy policies 26  and procedures, or we will vote the applicable proxies consistent with the recommendations of a third-party proxy voting service. GVA has designated staff to be responsible for and oversee our proxy voting process, and to deal directly with third parties to ensure that proxies and related materials are properly obtained where necessary. The designated staff also works with GVA’s investment staff to cast votes, resolve issues with proxy voting vendors, and compile proxy voting reports. GVA Clients may obtain records on how we voted their shares, and GVA’s voting policies and procedures, on request by contacting sevasti@goalvestadvisory.com. Item 18: Financial Information A. Balance Sheet GVA neither requires nor solicits prepayment of more than $1,200 in fees per Client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither GVA nor its management has any financial condition that is likely to reasonably impair GVA’s ability to meet contractual commitments to Clients. C. Bankruptcy Petitions in Previous Ten Years GVA has not been the subject of a bankruptcy petition in the last ten years. i While GVA does not generally charge performance-based fees to direct separately managed or subadvised advisory accounts, such Clients that meet the definition of “Qualified Client” may at any time enter into an agreement with GVA to be charged performance fees (a “Performance Fee”). The Performance Fee, if charged, is negotiable. As of August 16, 2021, Qualified Client is defined as: “…a natural person who, or a company that: (a) immediately after entering into the contract has at least $1,100,000 under the management of the investment adviser; or (b) the investment adviser entering into the contract (and any person acting on his behalf) reasonably believes, immediately prior to entering into the contract, either: (i) has a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more than $2,200,000 or (ii) is a qualified purchaser as defined in section 2(a)(51)(A) of the Investment Company Act of 1940 at the time the contract is entered into.” 27