Overview
- Headquarters
- Miami, FL
- Total Firm Assets
- $111 million
- Average High-Net-Worth Client Portfolio Size
- $2.7 million
- Stated Minimum Account Size
- $1,000,000
Fee Disclosure
GOI FORM ADV PART 2A
| Min | Max | Disclosed Annual Rate |
|---|---|---|
| $0 | $500,000 | 2.00% |
| $500,001 | $1,000,000 | 1.50% |
| $1,000,001 | $5,000,000 | 1.00% |
| $5,000,001 | and above | 0.50% |
Estimated Annual Fees (Based on ADV disclosures. Where a range is given, we use the upper rate)
| Portfolio Value | Estimated Annual Fee | Effective Fee Rate |
|---|---|---|
| $1 million | $17,500 | 1.75% |
| $5 million | $57,500 | 1.15% |
| $10 million | $82,500 | 0.82% |
| $50 million | $282,500 | 0.56% |
| $100 million | $532,500 | 0.53% |
Clients
- High-Net-Worth Share of Firm Assets
- 92.93%
- Number of High-Net-Worth Clients
- 39
- Total Client Accounts
- 140
- Discretionary Accounts
- 140
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles
Regulatory Filings
- SEC CRD Number
- 319494
Primary Brochure: GOI FORM ADV PART 2A (2026-09-18)
View Document Text
Global Opportune Investments LLC
Form ADV Part 2A – Disclosure Brochure
Effective: September 18, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Global Opportune Investments LLC (“goi” or the “Adviser”). If you have any questions about the
content of this Disclosure Brochure, please contact the Adviser at 888-464-4742, 888-goi-4ria or by email at
rkhilnani@goi-ria.com.
goi is a registered investment adviser U.S. Securities and Exchange Commission (“SEC”). The information in this
Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange Commission or by any
state securities authority. Registration of an investment adviser does not imply any specific level of skill or training.
This Disclosure Brochure provides information about goi to assist you in determining whether to retain the Adviser.
Additional information about goi and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Adviser’s firm name or CRD# 319494.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Adviser’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of goi.
goi believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. goi encourages all current and
prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Adviser.
Material Changes
The following material changes have been made to this Disclosure Brochure since the last annual amendment filing
on March 3, 2026.
• goi has amended Item 4 and 5 to reflect the Adviser provides portfolio management services to an offshore
fund. Please see these Items for additional information.
• goi has amended Item 4.B Our Strategies to reflect updated indices and language. Please review this
section for information pertaining to our strategies.
• goi has eliminated the goi Six Pack strategy as an option for client to invest. This is reflected in Item 4.
Future Changes
From time to time, the Adviser may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete Disclosure
Brochure or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Adviser’s firm name or CRD# 319494. You
may also request a copy of this Disclosure Brochure at any time by contacting the Adviser at 888-464-4742, 888-
goi-4ria or by email at rkhilnani@goi-ria.com.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents ..................................................................................................................................... 3
Item 4 – Advisory Services .................................................................................................................................... 4
A. Firm Information .............................................................................................................................................................. 4
B. Advisory Services Offered ............................................................................................................................................... 4
C. Client Account Management ........................................................................................................................................... 9
D. Wrap Fee Programs ........................................................................................................................................................ 9
E. Assets Under Management ............................................................................................................................................. 9
Item 5 – Fees and Compensation ....................................................................................................................... 10
A. Fees for Advisory Services............................................................................................................................................ 10
B. Fee Billing...................................................................................................................................................................... 11
C. Other Fees and Expenses ............................................................................................................................................ 12
D. Advance Payment of Fees and Termination ................................................................................................................. 12
E. Compensation for Sales of Securities ........................................................................................................................... 13
Item 6 – Performance-Based Fees and Side-By-Side Management ................................................................ 13
Item 7 – Types of Clients ..................................................................................................................................... 13
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 13
A. Methods of Analysis ...................................................................................................................................................... 13
B. Risk of Loss ................................................................................................................................................................... 14
Item 9 – Disciplinary Information ........................................................................................................................ 16
Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 16
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 16
A. Code of Ethics ............................................................................................................................................................... 16
B. Personal Trading with Material Interest ......................................................................................................................... 17
C. Personal Trading in Same Securities as Clients ........................................................................................................... 17
D. Personal Trading at Same Time as Client .................................................................................................................... 17
Item 12 – Brokerage Practices ............................................................................................................................ 17
A. Recommendation of Custodian[s] ................................................................................................................................. 17
B. Aggregating and Allocating Trades ............................................................................................................................... 18
Item 13 – Review of Accounts ............................................................................................................................. 18
A. Frequency of Reviews ................................................................................................................................................... 18
B. Causes for Reviews ...................................................................................................................................................... 18
C. Review Reports ............................................................................................................................................................. 18
Item 14 – Client Referrals and Other Compensation ........................................................................................ 18
A. Compensation Received by goi .................................................................................................................................... 18
B. Compensation for Client Referrals ................................................................................................................................ 19
Item 15 – Custody ................................................................................................................................................. 19
Item 16 – Investment Discretion ......................................................................................................................... 19
Item 17 – Voting Client Securities ....................................................................................................................... 19
Item 18 – Financial Information ........................................................................................................................... 20
Form ADV 2B - Brochure Supplement[s] .......................................................................................................... 20
Privacy Policy ....................................................................................................................................................... 25
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 3
Item 4 – Advisory Services
A. Firm Information
Global Opportune Investments LLC (“goi” - pronounced joy - or the “Adviser”) is a Registered Investment Adviser
with the SEC. The Adviser is organized as a Limited Liability Company (LLC) under the laws of the State of Florida.
goi was founded in February 2022 and is owned and operated by Rakesh Khilnani (Founder, Chief Investment
Officer, and Chief Compliance Officer). This Disclosure Brochure provides information regarding the qualifications,
business practices, and the advisory services provided by goi.
B. Advisory Services Offered
goi offers investment advisory services to individuals, high net worth individuals, families, trusts, foundations,
partnerships, businesses, and retirement accounts (each referred to as a “Client”).
The Adviser serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Adviser upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. goi's fiduciary commitment is further described in the Adviser’s Code of Ethics. For more
information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client
Transactions and Personal Trading.
Investment Management Service
goi provides customized investment advisory solutions for its Clients. This is achieved through continuous personal
Client contact and interaction while providing discretionary and non-discretionary investment management and
related advisory services. goi works closely with each Client to identify their investment goals and objectives as
well as risk tolerance and financial situation in order to create a portfolio strategy.
Each account is managed individually and reflects our deep understanding of your stated investment objectives. goi
creates a strategy around your wealth, investment objectives and risk tolerance, which constantly evolves as family,
business, and economic circumstances change. goi works on behalf of you, managing your liquid assets in public
equities and ETF’s, fixed income securities, cash equivalents, private equity funds, options, and hedge funds, when
appropriate. When appropriate opportunities arise, goi will trade in international markets and when protection is
deemed necessary, in declining markets, goi may take reverse market exposure. goi uses a combination of
quantitative fundamental and technical analysis to select and manage investment holdings. Client portfolios generally
have exposure to both domestic and international markets.
goi works with you to develop an investment strategy and an asset allocation appropriately aligned with your
individual investment objectives and constraints.
A Portfolio Manager and/or Relationship Manager manages your relationship. Their role is to oversee your investment
portfolios, make specific recommendations about how your assets are invested, be cognizant of your risk profile
based on your investment objectives, financial profile and risk tolerance, and understand the specific and unique
needs of your family or business. When appropriate, goi will create a comprehensive financial plan tailored to your
needs. Such plan will consider income, debt, expenditures, insurance policies, retirement assets, trusts, savings and
any other pertinent data, to give you a holistic picture of your financial profile. Our financial plan considers your current
lifestyle, future allocations and can include “what-if” scenarios. The plan is monitored and reviewed with you on a
periodic basis to help guide and keep your goals within target. You may impose certain restrictions on investing in
certain securities or types of securities.
Financial planning and consulting recommendations pose a conflict between the interests of the Adviser and the
interests of the Client. For example, the Adviser has an incentive to recommend that Clients engage the Adviser for
investment management services or to increase the level of investment assets with the Adviser, as it would increase
the amount of advisory fees paid to the Adviser. Clients are not obligated to implement any recommendations made
by the Adviser or maintain an ongoing relationship with the Adviser. If the Client elects to act on any of the
recommendations made by the Adviser, the Client is under no obligation to implement the transaction through the
Adviser.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 4
In addition, goi can coordinate tax and estate planning with your other professionals to identify and implement unique
and customized strategies. At the point of completing your financial plan, if it is determined that estate planning
documents need to be generated, our comprehensive estate planning services are designed to provide you with
peace of mind and a clear path forward. Similarly, when a capital raise or lending need arises for you, goi collaborates
with you to find a suitable investment bank or lender.
Estate Planning Services
At the point of completing your financial plan, if it is determined that estate planning documents need to be generated,
our comprehensive estate planning services are designed to provide you with peace of mind and a clear path forward.
By utilizing the services of Estate Guru, we leverage their extensive network of experienced estate planning
professionals to provide you with personalized, legally sound solutions tailored to your unique needs.
Our Estate Planning Services Include:
1. Wills and Trusts: We help you create legally binding wills and trusts that outline how your assets will be
distributed. This ensures that your estate is handled according to your specific instructions and potentially
minimizes the impact of probate.
2. Power of Attorney: We assist in designating a trusted individual to make financial and medical decisions on
your behalf if you become unable to do so.
3. Estate Tax Planning: We provide strategies to minimize estate taxes, ensuring that more of your assets are
preserved for your beneficiaries.
4. Asset Protection: Protect your assets from potential creditors and legal claims with our tailored asset
protection plans.
5. Charitable Giving: Incorporate charitable donations into your estate plan to support causes you care about
while potentially reducing your tax burden.
The Basic Will Package Includes:
• Last Will and Testament
• Financial Power of Attorney
• Healthcare Power of Attorney
• Cloud Storage and Sharing
The Trust Package Includes:
• Revocable Living Trust
• Certification of Trust
• Pour-Over Wills
• Financial Power of Attorney
• Healthcare Power of Attorney
• Comprehensive Transfer Document
• Community Property Agreement
• Schedule of Assets
• Cloud Storage and Sharing
Certain estate planning services preparation services will earn Advisers additional fees in addition to the advisory
fees paid to goi for assets managed. This practice presents a conflict of interest because persons providing
investment advice have an incentive to recommend estate planning preparation services for the purpose of
generating fees rather than solely based on client needs. However, clients are under no obligation, contractually or
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 5
otherwise, to enter into an agreement for estate planning services from any person affiliated with the Adviser.
Clients are recommended this service only after going through the financial planning process where there is a
specific need for estate planning services. Please see Item 10 – Other Financial Industry Activities and Affiliations.
goi’s investment strategies are primarily long-term focused, but goi may buy, sell or re-allocate positions that have
been held less than one year to meet your objectives or due to market conditions. goi will construct, implement, and
monitor the portfolio to ensure it meets your agreed upon goals, objectives, circumstances, and risk tolerance. You
will have the opportunity to place reasonable restrictions on the types of investments to be held in your respective
portfolio, subject to acceptance by goi. goi evaluates and selects investments for inclusion in your portfolios only
after applying its internal due diligence process. goi may recommend, on occasion, redistributing investment
allocations to diversify the portfolio. goi may recommend specific positions to increase sector or asset class
weightings. goi may recommend employing cash positions as a possible hedge against market movement. goi may
also recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses,
business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the
position[s] in the portfolio, change in your risk tolerance, generating cash to meet your needs, or any risk deemed
unacceptable for your risk tolerance.
Our Strategies
goi Established Growth
The Established Growth Portfolio is a global equity strategy of 20 primarily large cap securities, representing our
highest conviction primarily large cap growth ideas at a reasonable price. Companies in the portfolio are expected to
deliver good price appreciation and the portfolio is tilted towards companies selected from the strongest performing
sectors and household names. The selection process is quantitative and incorporates both technical and fundamental
screens to minimize behavioral biases and capture positive market trends. Securities are monitored daily and are
removed from the portfolio upon deterioration of technical indicators. Appreciating positions continue to be held and
are scaled back to meet model allocations annually. The portfolio remains mostly fully invested through both up and
down-market cycles. In extreme market conditions when we are unable to find 20 securities that meet our criteria, we
will temporarily hold cash and/or cash equivalents until market conditions improve. Clients should be capable of
absorbing the volatility associated with the S&P 500 Growth Index and have at least a 3 to 5-year time horizon.
goi Established Value
The Established Value Portfolio is a global equity strategy of 20 primarily large cap securities, representing our
highest conviction primarily large cap value ideas. The portfolio is comprised of dividend paying securities that are
priced reasonably to cash flow, book value and sales levels. The selection process applies fundamental screens with
a focus on the quality of the business, consensus analysts targets and the prevailing stock prices. This strategy
prioritizes stable businesses including household names. Securities are monitored daily and are removed from the
portfolio upon reaching price targets or erosion of cash flow, book value, or sales metrics. The portfolio is rebalanced
annually. The portfolio remains mostly fully invested through both up and down-market cycles. In extreme market
conditions when we are unable to find 20 securities that meet our criteria, we will temporarily hold cash and/or cash
equivalents until market conditions improve. Clients should be capable of absorbing the volatility associated with the
S&P 500 Value Index and have at least a 3 to 5-year time horizon.
goi Disruptors+
The Disruptors+ Portfolio is a global equity strategy of 20 disruptive or special situation companies, representing our
highest conviction high-growth ideas. The high expected growth may be due to the company’s disruptive technologies
or expected recovery from negative situations. Companies in the portfolio are expected to deliver very high sales and
earnings growth in the future but may not presently have positive earnings per share. The selection process is
quantitative and incorporates both technical and fundamental screens to minimize behavioral biases and capture
positive market trends. Although holdings are predominantly midcap companies, they may include large cap and
small cap companies as well. Securities are removed from the portfolio upon deterioration of technical indicators to
potentially limit significant downside. Appreciating positions continue to be held and are scaled back to meet model
allocations annually. The portfolio remains mostly fully invested through both up and down-market cycles. In extreme
market conditions when we are unable to find 20 securities that meet our criteria, we will temporarily hold cash and/or
cash equivalents until market conditions improve. As a concentrated portfolio of relatively new and/or highly volatile
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 6
companies, clients should consider Disruptors+ as part of an otherwise diversified portfolio. Further, clients should
be willing to ride out substantial volatility associated with the S&P 400 Midcap Growth Index and have at least a 5-
year time horizon.
goi Blend 20
The Blend 20 Portfolio is a global equity strategy of 20 companies, representing a combined, yet abridged, approach
of Growth at a Reasonable Price, Value, and Disruptive / Special Situation companies. The securities in this portfolio
are selected from the Established Growth, Established Value and Disruptors+ strategies with about 50% of the
securities coming from Established Growth, about 30% from Established Value and about 6% from Disruptors+.
Please review each of these individual strategies for details on the specific selection processes. The positions in
Blend 20 are monitored daily, and positions will be sold when they are removed from the underlying strategies from
which the stocks were chosen. The portfolio is rebalanced annually. Clients should be capable of absorbing the
volatility associated with the S&P 500 Index and have at least a 3 to 5-year time horizon.
goi Blend 60
The Blend 60 Portfolio is a global equity strategy of 60 companies, representing a combined approach of Growth at
a Reasonable Price, Value, and Disruptive / Special Situation companies. The securities in this portfolio consists of
approximately 50% Established Growth, 30% Established Value and 20% Disruptors+ strategies in their entirety.
Please review each of these individual strategies for details on the specific selection processes. The positions are
monitored daily, and positions will be sold when they are removed from the underlying strategies from which the
stocks were chosen. In extreme market conditions when we are unable to find 60 securities that meet our criteria, we
will temporarily hold cash and/or cash equivalents until market conditions improve. The portfolio is rebalanced
annually. Clients should be capable of absorbing the volatility associated with the S&P 500 Index and have at least
a 3 to 5-year time horizon.
goi Focus
The Focus Portfolio is a global, multi asset class strategy of 15 securities, representing our highest conviction ideas
from all our strategies. The selection process is quantitative and incorporates both technical and fundamental screens
to minimize behavioral biases and capture positive market trends. Securities held in the portfolio have, what we
believe to be, the strongest technical and fundamental indicators. Holdings may include large cap, mid cap, small
cap, international, and alternative securities. Securities are removed from the portfolio upon deterioration of technical
indicators to potentially limit significant downside. Appreciating positions continue to be held and are scaled back to
meet model allocations annually. The portfolio remains mostly fully invested through both up and down-market cycles.
As a more concentrated portfolio, the potential for increased volatility exists, with the expectation of a higher return
over time. In extreme market conditions when we are unable to find 15 securities that meet our criteria, we will
temporarily hold cash and/or cash equivalents until market conditions improve. Clients should be capable of
absorbing 1.2 times the volatility associated with the S&P 500 Index and have at least a 3 to 5-year time horizon.
goi Dynamic ETF
The Dynamic ETF Portfolio is a global equity strategy of up to 10 ETF/ETNs with the intention of staying dynamically
yet fully invested through market volatility in the strongest sectors and / or themes. The Dynamic ETF portfolio is
intended for clients that wish to participate in general trends in the market without the ownership of individual stocks.
The strongest sectors and / or themes are determined using our technical trading systems. The universe of ETF/ETNs
are reviewed regularly, and the portfolio is adjusted accordingly. Holdings may include sector, thematic, international,
or alternative ETF/ETNs. ETF/ETNs within the portfolio are monitored daily and will be allowed to appreciate until the
technical sell signal is triggered. In extreme market conditions when we are unable to find up to 10 ETFs/ETNs that
meet our criteria, we will temporarily hold cash and/or cash equivalents until market conditions improve. Clients
should be capable of absorbing the volatility associated with the S&P 500 Index and have at least a 3 to 5-year time
horizon.
goi Fixed Income
The Fixed Income Portfolio consists of up to 10 Bond ETFs that typically have fixed maturities. The ETFs are laddered
over 10 years. High-Yield Bond and/or Private Credit exposure is used for earlier maturity years and Investment
Grade Corporates, Munis, or Treasuries/Agencies are used for later maturity years. In addition, the portfolio may
include currency hedged and interest-rate hedged Bond ETFs. As the investments are laddered, a portion of the
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 7
portfolio is expected to mature almost every year, providing the ability to take distributions or reinvest. This portfolio
is intended for investors that seek fixed income or have a desire to reduce their overall portfolio risk by coupling it
with their equity portfolios. Investors should be capable of absorbing the volatility associated with the Barclays US
Aggerate Bond Index.
goi CAPE
The CAPE Portfolio consists of up to 10 ETF/ETNs in the Commodities, Alternatives, and Precious Metals space.
The objective is to gain diversification against an otherwise balanced portfolio of Stocks and Bonds. This strategy
may serve as a hedge against a standard stock / bond portfolio, a weakening dollar and inflation. The ETF/ETNs are
selected using our technical trading system and will be allowed to appreciate until the technical sell signal is triggered.
If none of the investments in the CAPE portfolio’s universe are on a buy-signal, we may stay in cash and/or cash
equivalents until the investment climate improves. The positions are monitored daily and are subject to an annual
rebalance. Clients should already have diversified portfolios, be capable of absorbing 1.5 times the volatility
associated with the Wilshire Liquid Alternatives Index and have at least a 3 to 5-year investment time horizon.
goi Equity Income
The Equity Income Portfolio consists of 15 high dividend paying securities with a portfolio target yield of
approximately 5% or greater. These securities may include REITs, MLPs, or high dividend common stocks. The
selection process applies fundamental screens with a focus on the quality of the business, consensus analysts
targets and the prevailing stock prices. This strategy does not discriminate by market capitalization and as such, my
hold a majority of small to mid-capitalization securities. Securities are monitored daily and are removed from the
portfolio upon reaching price targets or erosion of dividend coverage, cash flow, book value, or sales metrics, and is
rebalanced annually. The portfolio remains mostly fully invested through both up and down-market cycles. The
Equity Income portfolio may tactically hold significant amounts of cash and / or cash equivalents when high
dividend-yielding securities meeting our criteria cannot be found. If underperformance of high yield equity is
anticipated, we may also hold short term high yield bond ETFs in the interim. Appreciating positions continue to be
held in the portfolio and are scaled back to model allocations annually. It should be noted that MLPs generate K1s.
The Equity Income Portfolio is expected to have lower correlation to standard equity portfolios and thus can be
utilized to potentially reduce the overall long-term volatility of an otherwise balanced portfolio or as a bond
surrogate. Clients should be capable of absorbing the volatility associated with the Dow Jones Select Dividend
index.
At no time will goi accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Adviser provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Adviser is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Adviser will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the
assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account
to fee-based account). Such a recommendation creates a conflict of interest if the Adviser will earn a new (or
increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a
retirement account to an account managed by the Adviser.
Financial Planning Services
goi will typically provide a variety of financial planning and consulting services to Clients, in association with its
Investment Management services. Services are offered in several areas of a Client’s financial situation, depending
on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan
or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 8
A financial plan developed for, or financial consultation rendered to, the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence, or alter
retirement savings, establish education savings and/or charitable giving programs.
goi may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation.
For certain financial planning engagements, the Adviser will provide a written summary of the Client’s financial
situation, observations, and recommendations. For consulting or ad-hoc engagements, the Adviser may not provide
a written summary. Plans or consultations are typically completed within six (6) months of contract date, assuming
all information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Adviser and the
interests of the Client. For example, the Adviser has an incentive to recommend that Clients engage the Adviser for
investment management services or to increase the level of investment assets with the Adviser, as it would
increase the amount of advisory fees paid to the Adviser. Clients are not obligated to implement any
recommendations made by the Adviser or maintain an ongoing relationship with the Adviser. If the Client elects to
act on any of the recommendations made by the Adviser, the Client is under no obligation to implement the
transaction through the Adviser.
Portfolio Management to an Offshore Fund
goi provides discretionary portfolio management services to ETPCAP2 Designated Activity Company (“ETPCAP2”)
in connection with the goi Focus Strategy – Offshore (Series 590) Notes due 2046. Pursuant to a Portfolio
Management Agreement, the Adviser serves as Portfolio Manager and has discretionary authority to manage the
portfolio of securities and other assets attributable to the Series 590 Notes, subject to the applicable investment
objective, investment strategy and management criteria.
ETPCAP2 is the issuer of the Series 590 Notes. The Notes are secured, limited-recourse debt obligations of
ETPCAP2. The holders of the Notes are not clients of the Adviser solely by virtue of their ownership of the Notes
and do not have a direct advisory relationship with goi.
C. Client Account Management
Prior to engaging goi to provide investment advisory services, each Client is required to enter into one or more
agreements with the Adviser that define the terms, conditions, authority and responsibilities of the Adviser and the
Client. These services may include:
• Establishing an Investment Strategy – goi, in connection with the Client, will develop a strategy that seeks
to achieve the Client’s goals and objectives.
• Asset Allocation – goi will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation, and tolerance for risk for each Client.
• Portfolio Construction – goi will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
•
Investment Management and Supervision – goi will provide investment management and ongoing oversight
of the Client’s investment portfolio.
D. Wrap Fee Programs
goi does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by goi.
E. Assets Under Management
As of August 31, 2026, goi had regulatory assets under management of $115,535,906, all of which were managed
on a discretionary basis. In addition, goi provided financial planning and related advisory services with respect to
an additional $131,042,180 in assets that were not included in regulatory assets under management. Accordingly,
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 9
the total assets for which goi provided management and advisory oversight were approximately $246,578,086 as of
August 31, 2026. Clients may request more current information at any time by contacting the Adviser.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Adviser. Each Client engaging the Adviser for services described herein shall be required to enter into one or more
written agreements/a written agreement with the Adviser.
A. Fees for Advisory Services
Investment Management Services
goi investment advisory fees are paid quarterly, in advance, at the rate schedule below, based on the appraised
value of actively managed assets. In addition, the Adviser will provide the Client a report itemizing the fee, including
the calculation period covered by the fee, the account value and the methodology used to calculate the fee. It is the
responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage statement as
the Custodian does not assume this responsibility. Clients provide written authorization permitting advisory fees to
be deducted by goi to be paid directly from their account[s] held by the Custodian as part of the investment
advisory agreement and separate account forms provided by the Custodian.
goi Advisory Fee Schedule - Asset Management
AG - Aggressive Growth
MG - Moderate Growth
CG - Conservative Growth
AG&I - Aggressive Growth & Income
MG&I - Moderate Growth & Income
CG&I - Conservative Growth & Income
AI - Aggressive Income
MI - Moderate Income
CI - Conservative Income
Investment Objective / Risk Target
Household Value AG/90 MG/80 CG/70
1.70%
2.00%
First $500,000
1.28%
1.50%
Next $500,000
0.85%
1.00%
Next $4 million
0.43%
0.50%
Over $5 million
1.80%
1.35%
0.90%
0.45%
1.40%
1.05%
0.70%
0.35%
AI/30
1.30%
0.98%
0.65%
0.33%
MI/20
1.20%
0.90%
0.60%
0.30%
CI/10
1.00%
0.75%
0.50%
0.25%
AG&I/60 MG&I/50 CG&I/40
1.50%
1.60%
1.13%
1.20%
0.75%
0.80%
0.38%
0.40%
* Fees do not include custodian, and trading costs. Fees do not include third-party money manager or other
platform fees.
The tiered fee schedule results in a “blended” fee based on the assets under management at the time of the billing
calculation. For example, for an account in a conservative income strategy, assets valued at $1,000,000 based on
the above schedule, Clients will be billed 1.00% for the first $500,000, and 0.75% for the next $500,000. This
results in a blended rate of 0.88% annually.
A customized blend of goi strategies can be created to satisfy the investment objectives above. goi’s annual portfolio
management fee is billed and payable, quarterly in advance, based upon the market value of the assets on the last
business day of the previous quarter, as specified in your written agreement with goi (the “goi IAA”). If the goi IAA
is executed at any time other than the first day of a calendar quarter, goi’s fees will apply on a pro rata basis, which
means that the goi Fee is payable in proportion to the number of days in the quarter for which you are a client. Such
adjustments are reflected in the fee calculations for the next quarterly period. In the event the goi IAA is terminated,
the fee for the final billing period is prorated through the effective date of the termination and the unearned portion is
refunded to the client, as appropriate. No increase in the annual fee percentage shall be effective without 30 days’
prior written notification to you.
Portfolio Management to the goi Focus Strategy - Offshore Fund
The Adviser provides portfolio management services to the Series pursuant to a Portfolio Management Agreement.
The Adviser is entitled to receive a management fee equal to 0.75% per annum of the Net Asset Value of the
Portfolio. The management fee is calculated as of each NAV Calculation Date in accordance with the terms of the
Series Memorandum. The fund is only offered to qualified non-U.S. entities.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 10
The management fee is not negotiable.
Estate Planning Services:
When providing estate planning services as described above, please find the associated pricing for these services
below. 50% of the fees associated with these services is collected in advance, paid to Estate Guru and is non-
refundable. The remaining balance is due upon delivery of the estate planning documents.
• Financial Power of Attorney: complementary service
• Healthcare Power of Attorney: complementary service
Basic Will Package:
•
Individual: $500
• Married: $1,000
Trust Package:
Individual or Married: $1,400
•
Real Estate Retitling: $200 (Online service / per property)
Amendments:
• First Year: complementary service
• After the First Year:
o Will: $300
o Trust: $400
Any estate planning services beyond the scope mentioned above may incur an additional cost and will be pre-
negotiated based upon the determination of the extent of customization and complexity.
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Adviser or its delegate and deducted from the Client’s account[s] at the
Custodian. The Adviser shall send an invoice to the Custodian indicating the amount of the fees to be deducted from
the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the annual
rate (annual rate divided by 4) to the total assets under management with goi at the end of the prior quarter. Clients
will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory
fee. Clients are urged to also review and compare the statement provided by the Adviser to the brokerage statement
from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization
permitting advisory fees to be deducted by goi to be paid directly from their account[s] held by the Custodian as part
of the investment advisory agreement and separate account forms provided by the Custodian.
Estate Planning Services
The initial 50% due is paid directly to Estate Guru through www.estateguru.com. Final payment is paid to goi either
through debiting an existing non-retirement account; check made payable to goi; electronic funds transfer (wire; ACH,
Zelle). The Client will elect which option to pay for these services through the estate planning services agreement.
Portfolio Management to an Offshore Fund
The management fee is deducted from the Portfolio and is payable to the Adviser within ten (10) business days
following the end of each calendar month.
The Adviser is authorized to utilize the management fee to make payments to third parties for services provided to the
Adviser in accordance with the terms of the Portfolio Management Agreement.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 11
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than goi, in connection with investments
made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees
charged by the Custodian, as applicable. The Adviser's recommended Custodian does not charge securities
transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and
conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds
and other types of investments. The fees charged by goi are separate and distinct from these custody and
execution fees.
In addition, all fees paid to goi for investment advisory services are separate and distinct from the expenses
charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in
each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds,
other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible
distribution fee. A Client may be able to invest in these products directly, without the services of goi, but would not
receive the services provided by goi which are designed, among other things, to assist the Client in determining
which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the
Client should review both the fees charged by the fund[s] and the fees charged by goi to fully understand the total
fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
We may trade client accounts on margin. You must sign a separate margin agreement before margin is extended to
your account. Fees for advice and execution on these securities are based on the total asset value of the account,
which includes the value of the securities purchased on margin. While a negative amount may show on your
statement for the margined security as the result of a lower net market value, the amount of the fee is based on the
absolute market value. This can create a conflict of interest where we have an incentive to encourage the use of
margin to create a higher market value and therefore receive a higher fee. The use of margin may also result in
interest charges in addition to all other fees and expenses associated with the security involved.
Portfolio Management to an Offshore Fund
In addition to the management fee described above, the Portfolio and/or Series are responsible for certain other
fees and expenses associated with the establishment, operation, administration and maintenance of the Series.
These expenses may include fees and expenses payable to the Trustee, agents, Programme Coordinator,
Securities Account Provider, Broker Dealer of Record, auditors, corporate services providers, legal counsel and
other service providers, as well as certain issuance, listing, clearing, administrative and other ordinary or
extraordinary expenses.
The Portfolio is also responsible for applicable fees and expenses of the Securities Account Provider and other
expenses incurred in connection with the Portfolio's investments and operations. The offshore fund is only available
to qualified non-U.S. entities as defined in the Series Memorandum. Investors should review the Series
Memorandum for a complete description of the fees and expenses applicable to the Series.
D. Advance Payment of Fees and Termination
Investment Management Services
goi may be compensated for its investment management services in advance of the quarter in which services are
rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the investment advisory agreement within five (5) business
days of signing the Adviser’s agreement at no cost to the Client. After the five-day period, the Client will incur charges
for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the
Client. Upon termination, the Adviser will refund any unearned, prepaid investment advisory fees from the effective
date of termination to the end of the quarter. The Client’s investment advisory agreement with the Adviser is non-
transferable without the Client’s prior consent.
Portfolio Management to an Offshore Fund
The Adviser does not require management fees to be collected in advance. The management fee is calculated
based on the Net Asset Value of the Portfolio and is deducted from the Portfolio on the applicable payment date.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 12
E. Compensation for Sales of Securities
goi does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
goi does not charge performance-based fees for its investment advisory services. The fees charged by goi are as
described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by any
Client.
goi does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a
hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
goi offers investment advisory services to individuals, high net worth individuals, families, trusts, foundations,
partnerships, businesses, retirement accounts, and an offshore fund. goi generally requires a minimum relationship
size of $1,000,000 to effectively implement its investment process. goi reserves the right to lower the account
minimums at its discretion.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
goi employs charting, technical, fundamental, cyclical and modern portfolio theory analysis methods in developing
investment strategies for its Clients. Research and analysis from goi are derived from numerous sources, including
financial media companies, third-party research materials, Internet sources, and review of company activities,
including annual reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criterion
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity being
analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with
a value discounted by the market. While this type of analysis helps the Adviser in evaluating a potential investment,
it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in
the fundamental analysis may lose value and may have negative investment performance. The Adviser monitors
these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the
Adviser’s review process are included below in Item 13 – Review of Accounts.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and
trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk
in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if
the trend will eventually reoccur, there is no guarantee that goi will be able to accurately predict such a
reoccurrence.
Cyclical analysis is similar to technical analysis in that it involves the analysis of market conditions at a macro
(entire market/economy) or micro (company specific) level, rather than the overall fundamental analysis of the
health of the particular company that goi is recommending. The risks with cyclical analysis are similar to those of
technical analysis.
Charting analysis utilizes various market indicators as investment selection criteria. These criteria are generally
pricing trends that may indicate movement in the markets. Assets are deemed suitable if they meet certain criteria
to indicate that they are a strong investment with a value discounted by the market. While this type of analysis
helps the Adviser in evaluating a potential investment, it does not guarantee that the investment will increase in
value. Assets meeting the investment criteria utilized in the technical and charting analysis may lose value and may
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 13
have negative investment performance. The Adviser monitors these market indicators to determine if adjustments
to strategic allocations are appropriate.
Modern portfolio theory analysis is the theory of investments which attempts to maximize portfolio expected returns
for a given amount of portfolio risk or to minimize risk for a given level of expected return, by carefully diversifying
the proportions of various assets.
As noted above, goi generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. goi will typically hold all or a portion of a security for more than a year, but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, goi may also buy
and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals
of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. goi will assist Clients in determining an appropriate strategy
based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will
meet their investment goals. Please see Item 8.B. for risks associated with the Adviser’s investment strategies as
well as general risks of investing.
While the methods of analysis help the Adviser in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Adviser monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Adviser’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Adviser shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Adviser of any changes in financial condition, goals or
other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Adviser will work with each Client to determine their tolerance for risk as part of the portfolio construction
process. Following are some of the risks associated with the Adviser’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk
based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-
ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may
dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased
or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon
rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than
was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 14
exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk
associated with purchasing a debt instrument which includes the possibility of the company defaulting on its
repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the
company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity
Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same
price as a mutual fund purchased later that same day.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts
are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock.
This leverage can compound gains or losses.
Quantitative/Algorithmic Investing
The Adviser’s investment recommendations are based on proprietary algorithms. The risks associated with this
type of investing are as follows:
• Quantitative Risk: The risk that the effectiveness of the quantitative strategy can dissipate over time as
•
similar strategies are adopted and as the market becomes more efficiently priced.
Input Data Risk: The risk that the information and data supplied to the algorithm is subject to input and
quality errors. The Adviser’s strategies depend on the accuracy and reliability of the data and the strategies
may not function properly if the data proves to be incorrect or incomplete, or is input incorrectly.
• Programming Risk: The Adviser’s research and strategy development process is extremely complex and
the results of that process must then be translated into computer code. Although the Adviser seeks to hire
individuals skilled in each of these functions and to provide appropriate levels of oversight, the complexity
of the individual tasks, the difficulty of integrating such tasks, and the limited ability to perform “real world”
testing of the end product raises the chances that the finished algorithm may contain an error; one or more
of such errors could adversely affect a client’s portfolio.
• System Risk: The Adviser relies extensively on computer programs and systems in its proprietary
algorithms to evaluate securities, to monitor its portfolio, and to generate reports that are critical to
oversight of its activities. In addition, certain systems are operated by third party service providers. The
Adviser may not always be in the best position to verify the risks or reliability of such third-party systems.
These programs or systems, whether operated by a third party or not, may be subject to certain defects,
failures or interruptions, including, but not limited to, those caused by computer “worms,” viruses and power
failures. Any such defect or failure could have a material adverse effect on the Adviser’s activities. For
example, such failures could cause settlement of trades to fail, lead to inaccurate accounting, recording or
processing of trades, and cause inaccurate reports, which may affect the Adviser’s ability to monitor its
investment portfolios and its risks.
• Operational Risk: The Adviser has developed systems and procedures to control operational risk.
Operational risks arising from mistakes made in the trading confirmation or settlement of transactions, from
transactions not being properly booked, evaluated or accounted for or other similar disruption in The
Adviser’s operations may cause the Adviser to suffer financial loss; the disruption of its business; liability to
Clients or third parties; regulatory intervention; or reputational damage. The Adviser relies heavily on its
financial, accounting and other data processing systems.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Client should only have a portion of their assets in these investments.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 15
Frequent Trading
Frequent trading in securities can result in higher transaction costs in the Client’s account[s]. For taxable accounts,
frequent trading can also result in taxable transactions each year that would not be present in a buy-and-hold
strategy. There are no guarantees that a frequent trading strategy will correctly time purchases and sales of any
particular security.
Real Estate Investment Trusts (“REITs”)
Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks
associated with investing in the real estate industry in general. For Example, equity REITs may be affected by
changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the
quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and self-
liquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the
value of the REIT may decline).
Cryptocurrency ETF Risks
Cryptocurrency ETFs are investment vehicles designed to provide exposure to the price movements of
cryptocurrencies or cryptocurrency-related assets through exchange-listed securities. Cryptocurrencies and
cryptocurrency-related markets are highly volatile. Prices may fluctuate dramatically over short periods of time due
to factors including, but not limited to, market sentiment, technological developments, macroeconomic events,
regulatory actions, and changes in liquidity. As a result, Cryptocurrency ETFs may experience rapid and substantial
losses. A Cryptocurrency ETF’s performance may differ materially from the crypto market exposure it seeks to provide
due to fees and expenses, portfolio construction and rebalancing, and the use of derivatives, and during periods of
market stress liquidity may decline, bid-ask spreads may widen, shares may trade above or below the value of
underlying holdings, and trading may be halted or limited, which may prevent buying or selling at desired times or
prices.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Adviser.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving goi or its owner or management persons. goi
values the trust Clients place in the Adviser. The Adviser encourages Clients to perform the requisite due diligence
on any adviser or service provider that the Client engages. The backgrounds of the Adviser or Advisory Persons
are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with
the Adviser’s firm name or CRD# 319494.
Item 10 – Other Financial Industry Activities and Affiliations
goi does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the wealth management fees noted above.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
goi has implemented a Code of Ethics (the “Code”) that defines the Adviser’s fiduciary commitment to each Client.
This Code applies to all persons associated with goi (“Supervised Persons”). The Code was developed to provide
general ethical guidelines and specific instructions regarding the Adviser’s duties to each Client. goi and its
Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of goi’s
Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that
guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To
request a copy of the Code, please contact the Adviser at 888-464-4742, 888-goi-4ria or via email at
rkhilnani@goi-ria.com.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 16
B. Personal Trading with Material Interest
goi allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. goi does not act as principal in any transactions. In addition, the Adviser does not
act as the general partner of a fund, or advise an investment company. goi does not have a material interest in any
securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
goi allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Adviser has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by goi requiring reporting of personal securities trades by its Supervised Persons for review by the Chief
Compliance Officer (“CCO”) or delegate. The Adviser has also adopted written policies and procedures to detect
the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While goi allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no
time will goi, or any Supervised Person of goi, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
goi does not have discretionary authority to select the broker-dealer/custodian for custody and execution services.
The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and
authorize goi to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, goi
does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis.
Where goi does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to
Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the
Adviser and will not incur any extra fee or cost from the Adviser associated with using a custodian not
recommended by goi. However, the Adviser may be limited in the services it can provide if the recommended
Custodian is not engaged. goi may recommend the Custodian based on criteria such as, but not limited to,
reasonableness of commissions charged to the Client, services made available to the Client, and its reputation
and/or the location of the Custodian’s offices.
goi will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”), a
FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. goi
maintains an institutional relationship with Schwab, whereby the Adviser receives economic benefits from Schwab
(Please see Item 14 below.)
Following are additional details regarding the brokerage practices of the Adviser:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an adviser
enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and
other services. goi does not participate in soft dollar programs sponsored or offered by any broker-
dealer/custodian. However, the Adviser receives certain economic benefits from the Custodian. Please see
Item 14 below.
2. Brokerage Referrals - goi does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 17
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where goi will place trades within
the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded within
their respective account[s]. The Adviser will not engage in any principal transactions (i.e., trade of any security from
or to the Adviser’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into
one Client account from another Client’s account[s]). goi will not be obligated to select competitive bids on
securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs
are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. goi will execute its transactions through the Custodian as
authorized by the Client. goi may aggregate orders in a block trade or trades when securities are purchased or sold
through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be
executed in full at the same price or time, the securities actually purchased or sold by the close of each business
day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This
must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Rakesh Khilnani, Chief
Compliance Officer of goi. Formal reviews are generally conducted at least annually or more frequently depending
on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result
of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify goi if changes occur in the Client’s
personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be
triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the
Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Adviser may also
provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by goi
goi is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product. goi
does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third
party. goi may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys, accountants, estate
planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, goi may receive
non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Adviser Platform
goi has established an institutional relationship with Schwab through its “Schwab Adviser Services” unit, a division
of Schwab dedicated to serving independent advisory firms like goi. As a registered investment adviser
participating on the Schwab Adviser Services platform, goi receives access to software and related support without
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 18
cost because the Adviser renders investment management services to Clients that maintain assets at Schwab.
Services provided by Schwab Adviser Services benefit the Adviser and many, but not all services provided by
Schwab will benefit Clients. In fulfilling its duties to its Clients, the Adviser endeavors at all times to put the interests
of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates
a potential conflict of interest since these benefits may influence the Adviser's recommendation of this custodian
over one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Adviser may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Adviser may be able to invest in certain mutual funds and
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisers with access to technology,
research, discounts and other services. In addition, the Adviser receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with
Schwab. These services are intended to assist the Adviser in effectively managing accounts for its Clients but may
not directly benefit all Clients.
Services that May Only Benefit the Adviser – Schwab also offers other services to goi that may not benefit the
Client, including: educational conferences and events, financial start-up support, consulting services and discounts
for various service providers. Access to these services creates a financial incentive for the Adviser to recommend
Schwab, which results in a potential conflict of interest. goi believes, however, that the selection of Schwab as
Custodian is in the best interests of its Clients.
B. Compensation for Client Referrals
The Adviser does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place all
assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and securities
and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client should review
statements provided by the Custodian, as the Custodian does not perform this review. For more information about
custodians and brokerage practices, see Item 12 – Brokerage Practices.
Item 16 – Investment Discretion
goi generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by goi.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will
be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to
such authority. All discretionary trades made by goi will be in accordance with each Client's investment objectives
and goals.
In certain circumstances, goi does not have discretion over the selection and amount of securities to be bought or
sold in Client accounts without obtaining prior approval from the Client. The Adviser will contact the Client and
obtain approval prior to executing trades or allocating investment assets.
Item 17 – Voting Client Securities
goi does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the
Custodian. The Adviser will assist in answering questions relating to proxies, however, the Client retains the sole
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 19
responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither goi, nor its management, have any adverse financial situations that would reasonably impair the ability of
goi to meet all obligations to its Clients. Neither goi, nor any of its Advisory Persons, have been subject to a
bankruptcy or financial compromise. goi is not required to deliver a balance sheet along with this Disclosure
Brochure as the Adviser does not collect advance fees of $1,200 or more for services to be performed six months
or more in the future.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 20
Form ADV Part 2B – Brochure Supplement
for
Rakesh Khilnani
CEO / CIO / CCO
Effective: September 18, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Rakesh K. Khilnani (CRD# 2259700) in addition to the information contained in the Global Opportune Investments
LLC (“goi” or the “Advisor”, CRD# 319494) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the goi Disclosure Brochure or this Brochure
Supplement, please contact us at 888-464-4742, 888-goi-4ria.
Additional information about Mr. Khilnani is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2259700.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 21
Item 2 – Educational Background and Business Experience
Year of Birth: 1963
Formal Education After High School:
Wayne State University– College of Engineering, Mechanical Engineering, 1988
Employment History:
Chief Executive Officer, Chief Investment Officer, & Chief Compliance Officer, goi
Chief Investment Officer, Global Capital Strategies II, LLC
Registered Principal, Arq Advisors LLC
Chief Executive Officer / Chief Compliance Officer, Global Capital Strategies LLC
Financial Advisor, Catella & Co. Inc.
Managing Principal, PIM Portfolio Manager, Wells Fargo Advisors Financial Network
04/2022 to Present
06/2019 to 04/2022
01/2019 to 04/2022
01/2018 to 04/2022
01/2018 to 12/2018
05/2009 to 01/2018
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Khilnani. Mr. Khilnani has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Mr. Khilnani.
Securities laws require an adviser to disclose any instances where the adviser or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Khilnani.
However, we do encourage you to independently view the background of Mr. Khilnani on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
2259700.
Item 4 – Other Business Activities
President
Mr. Khilnani is the President of Khilnani Wealth Management LLC. Mr. Khilnani spends approximately 5 hour per
week in his role as the President.
Item 5 – Additional Compensation
Mr. Khilnani has other business activity where compensation is received that is detailed in Item 4 above.
Item 6 – Supervision
Mr. Khilnani serves as the Chief Investment Officer, Chief Executive Officer and Chief Compliance Officer of goi.
Mr. Khilnani can be reached at 888-464-4742.
goi has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of goi. Further, goi is subject to regulatory oversight by various
agencies. These agencies require registration by goi and its Supervised Persons. As a registered entity, goi is
subject to examinations by regulators, which may be announced or unannounced. goi is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Adviser.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 22
Form ADV Part 2B – Brochure Supplement
for
Ariana E. Sher
Investment Adviser Representative
Effective: September 18, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Ariana E. Sher (CRD# 7848236) in addition to the information contained in the Global Opportune Investments LLC
(“goi” or the “Adviser”, CRD# 319494) Disclosure Brochure. If you have not received a copy of the Disclosure
Brochure or if you have any questions about the contents of the goi Disclosure Brochure or this Brochure
Supplement, please contact us at 888-464-4742, 888-goi-4ria.
Additional information about Ms. Sher is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 7848236.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 23
Item 2 – Educational Background and Business Experience
Ariana E. Sher, born in 1996, is dedicated to advising Clients of GOI as an Advisor. Ms. Sher earned an
International Business BBA from CUNY Baruch Zicklin School of Business in 2020. Additional information regarding
Ms. Sher’s employment history is included below.
Employment History:
IAR, Global Opportune Investments LLC
Manager, New Business, Global Strategy Group
Project Manager, nmbl
Vendor and Account Manager, Commander Health Supply
Recruiter, Akadia
Intern - Strategy and New Business, Strawberry Frog
Journalist, Sevilla World
Intern - Marketing, UnidaysUS
01/2024 to Present
09/2022 to 08/2023
08/2021 to 09/2022
05/2020 to 08/2021
02/2019 to 04/2020
08/2017 to 05/2018
06/2017 to 07/2017
01/2017 to 06/2017
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Sher. Ms. Sher has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration claims
or administrative proceedings against Ms. Sher.
Securities laws require an adviser to disclose any instances where the adviser or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Ms. Sher.
However, we do encourage you to independently view the background of Ms. Sher on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD#
7848236.
Item 4 – Other Business Activities
Ms. Sher is licensed real estate agent. As a real estate agent Ms. Sher spends less than 5% of her time engaged in
this activity and less than 5% of her compensation is derived from this activity.
Item 5 – Additional Compensation
Ms. Sher has other business activity where compensation is received that is detailed in Item 4 above.
Item 6 – Supervision
Ms. Sher serves as an Advisor of goi and is supervised by Rakesh Khilnani, the Chief Compliance Officer. Mr.
Khilnani can be reached at 888-464-4742.
goi has implemented a Code of Ethics, an internal compliance document that guides each Supervised Person in
meeting their fiduciary obligations to Clients of goi. Further, goi is subject to regulatory oversight by various
agencies. These agencies require registration by goi and its Supervised Persons. As a registered entity, goi is
subject to examinations by regulators, which may be announced or unannounced. goi is required to periodically
update the information provided to these agencies and to provide various reports regarding the business activities
and assets of the Adviser.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 24
Privacy Policy
Effective: September 18, 2026
Our Commitment to You
Global Opportune Investments LLC (“goi” or the “Adviser”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Adviser, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. goi (also referred to as "we", "our" and "us”)
protects the security and confidentiality of the personal information we have and implements controls to ensure that
such information is used for proper business purposes in connection with the management or servicing of our
relationship with you.
goi does not sell your non-public personal information to anyone. Nor do we provide such information to others
except for discrete and reasonable business purposes in connection with the servicing and management of our
relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisers (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural, and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect
Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 25
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
goi does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where goi or the
client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for
marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
goi does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
State-specific Regulations
California
In response to a California law, to be conservative, we assume accounts with California addresses do not want us to
disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit
the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
us at 888-464-4742, 888-goi-4ria or via email at rkhilnani@goi-ria.com.
Global Opportune Investments LLC
801 Brickell Avenue, 8th Floor, Miami, FL 33131
Phone: 888-464-4742
Page 26