IMZ ADVISORY INC.

Item 1 Cover Page IMZ Advisory Inc. 137 W. Royal Palm Road Boca Raton, FL 33432 www.imzfinancial.com November 16, 2025 This brochure provides information about the qualifications and business practices of IMZ Advisory Inc., CRD# 314890. If you have any questions about the contents of this brochure, please contact us at 561-368-2336. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration as a registered investment advisor does not imply a certain level of skill or training. Additional information about IMZ Advisory Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 Material Changes There have been no material changes to this brochure since the date of the last annual update noted below. The material changes discussed above are only those changes that have been made to this brochure since the firm’s last annual update of the brochure. The date of the last annual update of the brochure was February 21, 2025. IMZ Advisory Inc. Page ii  Item 3 Table of Contents Brochure Item 1 Cover Page ................................................................................................................................. i Item 2 Material Changes ...................................................................................................................... ii Item 3 Table of Contents ..................................................................................................................... iii Item 4 Advisory Business .................................................................................................................... 4 Item 5 Fees and Compensation ............................................................................................................ 7 Item 6 Performance-Based Fees and Side-by-Side Management ........................................................ 8 Item 7 Types of Clients ........................................................................................................................ 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 8 Item 9 Disciplinary Information ......................................................................................................... 10 Item 10 Other Financial Industry Activities and Affiliations ............................................................ 10 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....... 11 Item 12 Brokerage Practices .............................................................................................................. 12 Item 13 Review of Accounts .............................................................................................................. 16 Item 14 Client Referrals and Other Compensation ............................................................................ 17 Item 15 Custody ................................................................................................................................. 17 Item 16 Investment Discretion ........................................................................................................... 17 Item 17 Voting Client Securities ........................................................................................................ 17 Item 18 Financial Information ............................................................................................................ 18 IMZ Advisory Inc. Page iii  Item 4 Advisory Business IMZ Advisory Inc. is a registered investment advisor firm registered with the United States Securities and Exchange Commission (SEC) since August 2021. IMZ Advisory Inc. is a wholly-owned subsidiary of IMZ Financial Services, Inc. The principal owners of IMZ Financial Services, Inc. are Irwin Zagoria, President and CEO of IMZ Advisory Inc. and Cory Davis, Vice President of IMZ Advisory Inc. Advisory Services IMZ Advisory Inc. (“IMZ” or “Advisor”) principal service is providing fee-based investment advisory services. The Advisor practices custom management of portfolios, on a discretionary basis, according to the client’s objectives. The Advisor’s primary approach is to use a tactical allocation strategy aimed at reducing risk and increasing performance. The Advisor may use exchange listed securities, corporate debt securities, municipal securities, mutual funds, and interests in partnerships investing in real estate to accomplish this objective. The Advisor measures and selects mutual funds by using various criteria, such as the fund manager’s tenure, and/or overall career performance. The Advisor may recommend, on occasion, redistributing investment allocations to diversify the portfolio in an effort to reduce risk and increase performance. The Advisor may recommend specific stocks to increase sector weighting and/or dividend potential. The Advisor may recommend employing cash positions as a possible hedge against market movement which may adversely affect the portfolio. The Advisor may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position(s) in the portfolio, change in risk tolerance of client, or any risk deemed unacceptable for the client’s risk tolerance. Pension Consulting Services IMZ will offer pension consulting services to Qualified Plans and participant fiduciary advice to plan participants for assets held at Qualified Plans. The Advisor’s pension consulting services and participant fiduciary advice will be based on information obtained from the plan participant about goals and investment objectives, time horizon, risk tolerance and the plan participant's financial situation. IMZ will utilize the Investment Policy Statement when providing standardized asset allocation recommendations for the investment of assets within Qualified Plans. IMZ provides ERISA Section 3(38) fiduciary investment services where IMZ is responsible for the implementation of recommendations for the Qualified Plans. IMZ may offer other pension consulting services that include but are not limited to educational seminars, plan surveys, evaluations of vendor's services or special projects on behalf of the plan sponsor. Qualified Retirement Plan Consulting Services As part of the Advisory Agreement for Pension Planning, IMZ may provide services as follows for qualified retirement plans: IMZ Advisory Inc. Page 4  Fiduciary Services The Advisor will perform the following Fiduciary Services: (i) Provide discretionary investment advice to the Client about asset classes and investment alternatives available for the Plan in accordance with the Plan’s investment policies and objectives. (ii) Assist the Client with the selection of a broad range of investment options consistent with ERISA section 404(c) and the regulations thereunder. (iii) Assist the Client in the development of an investment policy statement (IPS). The IPS establishes the investment policies and objectives for the Plan. Client shall have the ultimate responsibility and authority to establish such policies and objectives and to adopt and amend the investment policy statement. (iv) Assist in monitoring investment options by preparing periodic investment reports that document investment performance, consistency of fund management and conformance to the guidelines set forth in the IPS and make recommendations to maintain or remove and replace investment options. (v) Meet with Client on a periodic basis to discuss the reports and the investment recommendations. (vi) Provide discretionary investment advice to the Plan Sponsor with respect to the selection of a qualified default investment alternative (“QDIA”) for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. The Client retains the sole responsibility to provide all notices to participants required under ERISA section 404(c)(5). (vii) Provide specific investment advice to participants concerning investing and portfolio construction who request it. Such investment advice will only be provided after Advisor has assessed the participant’s investor profile based on information obtained from the participant about goals and investment objectives, time horizon, risk tolerance and the plan participant's financial situation. Non-Fiduciary Services The Advisor will perform the following Non-Fiduciary services: (i) Assist in the education of the participants in the Plan about general investment principles and the investment alternatives available under the Plan. Client understands that Advisor’s assistance in participant investment education shall be consistent with and within the scope of section (d) of Department of Labor Interpretive Bulletin 96-1 (i.e., the definition of investment education). As such, the Advisor is not providing fiduciary advice (as defined in ERISA) to the participants. Advisor will not provide investment advice concerning the prudence of any investment option or combination of investment options for a particular participant or beneficiary under the Plan. IMZ Advisory Inc. Page 5  (ii) Assist in the group enrollment meetings designed to increase retirement plan participation among employees and investment and financial understanding by the employees. Advisor may provide these services or, alternatively, may arrange for the Plan’s other providers to offer these services, as agreed upon between Advisor and Client. The Advisor's roles and actions in fulfilling all responsibilities pertaining to the qualified plan consulting services shall not include those of the Plan's Trustee and will be performed solely at the direction of the Plan Sponsor, its authorized officers, employees and/or agents. At no time will the Advisor accept, maintain possession of, or have custodial responsibility for the Plan's assets. Communicational and educational activities in which the Advisor engages related to Participants in the Plan shall be solely at the direction of the Plan Sponsor, and shall not be represented by the Advisor or Plan Sponsor as investment, tax or legal advice. The Advisor is not licensed to provide, shall not provide, nor be construed to provide, the services of an attorney or accountant. Selection of Other Advisors IMZ may recommend and refer clients to unaffiliated money managers or investment advisors through Managed Account programs sponsored by a third-party provider. In these arrangements, the client will then enter into a program and investment advisory agreement with the program sponsor and sub-advisors. IMZ will assist and advise the client in establishing investment objectives for the sub-advisors and continue to provide oversight of the client account and ongoing monitoring of the activities of the sub-advisors. The sub-advisors will develop an investment strategy to meet those objectives by identifying appropriate investments and monitoring such investments. In consideration for such services, the program sponsor will charge a program fee that includes the investment advisory fee of the sub-advisors, the administration of the program and trading, clearance and settlement costs. The program sponsor will add IMZ's investment advisory fee (described below in Item 5) and will deduct the overall fee from the client account quarterly in advance based on the fair market value at the beginning of the quarter. The asset- based program fee is tiered and varies depending on the size of the account, the asset class of the underlying securities and the sub-advisor selected. IMZ will ensure that all third-party money managers recommended to clients will be either an investment advisor registered with the appropriate state securities regulators, the United States Securities and Exchange Commission (SEC), or exempt from such registrations. The client, prior to entering into an agreement with a third-party money manager selected by IMZ, will be provided with that manager’s Brochure. In addition, IMZ and its client will agree in writing that the client’s account will be managed by that selected third-party money manager on a discretionary basis. IMZ will tailor its advisory services to its client’s individual needs based on meetings and conversations with the client. If clients wish to impose certain restrictions on investing in certain securities or types of securities, the Advisor will address those restrictions with the client to have a clear understanding of the client’s requirements. IMZ does not provide portfolio management services to wrap fee programs. IMZ Advisory Inc. Page 6  As of December 31, 2024, IMZ had $322,817,000 in discretionary, and $58,880,000 in non- discretionary client assets under management. Item 5 Fees and Compensation Asset Management Fees Pursuant to an investment advisory contract signed by each client, including pension plans, the client will pay a tiered annual management fee, payable quarterly in advance, based on the value of portfolio assets of the account managed by the Advisor as of the opening of business on the first business day of each quarter. New account fees will be prorated from the inception of the account to the end of the first quarter. Assets Under Management Annual Fee First $250,000 $250,001 to $500,000 $500,001 to $1,000,000 $1,000,001 to $5,000,000 Over $5,000,000 1.50% 1.25% 1.00% 0.75% 0.60% These fees may be negotiated at the sole discretion of the Advisor. Asset management fees will be directly deducted from the client account on a quarterly basis by the qualified custodian. The client will give written authorization permitting the Advisor to be paid directly from their account held by the custodian. The custodian will send a statement at least quarterly and the Advisor will also send an invoice to the client outlining the fee calculation and time period covered, and the amount withdrawn from the client account at the same time the fee deduction invoice is sent to the qualified custodian. Where it is not practical to deduct fees directly from client accounts, client will be sent an invoice at the beginning of each quarter. The invoice is payable upon receipt. Fixed Fees Where IMZ is not managing a client’s portfolio, IMZ will charge a fixed fee for ongoing investment advice and quarterly meetings with the client of $50 per month paid quarterly in advance. Fixed fees may be negotiated in advance based at the discretion of the Advisor. The fixed fees will be directly deducted from client accounts on a quarterly basis by the qualified custodian. The client will give written authorization permitting the Advisor to be paid directly from their account held by the custodian. The custodian will send a statement at least quarterly. All fees paid to IMZ for investment advisory services are separate and distinct from the expenses charged by mutual funds to their shareholders. These fees and expenses are described in each fund’s prospectus. These fees will generally include a management fee and other fund expenses. At no time will IMZ accept or maintain custody of a client’s funds or securities except for authorized fee deduction. Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. The Advisor’s fee is separate and distinct from the custodian and execution fees. IMZ Advisory Inc. Page 7  IMZ’s management fee is payable in advance. Upon termination, any fees paid in advance will be prorated to the date of termination and any unearned fees will be refunded to client. Where acting in the capacity of insurance agents, investment advisory representatives of IMZ may effect insurance transactions for typical and customary compensation. Clients are not obligated to use investment advisor representatives of IMZ to execute such securities transactions. Where acting in the capacity of a registered representative or insurance agent, investment advisor representatives (IARs) of IMZ may as broker or agent effect securities or insurance transactions for typical and customary compensation. This practice presents a conflict of interest by creating an incentive to recommend investment products based on the compensation received, rather than on a client’s needs. Clients of IMZ are not required to utilize the IARs in their capacity as registered representatives of the broker-dealer or in their capacity as insurance agents for the purchase of investment products. IMZ has established a Code of Ethics to address conflicts of interest. See the response to Item 11 below for more information on the Code of Ethics. A client may be able to invest in products recommended by the firm directly, without the services of IMZ. In that case, the client would not receive the services provided by IMZ which are designed, among other things, to assist the client in determining which products or services are most appropriate to each client’s financial condition and objectives. Commissions from the sale of investment products do not represent 50% or more of the revenues received by IMZ. IMZ does not charge advisory fees on client assets invested through the broker-dealer or on insurance products. Item 6 Performance-Based Fees and Side-by-Side Management IMZ does not charge performance-based fees. Item 7 Types of Clients The Advisor will offer its services to individuals, pension and profit sharing plans, trusts, estates, charitable organizations, corporations and other business entities. The Advisor does not have any minimum requirements for opening or maintaining an account. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss The Advisor primarily uses fundamental analysis techniques in formulating investment advice or managing assets for clients. Fundamental analysis of businesses involves analyzing its financial statements and health, its management and competitive advantages and its competitors and markets. Fundamental analysis is performed on historical and present data but with the goal of making financial forecasts. There are several possible objectives; to conduct a company stock valuation and predict its probable price evolution; to make a projection on its business performance; to evaluate its management and make internal business decisions and to calculate its credit risk. IMZ Advisory Inc. Page 8  The Advisor’s investment strategy is based generally on long-term purchases of securities held at least for one year. However, IMZ may trade more frequently in times of unusual market conditions or external events that may impact the markets. Clients need to be aware that investing in securities involves risk of loss that clients need to be prepared to bear. The methods of analysis and investment strategies followed by the Advisor are utilized across all of the Advisors clients, as applicable. One method of analysis or investment strategy is not more significant than the other as the Advisor is considering the client’s portfolio, risk tolerance, time horizon and individual goals. However, the client should be aware that with any trading that occurs in the client account, the client will incur transaction and administrative costs. Investing includes the risk that the value of an investment can be negatively affected by factors specifically related to the investment (e.g., capability of management, competition, new inventions by other companies, lawsuits against the company, labor issues, patent expiration, etc.), or to factors related to investing and the markets in general (e.g., the economy, wars, civil unrest or terrorism around the world, concern about oil prices or unemployment, etc.). Risks of fundamental analysis may include risks that market actions, natural disasters, government actions, world political events or other events not directly related to the price or valuation of a specific company’s fundamental analysis can adversely impact the stock price of a company causing a portfolio containing that security to lose value. Risks may also include that the historical data and projections on which the fundamental analysis is performed may not continue to be relevant to the operations of a company going forward, or that management changes or the business direction of management of the company may not permit the company to continue to produce metrics that are consistent with the prior company data utilized in the fundamental analysis, which may negatively affect the Advisor’s estimate of the valuation of the company. All investments involve some degree of risk. In finance, risk refers to the degree of uncertainty and/or potential financial loss inherent in an investment decision. In general, as investment risks rise, investors seek higher returns to compensate themselves for taking such risks. Every saving and investment product have different risks and returns. Differences include how readily investors can get their money when they need it, how fast their money will grow, and how safe their money will be. The primary risks faced by investors include: Business Risk With a stock, you are purchasing a piece of ownership in a company. With a bond, you are loaning money to a company. Returns from both of these investments require that that the company stays in business. If a company goes bankrupt and its assets are liquidated, common stockholders are the last in line to share in the proceeds. If there are assets, the company’s bondholders will be paid first, then holders of preferred stock. If you are a common stockholder, you get whatever is left, which may be nothing. IMZ Advisory Inc. Page 9  The business risk in purchasing an annuity is that the financial strength of the insurance company issuing the annuity may decline and not be able to pay out the annuity obligation. Volatility Risk Even when companies aren’t in danger of failing, their stock price may fluctuate up or down. Large company stocks as a group, for example, have lost money on average about one out of every three years. A stock’s price can be affected by factors inside the company, such as a faulty product, or by events the company has no control over, such as political or market events. Inflation Risk Inflation is a general upward movement of prices. Inflation reduces purchasing power, which is a risk for investors receiving a fixed rate of interest. The principal concern for individuals investing in cash equivalents is that inflation will erode returns. Interest Rate Risk Interest rate changes can affect a bond’s value. If bonds are held to maturity the investor will receive the face value, plus interest. If sold before maturity, the bond may be worth more or less than the face value. Rising interest rates will make newly issued bonds more appealing to investors because the newer bonds will have a higher rate of interest than older ones. To sell an older bond with a lower interest rate, you might have to sell it at a discount. Liquidity Risk This refers to the risk that investors won’t find a market for their securities, potentially preventing them from buying or selling when they want. This can be the case with the more complicated investment products. It may also be the case with products that charge a penalty for early withdrawal or liquidation such as a certificate of deposit (CD). The Advisor does not primarily recommend a particular type of security. However, clients are advised that many unexpected broad environmental factors can negatively impact the value of portfolio securities causing the loss of some or all of the investment, including changes in interest rates, political events, natural disasters, and acts of war or terrorism. Further, factors relevant to specific securities may have negative effects on their value, such as competition or government regulation. Also, the factors for which the company was selected for inclusion in a client portfolio may change, for example, due to changes in management, new product introductions, or lawsuits. Item 9 Disciplinary Information Neither IMZ nor its management persons have had any legal or disciplinary events, currently or in the past. Item 10 Other Financial Industry Activities and Affiliations Cory Davis, Vice President is a Registered Representative with Arete Wealth Management, LLC, CRD# 44856, a FINRA registered broker-dealer. IMZ Advisory Inc. Page 10  Neither IMZ nor any of its management persons are registered or have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. IMZ does not currently have any relationships or arrangements that are material to its advisory business or clients with either a municipal securities dealer, a government securities dealer or broker, investment company or other pooled investment vehicle (including a mutual fund, closed- end investment company, unit investment trust, private investment company or “hedge fund” or offshore fund), other investment advisor or financial planner, futures commission merchant, commodity pool operator, or commodity trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, pension consultant, real estate broker or dealer or sponsor of syndicator of limited partnerships. Investment advisor representatives of IMZ are also licensed and registered as insurance agents to sell life, accident and other lines of insurance for various insurance companies. Therefore, they can purchase insurance products for any client in need of such services and will receive separate, yet typical compensation in the form of commissions for the purchase of those insurance products. This creates a conflict of interest because of the receipt of additional compensation by the investment advisor representatives. Clients are not obligated to use IMZ or its investment advisor representative for insurance products. However, in such instances, there is no advisory fee associated with these products, and clients will be made aware of all commissions associated with the products prior to the transactions. The insurance agent activities are conducted through IMZ Financial Services, Inc., the parent company of IMZ Advisory Inc. Cory Davis, Vice President, is also the Manager of an unaffiliated private fund, Founders Capital Partners LLC. If appropriate, IMZ clients may be eligible to invest in the private fund if they meet the requirements for investment and such investment would be suitable to their investor profile. IMZ clients are not obligated to invest in the private fund. If a client chooses to invest in the private fund, IMZ will not charge its advisory fee on the assets invested in the private fund. IMZ does recommend or select other investment advisors for clients. For more specific information, see the response to 4 above. Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading IMZ maintains a Code of Ethics pursuant to SEC rule 204A-1. IMZ’s Code of Ethics sets forth the basic policies of ethical conduct for all managers, officers, and employees of the adviser. In addition, the Code of Ethics governs personal trading by each employee of IMZ deemed to be an Access Person and is intended to ensure that securities transactions effected by Access Persons of IMZ are conducted in a manner that avoids any conflict of interest between such persons and clients of the adviser or its affiliates. IMZ collects and maintains records of securities holdings and securities transactions effected by Access Persons. These records are reviewed to identify and resolve conflicts of interest. IMZ will provide a copy of the Code of Ethics to any client or prospective client upon request. IMZ Advisory Inc. Page 11  Where acting in the capacity of a registered representative, investment advisor representatives of IMZ may as broker or agent effect securities transactions for typical and customary compensation. This creates a conflict of interest. Clients are not obligated to use investment advisor representatives of IMZ to execute such securities transactions. If client elects to use the investment advisor representatives of IMZ in this capacity, fees associated with these types of transactions will be disclosed to the client in advance. IMZ and/or its investment advisor representatives may from time to time purchase or sell products that they may recommend to clients. This practice creates conflicts of interest in that personnel of IMZ can take advantage of the advance knowledge of firm securities trading and trade their personal accounts ahead of the client trades or recommend trades in client accounts that may affect the price of the securities owned by the Investment Advisor Representatives. To mitigate these conflicts, the Code of Ethics governs personal trading by each employee of IMZ deemed to be an Access Person and is intended to ensure that securities transactions effected by Access Persons of IMZ are conducted in a manner that avoids any actual or potential conflict of interest between such persons and clients of the adviser or its affiliates. Finally, supervised persons of registered investment advisors are fiduciaries by law and are required to put the client’s interest before those of the firm and themselves. IMZ requires that its investment advisor representatives follow its basic policies and ethical standards as set forth in its Code of Ethics. Investment Advisor Representatives of IMZ may trade for their own accounts securities that are being traded for client accounts at or about the same time. To mitigate the conflict of interest in such circumstances, IMZ’s policy is to require the trading of all relevant client account prior to the trading of their own accounts. The Chief Compliance Officer examines personal trading activities of IMZ’s personnel to verify compliance with this policy. Item 12 Brokerage Practices If requested by the client, IMZ may suggest brokers or dealers to be used based on execution and custodial services offered, cost, quality of service and industry reputation. IMZ will consider factors such as commission price, speed and quality of execution, client management tools, and convenience of access for both the Advisor and client in making its suggestion. The custodian and brokers we use IMZ does not maintain custody of your assets, although we are deemed to have custody of your assets if you give us authority to withdraw assets from your account (see Item 15 – Custody, below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. Not all advisors require IMZ Advisory Inc. Page 12  their clients to use a particular broker-dealer or other custodian selected by the advisor. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account as described below (see “Your brokerage and custody costs”). How we select brokers/custodians We seek to recommend a custodian/broker that will hold your assets and execute transactions on terms that are overall most advantageous when compared with other available providers and their services. We consider a wide range of factors, including: • Combination of transaction execution services and asset custody services (generally without a separate fee for custody) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange- traded funds (ETFs), etc.) • Availability of investment research and tools that assist us in making investment decisions • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security and stability • Prior service to us and our clients • Availability of other products and services that benefit us, as discussed below (see “Products and services available to us from Schwab”) Your brokerage and custody costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. For some accounts, Schwab may charge you a percentage of the dollar amount of assets in the account in lieu of commissions. Schwab’s commission rates and asset-based fees applicable to our client accounts were negotiated based on the condition that our clients collectively maintain a total of at least $100 million of their assets in accounts at Schwab. This commitment benefits you because the overall commission rates and asset-based fees you pay are lower than they would be otherwise. In addition to commissions and asset-based fees, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker/dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How we select brokers/custodians”). IMZ Advisory Inc. Page 13  Products and services available to us from Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide our clients and us with access to their institutional brokerage services (trading, custody, reporting and related services), many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services That Benefit You. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that may not directly benefit you. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and account statements) facilitate trade execution and allocate aggregated trade orders for multiple client accounts facilitate payment of our fees from our clients’ accounts • • provide pricing and other market data • • assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: • Educational conferences and events • Consulting on technology, compliance, legal, and business needs • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Schwab may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. IMZ Advisory Inc. Page 14  Our interest in Schwab’s services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. This creates an incentive to recommend that you maintain your account with Schwab, based on our interest in receiving Schwab’s services that benefit our business and Schwab’s payment for services for which we would otherwise have to pay rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How we select brokers/custodians”) and not Schwab’s services that benefit only us. For any such products and services IMZ receives from Schwab or other custodians, it will follow procedures which ensure compliance with Section 28(e) of the Securities Exchange Act of 1934 or applicable state securities rules. The firm seeks to obtain the most favorable net results for clients’ price, execution quality, services and commissions. Although the firm seeks competitive commission rates, it may pay commissions on behalf of clients which may be higher than those available from other brokers in order to receive other services. The firm may enter into such transactions so long as it determines in good faith that the amount of commission paid was reasonable in relation to the value of the brokerage and research services provided by the broker. The services that may be considered in this determination of reasonableness may include (1) advice, either directly or through publications or writing, as to the value of securities, the advisability of investing in, purchasing or selling securities, and the availability of securities or purchasers or sellers of securities; (2) analysis and reports concerning issuers, industries, securities, economic factors and trends, portfolio strategy, and the performance of accounts; or (3) effecting securities transactions and performing functions incidental thereto. Such research furnished by broker-dealers may be used to service any or all of IMZ’s clients and may be used in connection with accounts other than those that pay commissions to the broker-dealers providing the research. In particular, third-party research provided by broker- dealers may be used to benefit all of the firm’s clients. This creates a conflict of interest in that the firm has an incentive to select or recommend a broker-dealer based on its interest in receiving the research or other products or services, rather than on the clients’ interest in receiving most favorable execution. Trading commissions may be used as soft dollars provided that: • The service is primarily for the benefit of IMZ’s clients • The commission rates are competitive with rates charged by comparable broker-dealers; • and IMZ does not guarantee a minimum amount of commissions to any broker-dealer. IMZ does not receive client referrals from any broker-dealer or third party as a result of the firm selecting or recommending that broker-dealer to clients. IMZ Advisory Inc. Page 15  As an investment advisory firm, IMZ has a fiduciary duty to seek best execution for client transactions. While best execution is difficult to define and challenging to measure, there is some consensus that it does not solely mean the achievement of the best price on a given transaction. Rather, it appears to be a collective consideration of factors concerning the trade in question. Such factors include the security being traded, the price of the trade, the speed of the execution, apparent conditions in the market, and the specific needs of the client. IMZ’s primary objectives when 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 order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the broker. IMZ may not necessarily pay the lowest commission or commission equivalent as specific transactions may involve specialized services on the part of the broker. IMZ does not permit clients to direct brokerage. IMZ may combine orders into block trades when more than one account is participating in the trade assuming there are multiple client accounts at the same custodian participating in the security that is being bought or sold. This blocking or bunching technique must be equitable and potentially advantageous for each such account (e.g., for the purposes of reducing brokerage commissions or obtaining a more favorable execution price). Block trading is performed when it is consistent with the duty to seek best execution and is consistent with the terms of IMZ’s investment advisory agreements. Equity trades are blocked based upon fairness to client, both in the participation of their account, and in the allocation of orders for the accounts of more than one client. Allocations of all orders are performed in a timely and efficient manner. All managed accounts participating in a block execution receive the same execution price (average share price) for the securities purchased or sold in a trading day. Any portion of an order that remains unfilled at the end of a given day will be rewritten on the following day as a new order with a new daily average price to be determined at the end of the following day. Due to the low liquidity of certain securities, broker availability may be limited. Open orders are worked until they are completely filled, which may span the course of several days. If an order is filled in its entirety, securities purchased in the aggregated transaction will be allocated among the accounts participating in the trade in accordance with the allocation statement. If an order is partially filled, the securities will be allocated pro rata based on the allocation statement. IMZ may allocate trades in a different manner than indicated on the allocation statement (non-pro rata) only if all managed accounts receive fair and equitable treatment. Item 13 Review of Accounts Investment advisory client accounts are monitored on an ongoing basis, with quarterly analysis of holdings and rebalancing of the accounts if necessary. Meetings with clients are held at least annually, or more frequently if requested by the client. Client accounts are reviewed by Irwin Zagoria, President and CEO, and Cory Davis, Vice President. The nature of the review is to determine if the client account is still in line with the client’s stated objectives. The client is encouraged to notify the Advisor and Investment Advisor Representative if changes occur in his/her personal financial situation that might materially affect his/her investment plan. IMZ Advisory Inc. Page 16  The client will receive written statements no less than quarterly from the custodian. In addition, the client will receive other supporting reports from mutual funds, asset managers, trust companies or other custodians, broker-dealers and others who are involved with client accounts. IMZ does not provide separate client reports. Item 14 Client Referrals and Other Compensation IMZ has an arrangement with Arete Wealth Management, LLC (“Arete”), a FINRA registered broker-dealer, where IMZ can refer to Arete any of its clients that would like access to the securities brokerage services offered by Arete. IMZ is compensated by Arete for such referrals with a one-time payment. This creates a conflict of interest because of the receipt of additional compensation by IMZ. Clients are not obligated to use Arete for securities brokerage services. The payment to IMZ does not increase fees the client will pay to Arete for its services. IMZ does not directly or indirectly compensate any person who is not a supervised person for client referrals. Item 15 Custody IMZ does not have custody of client funds or securities, except for the withdrawal of advisory fees directly from client accounts (please see Item 5 which describes the safeguards around direct fee deduction). However, as noted in Item 13 above, clients will receive statements not less than quarterly from the qualified custodian, and we encourage you to review those statements carefully. Any discrepancies should be immediately brought to the firm’s attention. Item 16 Investment Discretion IMZ 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 for each transaction. 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 IMZ. Discretionary authority will only be provided 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 IMZ will be in accordance with each client’s investment objectives and goals. Item 17 Voting Client Securities IMZ will not vote, nor advise clients how to vote, proxies for securities held in client accounts. The client clearly keeps the authority and responsibility for the voting of these proxies. Also, IMZ cannot give any advice or take any action with respect to the voting of these proxies. The client and IMZ agree to this by contract. Clients will receive proxy solicitations from their custodian and/or transfer agent. IMZ Advisory Inc. Page 17  Item 18 Financial Information IMZ does not require or solicit prepayment of more than $500 in fees per client, six months or more in advance, and is not required to file a balance sheet. IMZ has discretionary authority over client accounts and is not aware of any financial condition that will likely impair its ability to meet contractual commitments to clients. If IMZ does become aware of any such financial condition, this brochure will be updated and clients will be notified. IMZ has never been subject to a bankruptcy petition. IMZ Advisory Inc. Page 18