L 1 GLOBAL WEALTH LLC

Form ADV Part 2A Brochure December 11, 2025 This Brochure provides information about the qualifications and business practices of L 1 Global Wealth LLC. If you have any questions about the contents of this Brochure, please contact us at 305-848-3411 or ignacio.martinez@l1gw.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. L 1 Global Wealth LLC is a registered investment adviser. Registration as an Investment Adviser with the United States Securities and Exchange Commission or any state securities authority does not imply any level of skill or training. Additional information about L 1 Global Wealth LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  Item 2 – Material Changes This Brochure is L 1 Global Wealth LLC’s 120 Day Updating Amendment to its Form ADV Part 2A. L 1 Global Wealth LLC’s initial Form ADV Part 2A was submitted with our application for registration in July 2025. Since then, there have been no material changes to report. In the future, if the Brochure contains material changes from our last update, we will identify and discuss those changes in this section. If you would like to request a copy of the Brochure, without charge, please contact us at 305-848-3411 or ignacio.martinez@l1gw.com Additional information about L 1 Global Wealth LLC also is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  Item 3 – Table of Contents Item 2 – Material Changes ............................................................................................................................................................................................. 3 Item 3 – Table of Contents ............................................................................................................................................................................................ 4 Item 4 – Advisory Business ............................................................................................................................................................................................ 5 Item 5 – Fees and Compensation .................................................................................................................................................................................. 5 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................................................................................... 6 Item 7 – Types of Clients ............................................................................................................................................................................................... 6 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................................................................................... 6 Item 9 – Disciplinary Information .................................................................................................................................................................................. 6 Item 10 – Other Financial Industry Activities and Affiliations ....................................................................................................................................... 6 Item 11 – Code of Ethics, Participation or Interest in Client Transactions & Personal Trading ..................................................................................... 6 Item 12 – Brokerage Practices ....................................................................................................................................................................................... 7 Item 13 – Review of Accounts ....................................................................................................................................................................................... 8 Item 14 – Client Referrals and Other Compensation ..................................................................................................................................................... 9 Item 15 – Custody ......................................................................................................................................................................................................... 9 Item 16 – Investment Discretion ................................................................................................................................................................................. 10 Item 17 – Voting Client Securities ................................................................................................................................................................................ 10 Item 18 – Financial Information .................................................................................................................................................................................. 10 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  Item 4 – Advisory Business OVERVIEW OF ADVISORY BUSINESS L 1 Global Wealth, LLC, a Delaware limited liability company (“L 1” or “we” or the “Firm”) was formed in 2025 and is applying for registration as an investment adviser with the United States Securities and Exchange Commission (“SEC”) under the Investment Advisers Act of 1940, as amended. The Firm is principally owned by L1 JM LLC (Jesus Fomperosa), L1 DM LLC (Diego Mas), and L1 IM LLC (Ignacio Martinez). Further information on the Firm’s owners, including their biographies, is contained in L 1 ’s Form ADV Part 2B Brochure Supplement. The Firm provides comprehensive family wealth management services to our broad client base (each a “Client” and together “Client Accounts” or “Clients”). Our ongoing service offering includes customized investment portfolios, investment management, and financial planning on both a discretionary and non-discretionary basis. Each client establishes a custodial relationship with an independent bank or brokerage Firm and L 1 will manage the Assets and liabilities custodied in different institution. As of December 8, 2025, L 1 has $300,742,594 assets under management on a discretionary basis and $2,810,167,033 assets under management on a non-discretionary basis. INVESTMENT MANAGEMENT The Firm’s broader team of advisors and investment professionals meet on a recurring basis to create customized investment strategies that aim to maximize wealth preservation while taking advantage of wealth creation opportunities. We also use our investment philosophy and internal research team to support our investment decisions. We primarily invest in exchange traded individual equity securities, fixed income securities, exchange traded funds and mutual funds. On a limited basis, we may recommend that our clients invest in alternative assets including private equity funds, real estate funds and other alternative funds. As a fiduciary, L 1 acts in the Clients’ best interest. In order to understand our clients’ goals and objectives, we have an initial assessment meeting as well as ongoing communication with the clients. At the onset of a client relationship, we set an asset allocation based on the clients’ objectives. Clients may impose restrictions on investing in certain securities or types of securities or limits on their weightings. Item 5 – Fees and Compensation We charge an investment management fee that starts at 0.20% - 1.00% of a client’s assets under management. The investment management fee is negotiable depending on certain client-specific factors including, but not limited to, the size of the account, the aggregate value of related accounts, the nature of the relationship, the complexity of the services provided and other factors. Additionally, the Firm waives the investment management fees for employees and immediate family members. Each client executes an investment advice contract with L 1 Global Wealth LLC which establishes the investment management fee. We bill clients in advance of each calendar quarter and typically directly debit the fee from the clients’ bank or brokerage custodial accounts. Accounts initiated or terminated during a calendar quarter will generally be charged a prorated fee based on the number of days the client account was open during that quarter. Upon termination of any account, any prepaid or unearned fees will be refunded. Fees are calculated based on the value of the client’s assets under management as valued on the close of business on the last business day of the previous quarter. OTHER FEES AND EXPENSES L 1's fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third-party investment managers and other third-parties. These charges include, but are not limited to, management and performance fees charged by third-party managers, ticket charges, brokerage commissions, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds, money market funds, exchange traded funds and private funds also charge internal management fees, which are disclosed in a fund’s prospectus or offering documents. These charges, fees and commissions are exclusive of and in addition to L 1’s management fee. Neither L 1 s nor its supervised persons accept compensation for the sale of securities or other investment products. Item 12 further describes the factors that L 1 considers in selecting or recommending broker-dealers for client transactions. 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  Item 15 further discusses L 1 ’s use of a pricing hierarchy to value certain securities and the impact it has on investment management fees. Item 6 – Performance-Based Fees and Side-By-Side Management L 1 does not charge any performance-based fees. Item 7 – Types of Clients L 1 provides financial counseling, investment management, and customized investment portfolios to ultra-high net worth individuals and families, trusts, and partnerships. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss METHOD OF ANALYSIS L 1 will manage individualized portfolios for Clients based upon their personal objectives, goals and risk tolerances in accordance with each Client’s investment management agreement. L 1 advises on equity, fixed income, alternatives, and balanced portfolios and we conduct our own research and analysis to support our investment decisions. Additionally, the Firm uses portfolio optimizer tools to project return objectives in accordance with the least amount of risk. When evaluating investment opportunities, we talk directly with companies, competitors, suppliers and industry contacts and use various resources such as corporate data, third party research, SEC filings, company press releases, management conference calls and meetings and proprietary research. We generally look for businesses that are both understandable and predictable and that have high returns on capital, sustainable competitive advantages, strong balance sheets and reliable management teams. INVESTMENT PHILOSOPHY AND STRATEGY The Firm generally employs a long-term investment horizon, with investment theses designed to play out over years rather than months. Assets are selected in accordance with each client’s risk profile and investment objectives, including time horizon. The Firm is mindful of tax implications and generally manages holding periods to minimize individual tax burdens where appropriate. Investment decisions also take into account fiscal responsibility and the expected long-term benefits to the client’s overall financial position. RISK OF LOSS The following are certain of the material risks involved in our investment strategy. This list does not purport to be a complete enumeration or explanation of the risks involved in such strategy. Trading Risk An investment in a Client Account managed by L 1 is speculative and involves a high degree of risk. L 1 may employ certain trading techniques, such as short selling, options trading and the use of leverage, that may increase the risk of investment loss. Because the Client Account s invest primarily in public equities, L 1 believes their primary risk of loss is associated with portfolio construction, security selection and broad market movements. Wide and sudden fluctuations in market value can occur. Prospective investors are strongly urged to consult with their own financial, legal and tax advisors, before investing. Short Sales We may recommend or engage in short selling of securities, currencies, or indices, including all forms of derivatives. Short selling involves the sale of a security that the investor doesn’t own and must borrow in order to make deliver in the hope of purchasing the same security at a later date at a lower price. A short sale will result in a gain if the price of the instrument sold declines sufficiently between the time of the short sales and the time which another is purchased to replace it. A short sale will result in a loss if the price of the instrument sold short increases or does not decline sufficiently to cover transaction costs. Selling securities short risks losing an amount greater than the proceeds received due to the lack of an upper limit on the price in which an investment can rise. In addition, the supply of securities that can be borrowed fluctuates from time to time. An investor may have losses if a security lender demands return of lent securities and an alternative lending source can’t be found. Options 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  L 1 could invest portions of Client assets into options, including purchasing or writing put and call options. Like equity securities, options carry no guarantees of profit and are subject to a wide variety of market and risk factors. Investments in options involve risks different from, or possibly greater than, the risks associated with investing directly in securities and other traditional investments. These risks include risk: (i) that the counterparty to a transaction may not fulfil its contractual obligations; (ii) of mispricing or improper valuation; and (iii) that changes in the value of the option may not correlate perfectly with the underlying asset, rate or index. Be aware it is possible to lose the entire principal invested, and sometimes more. As an options holder, you risk the entire amount of the premium you pay. Option prices are highly volatile and may fluctuate substantially during a short period of time. Such prices are influenced by numerous factors that affect the markets, including, but not limited to: government programs and policies; national and international political and economic events, changes in interest rates, inflation and deflation and changes in supply and demand relationships. It is possible that certain options might be difficult to purchase or sell, possibly preventing from executing positions at an advantageous time or price, or possibly requiring disposal of other investments at unfavorable times or prices in order to satisfy a portfolio’s other obligations. Leverage We may leverage investment positions by borrowing funds from securities broker dealers, banks or others. While leverage presents opportunities for increasing the total return on an investment, it has the effect of potentially increasing losses as well. Accordingly, any event that adversely affects the value of an investment by a Client would likely be magnified to the extent that any of them are leveraged. Equity Securities Common stocks and other equity securities generally increase or decrease in value based on the earnings of a company and on general industry and market conditions. The value of a company’s share price could decline as a result of poor decisions made by management, lower demand for the company’s services or products or if the company’s revenues fall short of expectations. There are also risks associated with the stock market overall; in particular, the stock market may experience periods of turbulence and instability. Counterparty Risk The Client Accounts will deposit all or substantially all of their assets with its brokers and may choose not to use a bank custodian to hold their assets. Rule 15c3-3 under the Securities Exchange Act of 1934, as amended (the “Exchange Act”) requires a broker-dealer to segregate a customer’s cash and fully paid-for securities from the broker-dealer’s own assets. If the broker-dealer fails to do so, the Client Accounts may be subject to risk of loss of the assets held by the broker-dealer in the event of the broker-dealer’s bankruptcy. In the event of a failure of a broker- dealer used by the Client, the U.S. Securities Investor Protection Corporation provides a maximum of $500,000 of account insurance per entity, subject to a limit of $250,000 for cash. If the Client Account’s assets on deposit exceed these amounts, the Client Accounts may receive only a pro rata share of the remaining assets deposited with the failed broker-dealer. Alternative Investment Manager Risks L 1 could recommend that Client assets be invested with alternative investment managers, including Independent Managers, who make their trading decisions independently. It is possible that one or more investment managers may take investment positions that are opposite of positions taken by other investment managers. Some investment managers may have overlapping strategies or portfolios and thus could accumulate large positions in the same or related instruments at the same time. L 1 may not have access to information regarding the underlying investments made by the investment managers or investment funds and thus may not be able to mitigate the associated risks of concentration or exposure to specific markets or strategies. Because each investment manager will trade independently of the others, the trading losses of some investment managers could offset trading profits achieved by other investment managers. In addition, investment managers may compete for similar positions at the same time. Activities of Alternative Investment Managers and Alternative Investment Funds L 1 will have no control over the day-to-day operations of any unaffiliated alternative investment fund or investment manager. As a result, there can be no assurance that every alternative investment fund or investment manager will invest on the basis expected by L 1. Furthermore, because L 1 will have no control over any investment fund’s or investment manager’s day-to-day operations, Clients may experience losses due to the fraud. 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  Limited Operating History L 1 has a limited operating history for prospective Clients to evaluate prior to selecting us as an investment adviser. Operational Risk Operational risk is the potential for loss caused by a deficiency in information, communication, transaction processing and settlement and accounting systems. We maintain controls that include systems and procedures to record and reconcile transactions and positions, and to obtain necessary documentation for trading activities. Long Term Investments L 1 ’s strategy will frequently require longer-term holding periods for its positions and Private Investments in order to be successful and such investments may experience considerable price volatility over such holding periods. In addition, such investments are generally illiquid. Valuation L 1 may invest in securities or Private Investments which are illiquid or very thinly traded. These investments may be extremely difficult to ascribe a market value, at specific points of time. Third party pricing information may not be available for certain positions held by Clients. Leverage Certain Private Investments may include companies whose capital structures have significant leverage. Due to such leverage, such companies may be more sensitive to adverse business or financial developments or economic factors. In an environment of rising interest rates a leveraged company may have increased interest obligations associated with its indebtedness. As such, the company’s cash flow could be severely impaired resulting in the value of the portfolio company being significantly reduced or eliminated. Portfolio Company Management Risks The management team of a Private Investment company may have a limited number of key individuals, the loss of any one of whom could significantly adversely affect the portfolio company’s performance. Reliance on Corporate Management and Financial Reporting The Private Investment that may be recommended by L 1 will rely on the financial information made available by each portfolio company. L 1 may be limited in its ability to independently verify the financial information disseminated by any such portfolio company and is, therefore, dependent upon the integrity of both the management of such company and its financial reporting process in general. Economic Conditions Changes in economic conditions, including, for example, interest rates, inflation rates, currency and exchange rates, industry conditions, competition, technological developments, trade relationships, supply-chain disruptions, economic sanctions, political and diplomatic events and trends, tax laws and innumerable other factors, can affect substantially and adversely the investment performance of the Funds. Economic, political and financial conditions, or industry or economic trends and developments, may, from time to time, and for varying periods of time, cause volatility, illiquidity or other potentially adverse effects in the financial markets. Economic or political turmoil, a deterioration of diplomatic relations or a natural or man- made disaster in a region or country where Client assets are invested may result in adverse consequences to such Clients. Over the last couple of years, there is an especially high degree of economic uncertainty given elevated inflation, a rapid increase in interest rates by central banks, and a high level of geopolitical uncertainty in Europe and Asia. The likelihood of a recession, and the magnitude of any such recession, is highly uncertain and would have significant implications across asset classes. None of these conditions is or will be within the control of L 1, and no assurances can be given that L 1 will anticipate these developments. Exposure to Material, Non-Public Information From time to time, L 1 employees receive material, non-public information with respect to an issuer of publicly traded securities resulting from professional and/or personal channels. In such circumstances, Clients may be prohibited, by law, and policies and procedures for a period of 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  time from (i) unwinding a position in such issuer, (ii) establishing an initial position or taking any greater position in such issuer, and (iii) pursuing other investment opportunities related to such issuer. Custody Risk L 1 is required to maintain Client funds and securities over which the Firm is deemed to have custody with a qualified custodian. Clients may incur a loss on securities and cash held in custody in the event of a custodian’s or sub-custodian’s insolvency, negligence, fraud, poor administration or inadequate recordkeeping. Generally, deposits maintained at a bank do not become part of a failed bank’s estate; however, L 1 ’s operations could be impacted by the bank’s insolvency in that there may be a delay in access to liquidity, trade settlement, delivery of securities, etc. Establishing multiple custodial relationships could mitigate custodial risk in the event of a bank failure. Epidemics and Pandemic Outbreak Pandemics or epidemics and reactions to such an outbreak could cause uncertainty in markets and businesses, including L 1 ’s business, and may adversely affect the performance of the global economy as a whole, as well as specific industries or asset classes, including causing market volatility, market and business uncertainty and closures, supply chain and travel interruptions, the need for employees and vendors to work at external locations, and extensive medical absences. L 1 has policies and procedures to address known situations, but because a large outbreak may create significant market and business uncertainties and disruptions, not all events that could affect L 1 ’s business, portfolio investments, their respective service providers and/or the markets can be determined and addressed in advance. Business Continuity Risk L 1 ’s business operations may be vulnerable to disruption in the case of catastrophic events such as fires, natural disaster, terrorist attacks or other circumstances resulting in property damage, network interruption and/or prolong power outages. Although L 1 has implemented, or expects to implement, measures to manage risks relating to these types of events, there can be no assurances that all contingencies can be planned for. These risks of loss can be substantial and could have a material adverse effect on L 1 and its ability to manage clients. Cybersecurity Breaches and Identity Theft L 1 and the Clients’ information and technology systems are subject to a number of different threats or risks that could adversely affect the Clients and its investors. Although L 1 has implemented various measures to mitigate these risks and protect the security of its computer systems, software, networks and other technology assets, as well as the confidentiality, integrity and availability of information belonging to the Clients and its investors, if these systems are compromised, become inoperable for extended periods of time or cease to function properly, L 1 and/or the Clients could be materially adversely affected. For example, these systems are subject to damage or interruption from computer viruses, network failures, computer and telecommunication failures, security threats (including ongoing cyber security threats to and attacks on information technology infrastructure), infiltration by unauthorized persons and other security breaches, usage errors by their respective professionals. The service providers of the Clients are subject to the same information security threats. If a service provider fails to adopt or adhere to adequate data security policies, or if the service provider’s network is breached, information relating to the transactions of the Clients and personally identifiable information of the investors (and beneficial owners thereof) may be lost or improperly accessed, used, or disclosed. Artificial Intelligence and Machine Learning Risk The emergence of recent technology developments in artificial intelligence and machine learning such as OpenAI and ChatGPT (collectively, “Machine Learning Technology”) can pose risks to the Firm, Client Accounts, and their investments. The Firm is exposed to the risks of Machine Learning/AI Technology from both such limited, known uses, as well as from any uses of AI Technology that may be undertaken by third-party service providers or advisers of or any counterparties to Client Accounts or their underlying investments, whether or not known to L 1. Use of Machine Learning Technology involves the risk of inaccuracies or errors in the data utilized by AI, may directly or indirectly create security or data risks, and may increase trademark, licensing and copyright risks. AI Machine Learning Technology continues to develop rapidly and it is impossible to predict the future risks that may arise from such developments. Regulatory/Legislative Developments Risk Regulators and/or legislators may promulgate rules or pass legislation that places restrictions on, adds procedural hurdles to, affects the liquidity of, and/or alters the risks associated with certain investment transactions or the securities underlying such investment transactions. 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  Such rules/legislation could adversely affect the value associated with such investment transactions or underlying securities. Future legal, tax and regulatory changes could occur that may adversely affect business and require additional reporting for registered investment advisors. The SEC, other regulators and self-regulatory organizations and exchanges have taken various extraordinary actions in connection with market events and may take additional actions. Registered investment advisors may also be adversely affected by changes in the enforcement or interpretation of existing laws, rules and regulations, including tax laws, by federal, state and non-U.S. agencies, courts, authorities or regulators. The foregoing list of risk factors does not purport to be a complete enumeration or explanation of the risks involved with L 1 ’s investment program or an investment in any Client. The underlying investments or activities of alternative investment managers and alternative investment funds in which L 1 invests may be subject to unique risks and considerations not discussed herein. For specific information regarding the risks of investing in a particular Client and the types of securities issued by that Client, investors should refer to that Client’s Governing Documents and subscription documents. Prospective investors must consult their own advisers before deciding whether to make such an investment, and should carefully review the organizational and subscription documents of the applicable Client, together with all information provided by or on behalf of L 1 with respect to the associated investments, before deciding whether to invest. Such documents are available only to current investors or prospective investors who are eligible to invest in such entities, as determined in the sole discretion of L 1. Item 9 – Disciplinary Information Neither L 1, nor any of its personnel has been the subject of any material legal or disciplinary events. Item 10 – Other Financial Industry Activities and Affiliations Neither L 1, nor any of its personnel has any other material affiliation to other financial industry activities. Item 11 – Code of Ethics, Participation or Interest in Client Transactions & Personal Trading L 1 has adopted a Code of Ethics for all supervised persons, describing our standard policies and procedures governing their business conduct and fiduciary duty to our clients. The Code of Ethics includes provisions relating to the confidentiality of client information, prohibition on insider trading, prohibition against spreading rumors, restrictions on accepting significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other standards of business conduct. All supervised persons at L 1 must acknowledge the terms of the Code of Ethics at the beginning of employment, annually or as amended. Subject to satisfying the Code of Ethics and applicable laws, employees of L 1 or affiliated accounts can trade for their own accounts in securities which are purchased or recommended for L 1 ’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of L 1 will not interfere with (i) making decisions in the best interest of clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would not interfere materially with the best interest of L 1 ’s clients. Because the Code of Ethics permits employees to invest in the same securities as clients, there is a potential conflict that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics to reasonably prevent and mitigate conflicts of interest between L 1 and its clients. L 1 ’s clients or prospective clients may request a copy of the Firm's Code of Ethics by contacting us at 305-848-3411 or ignacio.martinez@l1gw.com. Item 12 – Brokerage Practices L 1 has the authority and discretion to choose the executing broker-dealer for client transactions. We consider several factors in selecting the broker-dealer, including but not limited to, the nature of the security being traded, the size of the transaction, the transaction costs, particular expertise in the type of security or market, responsiveness and promptness in providing execution, ability to maintain anonymity, opportunity for price improvement and access to relevant markets. Brokerage commissions are negotiated by us with each broker-dealer. Depending on various factors, such as the value of research or execution quality, we will pay higher fees than if our only consideration was to obtain the lowest possible transaction commission. 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  The Firm receives eligible research, brokerage and other products or services (“soft dollar benefits”) other than execution from broker-dealers in connection with transactions on behalf of clients. In selecting a broker-dealer, we take into consideration such soft dollar benefits. The types of research, brokerage and/or other products or services we acquired in the previous year included: proprietary or third-party investment-related research, limited circulation publications focused on investing, research consultants, pricing information and market data services, meetings and software or other products and services used by L 1 in providing investment advisory services to clients. Additionally, in some cases, these “soft” or commission dollars are used to service client accounts that did not pay for the benefits since we do not allocate soft dollar benefits to client accounts based on the soft dollar credit the accounts generate. As a result, the commissions paid to broker-dealers can exceed the lowest possible commissions available and clients can be deemed to be paying for such services with “soft” or commission dollars. When “soft” or commission dollars are used to obtain research, brokerage or other products or services, the adviser receives a benefit because the adviser does not have to produce or pay for the research, brokerage, products or services. On the other hand, the client benefits because they receive research, brokerage, and other products or services they otherwise would not have been able to benefit from. This creates an incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services. L 1 d e t e r m i n e s in good faith that commissions charged are reasonable in relation to the value of services received in view of the terms of the particular transaction or the adviser’s overall responsibilities to all of its clients In all cases, “soft dollar” arrangements will comply with the so-called “safe harbor” provisions of Section 28(e) of the Securities Exchange Act of 1934. The Firm also receives incidental research-related products or services from brokers outside of formal soft dollar arrangements that are considered a “soft dollar benefit” under applicable law. Clients may request us to direct brokerage to a certain broker-dealer. If a client chooses to direct brokerage, the agreement between the client and broker must be provided to us in writing. L 1 ’s ability to achieve best execution will be partially or wholly limited by the nature of the directed brokerage agreement that the client has instructed us to follow. For example, the commissions charged in directed brokerage arrangements may be higher than what L 1 would pay for similar transactions. Additionally, the client may incur a higher cost because we are unable to obtain the most favorable execution and/or we will not be able to aggregate the order to reduce transaction costs. The Firm will infrequently direct trades of securities directly between client accounts when, in the judgment of L 1 , the transaction is in the best interest of each client participating in the transaction. When this occurs, we arrange the transaction through an independent broker-dealer for one client account to purchase a security directly from another client account at prevailing market prices. We are not a broker-dealer and we do not receive compensation from a cross trade. However, the broker-dealer facilitating the trade normally charges an administrative fee to the clients’ accounts. Trade Errors As a fiduciary, we have the responsibility to effect orders correctly, promptly and in the best interests of the Clients. In the event any error occurs in the handling of any transactions due to L 1 ’s actions, or inaction, or the actions of others, our policy is to assess each trade error on a case-by-case basis. Item 13 – Review of Accounts L 1 investment professionals, relationship managers and investment analysts, review all client accounts on a continuous and ongoing basis to ensure the accounts are consistent with the client’s stated objectives and identify accounts that warrant a more detailed review. Client accounts are also reviewed as needed based on market conditions and changes to a client’s financial situation. The account reviews include, but are not limited to, assessing the client’s objectives, evaluating the asset class weightings against targets, analyzing the composition of the individual securities in the portfolio, and reviewing any stated restrictions by the client. On a quarterly basis or monthly basis depending on client’s preference, all clients receive a package that contains written reports regarding their account which may include a summary of assets under management, portfolio appraisal, performance, billing statement and other client specific statements. Clients may request that specific reports be added to their quarterly package. Item 14 – Client Referrals and Other Compensation L 1 does not pay third parties for client referrals nor do we receive any other compensation for client referrals. In the event that this should change, the details of any specific agreement with unaffiliated third parties for their assistance in referring business to L 1 will be provided to affected clients 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  prior to, or at the time of, entering into any advisory contract with such clients. Any such arrangements will comply with Rule 206(4)-3 under the Investment Advisers Act of 1940. Item 15 – Custody The amended and revised Rule 206(4)-2 of the Advisers Act sets forth extensive requirements regarding possession or custody of Client funds or securities. The Rule requires advisers that have custody of Client funds or securities to implement a set of controls designed to protect those Client assets from being lost, misused, misappropriated, or subject to financial reverses. L 1 does not have physical custody of client funds or securities. Each client establishes a custodial relationship with an independent bank or brokerage Firm and opens an investment account in the client’s name that is advised by L 1. Clients receive at least quarterly statements from the broker-dealer, bank or other qualified custodian that holds and maintains the client’s investment assets. L 1 urges clients to carefully review these statements and compare these official custodial records to the account statements that we provide. Item 16 – Investment Discretion L 1 provides financial counseling, investment management and customized investment portfolios to multi-generational families on both a discretionary and non-discretionary basis through the use of power of attorneys over accounts on a case-by-case basis. In the case of a discretionary investment management agreement, L 1 ’s “standard” investment contract will include to Power of Attorneys, in which we have full discretionary authority to select the specific type and quantities of securities to be bought or sold without obtaining client consent or authority. In all cases, such discretion is exercised in a manner consistent with the stated investment objectives for the particular client account. In the case of a non-discretionary investment management agreement, we must obtain client consent or authority before final execution of selecting the specific type and quantities of securities to be bought or sold. Clients execute an investment management agreement which appoints L 1 as investment adviser for their investment accounts. Clients are responsible for informing of any investment guidelines or restrictions and any changes to their investment objectives. When selecting securities and determining amounts, the Firm observes the investment policies, limitations and restrictions of the clients for which it advises. Item 17 – Voting Client Securities If clients grant Power of Attorney to L 1 over investments accounts, L 1 has the authority to vote proxies on clients’ behalf, unless otherwise stated in the investment management agreement. Because solicited votes with respect to private funds often raise unique questions, we review, evaluate and vote these on a case-by-case basis. When a consent or other solicited vote or proxy relates to a routine matter, we generally vote in accordance with the objective of encouraging action that enhances client value. When we identify a potential conflict of interest, we will determine whether the conflict is material. If we determine the conflict is material, we will take one or some of the following steps: • Inform the client of the material conflict and our voting decision. • Discuss the proxy vote with the client. • Fully disclose the material facts regarding the conflict and seek the client’s consent to vote the proxy as intended. • Seek the recommendation of an independent third party. In all cases, we will document the steps we took to address the conflict. Clients can obtain a copy of L 1 ’s complete proxy voting policies and procedures upon request. Clients can also obtain information from L 1 about how L 1 voted any proxies on behalf of their account(s). Clients who wish to vote their own proxies or would like to obtain any information about how their proxies were voted should contact us at 305-848-3411 or ignacio.martinez@l1gw.com. 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133  Item 18 – Financial Information L 1 has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 2601 S Bayshore Dr Unit 100 Coconut Grove Florida 33133