LOTUSGROUP ADVISORS

Item 1: Cover Page (Firm CRD #143379 / SEC #801- 111051) 1005 South Gaylord Street Denver, CO 80209 Email: info@lgadvisors.com Website: www.lgadvisors.com Phone: 720.593.9861 March 31, 2026 This Form ADV Part 2A Brochure (or "Brochure") provides information about the investment qualifications and business practices of LotusGroup Advisors, LLC. ("LotusGroup,” "LGA," the "Adviser,” "us,” "we," or "our"), an investment adviser registered with the United States Securities and Exchange Commission. If you have any questions about this brochure's contents, please contact LotusGroup's Chief Compliance Officer, Amanda N. Cohen, at 720.593.9861. This Brochure's information has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or any state securities authority. Nothing in this document is to be construed as a recommendation or an endorsement by the SEC or any state securities authority or an offer of securities; please refer to the actual investment offering and related legal documentation for complete disclosures. Any reference to or use of the terms "registered investment adviser" or "registered" does not imply LotusGroup or any of its associated persons have achieved a certain level of skill or training. Investments involve risk, including the possible loss of principal. An adviser's written and oral communications provide you with information to determine whether to retain their services. As required by federal and state regulations, this Brochure is on file with the appropriate regulatory authorities. Additional information about LotusGroup Advisors, Inc. is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Adviser Firm," and type in the firm's name or CRD #143379.) Results will provide you with all parts of the firm's disclosure brochures.) 1  Item 2: Summary of Material Changes Update LotusGroup Advisors reviews its Form ADV Part 2A Brochure at least annually to confirm it remains current. In this item, we are required to summarize only those material changes made to the Brochure since the last annual updating amendment of March 2025. Since the previous annual amendment, changes have been created to the following Brochure areas: Item 4: Advisory Business • Updated description of the Adviser’s principal owners; • Added language for clarification pertaining to the Adviser’s 3(21) fiduciary status under ERISA due to services provided to ERISA qualified plans; and • Added language regarding Selection of Other Advisers as an advisory service provided to Clients. Item 5: Fees and Compensation • Added language identifying where Clients may find information pertaining to outside compensation arrangements of the Adviser within this Brochure; • Updated the Adviser’s strategies and associated Management Fee Schedule; • Defined “Solicited Clients” and expanded language on the fees typically charged to Solicited Clients; • Added language disclosing the fees typically charged for services provided to ERISA qualified plans or plan sponsors; • Expanded language pertaining to the fee billing cycle for Clients; and • Described how private investments are valued for fee calculations and billing. Item 6: Performance Based Fees & Side-By-Side Management • Clarified language to state LGA does not charge performance-based fees. Item 7: Types of Clients • Removed pooled investment vehicles as a client type LGA to which provides investment advisory services. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss • Updated the list and description of investment strategies LGA offers to Clients; • Added language pertaining to Private Investments strategy method of analysis; and • Added additional risks pertaining to LGA’s offered investment strategies that may be material to Clients. Item 10: Other Financial Industry Activities and Affiliations • Updated disclosure language pertaining to LGA’s affiliate, LotusGroup Capital, LLC (“LGC”) noting updates to LGC’s private fund vehicles under management; • Added language for disclosure of LotusGroup Life Settlements, a d.b.a of LGC; and • Added language for the disclosure of Martorello Money Management, LLC. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading • Clarified language regarding the Adviser’s policies, procedures, and practices for disclosing potential conflicts of interest of its Associates, including when Associates have an interest in Client transactions Item 12: Brokerage Practices • Clarified language pertaining to LGA’s brokerage practices, including LGA’s procedure for reviewing brokerage partners typically utilized for LGA Client transactions. 2  Item 13: Review of Accounts • Clarified language pertaining to LGA’s typical Client account review process. Item 14: Client Referrals and Other Compensation • Clarified language pertaining to Solicitor arrangements disclosure; and • Added language pertaining to additional compensation LGA and its affiliates receive via Endorsement Agreements with third parties. Item 16: Investment Discretion • Clarified language pertaining to non-discretionary assets under management at LGA. Item 17: Voting Client Securities • Clarified language pertaining to LGA’s proxy voting practices, policies, and procedures. Part 2B: Mr. Matthew Woolbright • Removed Mr. Matthew Woolbright’s Form ADV Part 2B Brochure Supplement as Mr. Woolbright is no longer a licensed IAR with the Adviser. Part 2B: Mr. Xavier Lewis • Updated conflict of interest disclosure language for Mr. Xavier Lewis as an IAR in his attached ADV Part 2B Brochure Supplement. Full Brochure Availability This Form ADV Part 2A Brochure applies to all LotusGroup advisory accounts, including any accounts a client may open in the future. The adviser may, at any time, amend this document to reflect changes in its business practices or for other required updates as mandated by securities regulators. Annually, we will provide clients - either by electronic means or by hard copy, with a copy of this Brochure or a "summary of material changes" notice from the document previously distributed. Please retain this for future reference, as it contains essential information concerning LGA advisory services and business. At any time, you may view the current disclosure brochures online at the SEC's Investment Adviser Public Disclosure website at https://adviserinfo.sec.gov/ by searching the firm name or CRD #143379. You may also request a copy by contacting us at 720.593.9861. 3  Item 3: Table of Contents Item 1: Cover Page .............................................................................................................................................................................. 1 Item 2: Summary of Material Changes ............................................................................................................................................. 2 Item 3: Table of Contents .................................................................................................................................................................. 4 Item 4: Advisory Business .................................................................................................................................................................. 5 Item 5: Fees & Compensation ........................................................................................................................................................... 7 Item 6: Performance-Based Fees & Side-By-Side Management................................................................................................... 9 Item 7: Types of Clients ..................................................................................................................................................................... 9 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ........................................................................................ 10 Item 9: Disciplinary Information .................................................................................................................................................... 14 Item 10: Other Financial Industry Activities & Affiliations ........................................................................................................ 14 Item 11: Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading ........................................... 15 Item 12: Brokerage Practices ........................................................................................................................................................... 16 Item 13: Review of Accounts .......................................................................................................................................................... 16 Item 14: Client Referrals & Other Compensation ....................................................................................................................... 17 Item 15: Custody ............................................................................................................................................................................... 18 Item 16: Investment Discretion ...................................................................................................................................................... 18 Item 17: Voting Client Securities .................................................................................................................................................... 18 Item 18: Financial Information ....................................................................................................................................................... 19 Form ADV Part 2B Brochure Supplement - Raphael A. Martorello ........................................................................................ 20 Form ADV Part 2B Brochure Supplement - Nicholas S. Pirnack, CEPA .............................................................................. 25 Form ADV Part 2B Brochure Supplement - Stephanie L. Schlemeyer ................................................................................... 28 Form ADV Part 2B Brochure Supplement - Brian W. McAuliffe ........................................................................................... 31 Form ADV Part 2B Brochure Supplement - Samuel S. Redman ............................................................................................. 34 Form ADV Part 2B Brochure Supplement - Keaton H. Hamilton ......................................................................................... 38 Form ADV Part 2B Brochure Supplement - Xavier Lewis ....................................................................................................... 42 4  Item 4: Advisory Business Description of the Advisory Firm LotusGroup Advisors, LLC ("LotusGroup Advisors", "LGA", or the “Adviser”) is a federally registered investment adviser formed on December 22, 2006, and is organized as a limited liability company under the laws of the State of Colorado. The Adviser has been in business since January 2007. LGA is authorized to do business in any state but also has made specific State Notice Filing for state registrations as detailed under Item 2 of LGA’s Form ADV Part 1. LGA is principally owned by Raphael A. Martorello, Managing Partner. Mr. Martorello also maintains principal ownership and full authority to manage LotusGroup Capital, LLC (“LGC”), a separate but affiliated registered investment advisory firm and related adviser, also located in Denver, CO. LotusGroup Capital, LLC, LGA’s affiliated SEC registered investment adviser, collectively with LGA and other affiliates, form “LotusGroup.” (Please see Mr. Martorello's LGA Form ADV Part 2B – Brochure Supplement for additional details on his formal education, business background, and outside business activities.) Types of Advisory Services LotusGroup offers the following services to advisory clients: Financial Planning & Portfolio Management LotusGroup Advisors offers financial planning services and advice, investment advisory and portfolio management services for private clients, solicited clients, individuals and their households, high-net-worth individuals, and companies (all collectively called "Clients" going forward in this document) through appropriate advisory agreements, such as Investment Management Agreements (“IMAs”), Full Trading Authorization, and/or a Limited Power of Attorney. LotusGroup Advisor's minimum asset requirement for new Clients is generally $500,000. LotusGroup Advisors may make an exception to the minimum asset requirement at its sole discretion. Although this practice is highly recommended for ongoing savings, asset allocation, and tax efficiency, there are no ongoing contribution requirements. Upon engagement with LGA, Clients undergo an introductory interview to outline their financial situation and help LotusGroup Advisors set risk tolerance and investment objectives. Clients then choose a portfolio strategy based on their risk profile, objectives, investor behavior profile, liquidity needs, and the amount of assets that LotusGroup Advisors will be managing on their behalf. Clients select one of six risk profiles: aggressive, moderate-aggressive, moderate, conservative-moderate, conservative, and ultra-conservative, and choose one of four portfolio strategies based on behavior profile and assets: index, global rotation, tactical, and private investment only. LotusGroup Advisors meets with Clients periodically to review their financial situation, answer questions, and determine if adjustments are needed relative to their financial objectives, risk tolerance, and time horizon. For individual Clients who have expressed interest, LGA offers a complimentary financial planning service to help them make major life decisions and track how they are doing against their financial goals on an ongoing basis. In certain circumstances, LGA may provide investment advice with respect to retirement assets, including individual retirement accounts (“IRAs”) and recommendations regarding rollovers from employer-sponsored retirement plans. In such scenarios, while IRAs are not subject to Employee Retirement Income Security Act of 1974 (“ERISA”), they are subject to the prohibited transaction rules under Section 4975 of the Internal Revenue Code. LGA’s Investment Adviser Representatives (“IARs”) may, at times, provide advice and/or recommendations to qualified retirement plans, including plans governed by ERISA, such as 401(k) plans. When providing such services, LGA may act as a fiduciary within the meaning of Section 3(21) of ERISA. In this capacity, LGA and its IARs provide non-discretionary advice and consultation to plan sponsors, plan fiduciaries, and/or plan participants. LGA does not serve as an investment manager of the plan and final decision-making authority remains with the plan sponsor or other plan fiduciaries. 5  When providing advice with respect to retirement assets, LGA seeks to act in the best interest of its Clients and, where applicable, to comply with relevant fiduciary standards and prohibited transaction rules under ERISA and the Internal Revenue Code. LotusGroup Advisors generally performs daily management activities within the guidelines of an Investment Policy Statement ("IPS") and IMA without day- to-day client consultation with Clients (known as "discretionary" management of assets). All funds are held in a Client's account at an independent brokerage firm(s), and each Client authorizes invoices to be paid from their account(s). Also, LotusGroup Advisors provides: • Account setup and transfers to a selected Broker/Custodian, • Development of a Client IPS, along with a personalized savings & investment program, • Discretionary selection of specific investments within the program, • Periodic adjustment of the asset allocation model within the stated client's category grouping and risk profile, • Weekly (for Tactical Strategies) and monthly (for Global and Index) administration of portfolio rebalancing as assets move outside of a specified target range, • Production and distribution of individual quarterly performance reports, • Production and delivery of Client newsletters, • Ongoing reviews and updates of Client goal trackers, • Personalized advice and analysis to assist in making good decisions, • Support in setting up 401K plans for small business owners and investment fund line-up evaluation and selection services. Selection of Other Advisers (Including Private Fund Managers) For select Clients that meet investor sophistication standards qualifying them to invest in privately offered pooled investment vehicles and other alternative asset types, LGA provides services to assist with the sourcing, negotiation, and sharing of private investment opportunities that can be made available from other investment advisers. LGA does not provide discretionary investment management services to Clients who choose to invest in these products, oftentimes other pooled investment vehicles, managed by other investment advisory firms. Sourcing, negotiation, and sharing of private investment opportunities enable sophisticated Clients to select an alternative investment opportunity they would like to participate in, the amount they would like to invest, and an account in which they would like to invest. Each Client chooses investments for themselves, with LGA providing introduction access, non- discretionary advice, and ongoing updates to the Client of the particular investment opportunities. In some cases, LGA may introduce select Clients to investment products managed by LGC, an affiliated investment adviser to LGA. Further information about potential conflicts involved with this service is described in Item 8 and Item 10 of this brochure. Business Valuation Services LGA offers business valuation services to current and prospective Clients of the Adviser. These business valuations are administered by a Certified Exit Planning Advisor (“CEPA”) at LGA. These services are targeted to be provided to sophisticated business owners across many industries, including, but not limited to, accounting, finance, trades, goods manufacturing, consultation services, energy exploration, midstream energy services, retail stores, and other small and mid-size businesses. Business valuation Clients will undergo initial meetings and interviews with LGA to identify the intention of the valuation, such as for a sale of the entity or for other means, and the tentative time horizon for any such actions based on the finalizing of the valuation opinion by LGA. The completion of LGA’s valuation opinion will vary depending on the availability of information from the business owner but typically takes between four (4) and eight (8) weeks to complete. 6  Client Tailored Services & Client Imposed Restrictions LGA offers the same suite of services to all its clients. In rare cases, a Client can request that LGA does not sell specific legacy securities (e.g., an inherited stock with large capital appreciation).Clients can impose restrictions on investing in certain securities or types of securities by their values or beliefs. However, if the restrictions prevent LGA from adequately servicing the Client account or if the limits require LGA to deviate from its standard suite of services, LGA reserves the right to end the relationship. Assets Under Management LotusGroup Advisors does not participate in wrap fee programs by providing portfolio management services and, therefore, receives no portion of a wrap fee for LGA services. LotusGroup Advisors provides the above services, managing $286,036,049 in Client assets, $217,855,639 on a discretionary basis, and $68,180,410 on a non-discretionary basis as of December 31, 2025. Item 5: Fees & Compensation Please note, unless a Client has received the Adviser's disclosure brochure at least 48 hours before signing the investment advisory contract, the Client's investment advisory contract may be terminated within five (5) business days of signing the contract without incurring any advisory fees. LotusGroup Advisors’ payment is dependent upon the type of advisory service performed. Management fees charged by LGA are generally standardized but may be negotiable at LGA’s discretion based on factors such as account size, relationship scope, or other considerations. Fee Schedule Investment Management Fees The LotusGroup Advisors' management fee is based solely on the Client's assets under management and investment strategy selected which are detailed in a Client’s IMA. LotusGroup Advisors does not engage in any compensation arrangements that involve performance-based fees. LGA may receive additional endorsement fees from third-parties that is further outlined under Item 14: Client Referrals and Other Compensation. Additionally, certain LGA IARs may receive compensation through their outside business activities, as described further in Item 10: Other Financial Industry Activities and Affiliations and in the respective IAR Part 2B Brochure Supplement. 7  Each strategy and the corresponding fees are detailed in the fee schedule: Incremental Fee Charged Per Annum Assets Under Management Tactical Strategies on the first $1 Million* On amounts between $1 Million On amounts over $20 Million 1.75% 0.75% 0.50% Global Rotation Strategies On the first $1 Million On amounts in excess of $1 Million 1.50% 0.75% Index Strategies On the first $1 Million On amounts in excess of $1 Million 1.25% 0.75% Private Investment Only On the first $1 Million On amounts in excess of $1 Million 1.75% 0.75% Certain Clients of LGA may be obtained through the services of an engaged third-party solicitor (a “Solicitor”). Any such Solicitor arrangements are governed by a written agreement between LGA and the Solicitor (“Solicitor Agreement”). Please refer to Item 14: Client Referrals and Other Compensation for details pertaining to LGA’s Solicitor engagements. Clients obtain through such Solicitor arrangements (referred to as “Solicited Clients”) may be subject to different management fees than the standard LGA Client fees detailed in the schedule above. The fees paid by Solicited Clients, which are detailed for each individual Solicited Client in their respective IMA, will vary based on the strategy the Solicited Client elects to pursue, the total amount of assets managed by LGA for the Solicited Client, scope of services, and other factors. Solicited Client fees typically range from 0.50% - 1.50% of assets under management, calculated and billed quarterly based on the market value of the portfolio, as of market close on the last day of every calendar quarter. Regarding services provided by LGA IARs to qualified retirement plans, including plans governed by ERISA, as outlined in Item 4: Advisory Business above, LGA will typically charge a fee for these services of 0.50% per annum, billed in arrears either monthly or quarterly depending on the plan or services provided. LGA at their discretion may elect to waive some or all of these fees. Financial planning fees are broken out separately, all of which are clearly articulated in the Solicitor Agreement. Please refer to Item 14: Client Referrals and Item 14: Client Referrals and Other Compensation for more information about LGA’s use of paid solicitors. LotusGroup Advisors retains the discretion to negotiate fees. Clients may be able to find advisory services at lower prices, and LGA maintains the discretion to negotiate fees and has a small subset of clients with reduced or free fee schedules. Advisory fees are calculated quarterly in advance based on the value of the managed assets under management as of the close of business on the last day of the previous calendar quarter, including cash held in the account. Fees are deducted mid-quarter on the 45th day of the quarter. For the first quarter, the billing statement is prorated based on the Client's start date. The Client's start date is the date the funds are initially invested. Private investment assets managed by third-parties are valued based on the last reported value from the applicable 8  fund sponsor or from a third-party valuation firm. In certain circumstances if LGA believes such private investment valuations are unavailable, stale, or not reflective of fair value, LGA may make an independent fair value determination in good faith in accordance with the Adviser’s written valuation policies and procedures that may impact the advisory fees charged by LGA to applicable Clients. These LGA-determined values may be higher or lower than the amount shown on an offering statement or custodian statement. Consequently, portfolio values may reflect estimated values, and prices may not reflect the value at which securities could be sold. Upon account closure (at will by either party), prorated fees will either be collected from or returned to the Client based on the day funds are withdrawn from the Adviser’s supervision by terminating the Client IMA in writing. LotusGroup Advisors automatically deducts advisory fees from the Client's account. In all cases, the Client receives an invoice from LotusGroup Advisors before the withdrawal. The Client authorizes withdrawals through a signed Customer Agreement and written authorization with the Custodian. Invoices are sent to clients at the beginning of each quarter but no later than the 15th day of the first month in the quarter, along with their quarterly reporting packet. The Custodian also sends monthly account statements to the Client with the management fee transaction displayed in its withdrawal month. LotusGroup Advisors sends the Custodian invoices for withdrawal of fees on the 45th day of the quarter. Please refer to Item 15: Custody for more information that Clients receive from the Custodian. Other Fees Clients typically incur additional portfolio expenses from brokerage transaction fees, wire transfer fees, annual private asset custodian fees, and underlying mutual fund and ETF expenses. Please refer to Item 12: Brokerage Practices for more information regarding brokerage practices. Business Valuation Fees LotusGroup Advisors charges a flat fee for providing business valuation opinion services. This fee is stated, and generally non- negotiable, and set for all current clients and prospective clients. LGA Business Valuation Opinion $2,500.00 / entity valuation provided Fees are paid upfront to LGA at the time of contract execution. In the event that the contract is with a current LGA client, the fee may be paid by deducting the amount directly from the Client’s account, as advised by LGA and Client authorization exists. For those that are not current LGA Clients, fees must be paid to LGA by way of a check written out to LGA and mailed to the Adviser's address. Item 6: Performance-Based Fees & Side-By-Side Management As described above in Item 5: Fees and Compensation, LGA's wealth management fee is based solely on Client assets under management. The Adviser does not utilize performance-based fees. Consequently, LGA does not engage in the side-by-side management of accounts charged a performance-based fee with accounts charged with another type of fee (such as assets under management). Item 7: Types of Clients LotusGroup Advisors provides discretionary and non-discretionary investment advice and supervisory management services to several types of Clients, including the following: • Private individuals (taxable accounts, retirement accounts, educational accounts). • High-net-worth individuals. • Trusts (personal and business accounts). • Companies and Institutions • Pension and profit-sharing plans (but not the plan participants or government pension plans). • Retirement accounts and other assets that may be deemed subject to ERISA requirements 9  • Other investment advisors. Minimum Account Size The minimum asset requirement for new wealth management clients is $500,000. LotusGroup Advisors can make an exception to the minimum asset requirement at its sole discretion. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss Analysis & Strategies LotusGroup Advisors maintains a list of investable asset classes and preferred investment product(s) within these asset classes. This list is continually refined as market conditions change and new products become available. Such investment products are evaluated continuously through a combination of independent analysis and purchased research, intending to find the lowest cost and competitive options within their respective asset classes. LotusGroup Advisors then provides Clients with the following investment choices within their stated Client grouping and risk profile, referencing the investable asset/product list described below: • Index: The Index strategy is a diversified, long-term approach that aligns with principles of broad market exposure and passive investing. Portfolios are invested across global asset classes using index-based investment vehicles designed to track market performance. The strategy maintains consistent market exposure with minimal allocation adjustments over time. Portfolios are monitored on an ongoing basis and are generally rebalanced at least monthly to maintain alignment with target allocations. • Global Rotation: The Global Rotation strategy is a diversified, long-term approach that seeks to maintain broad exposure across global asset classes. LGA utilizes third-party research, including Ned Davis Research (“NDR”), to evaluate regional, style, and market capitalization trends and may modestly overweight or underweight asset classes relative to a baseline allocation. The strategy is designed to maintain relatively consistent market exposure over time, with only modest adjustments and, in certain circumstances, may modestly reduce exposure during periods of significant market stress. Portfolios are monitored on an ongoing basis and are generally rebalanced monthly to maintain alignment with target allocations. • Tactical: The Tactical strategy is a more actively managed approach that seeks to adjust portfolio exposures in response to changing market conditions. LGA utilizes third-party research, including NDR, along with internal analysis to more actively overweight or underweight asset classes, including adjusting overall market exposure, regional positioning, and style or capitalization tilts. The strategy is designed to be more responsive to market conditions and, in certain environments, may utilize active trading and risk management techniques, including volatility-based hedging, to seek to manage downside risk. Portfolios are monitored on an ongoing basis and are generally rebalanced more frequently, typically on a weekly basis. • Private Investments: LGA conducts a sourcing and due diligence process to identify and evaluate private investment opportunities for select Clients who meet applicable investor eligibility standards. This process may include reviewing investment strategy, manager experience, terms, fees, and other relevant factors, as well as negotiating certain investment terms where appropriate. Participation in private investments is at the discretion of the eligible Client, LGA may monitor these investments on an ongoing basis; however, Clients should be aware that private investments are typically managed by third- party managers and may involve limited liquidity and transparency. Typical public market investments include Exchange Traded Funds (“ETFs”), closed-end funds, open-ended funds, and individual company stocks across a broad base of different asset classes: US stocks, US bonds, Foreign stock, Foreign bonds, Emerging Markets, Raw Materials, Energy, Precious Metals, REITs, Currencies, Managed Futures, Long-Short Strategies, Absolute Return Strategies, Merger Arbitrage Strategies. Typical private investments are made 10  through other private fund vehicles (“fund-of-funds”) with strategies that focus on infrastructure holdings, real estate equity, real estate debt, private debt, special situations, litigation financing, life settlements, and private equity. In evaluating investments, LGA utilizes a combination of fundamental and technical analysis. These approaches may include the review of economic conditions, valuation, sentiment, market trends, and other relevant factors to support investment decision-making and portfolio management. Risks of Loss The principle risks involved in LGA’s investment strategies generally include the following: • Stock Market Risk: The market value of stocks will generally fluctuate with market conditions. While stocks have historically outperformed other asset classes over the long term, they tend to fluctuate over the short term due to factors affecting the individual companies, industries, or the securities market. The past performance of investments is no guarantee of future results. • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before generating a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment. • Currency Risk: Overseas investments are subject to fluctuations in the dollar's value against the investment's originating country's currency. This risk is also referred to as exchange rate risk. • Financial Risk: Excessive borrowing to finance a business's operations increases the risk of profitability because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations can result in bankruptcy and declining market value. • Liquidity Risk: Liquidity is the ability to convert an investment into cash readily. Assets are generally more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Political & Legislative Risk: Companies face a complex set of laws and circumstances in each country in which they operate. The political and legal environment can change rapidly and without warning, with significant impact, especially for companies operating outside of the United States or those that conduct a substantial amount of their business outside of the United States. • Geopolitical Risk: Geopolitical events may have adverse effects on financial markets, specific sectors, and individual securities. Such events may include, but are not limited to, changes in government policies, trade agreements or tariff policies, political instability, armed conflicts, terrorism, sanctions, or other global or regional developments. These events may cause increased market volatility, reduced liquidity, disruptions to trading markets, and uncertainty in the valuation of certain investments. Client accounts may be adversely affected by such conditions, which are outside of the LGA’s control. • Emerging Market Risk: The risk involved with investing in companies organized in emerging market nations. Investments in securities and instruments traded in developing or emerging markets or that provide exposure to such securities or markets can involve additional risks relating to political, economic, or regulatory conditions not associated with investments in U.S. securities and instruments or investments in more developed international markets. Such conditions may impact the ability to buy, sell, or otherwise transfer securities. • • Reinvestment Risk: This is the risk that future proceeds from investments will have to be reinvested at a potentially lower rate of return (i.e., interest rate). This risk primarily relates to fixed-income securities. Investment Strategy Risk: The success of the LGA’s investment strategies depends on the Adviser’s ability to identify and implement appropriate investment opportunities. There is no assurance that any strategy will achieve its intended results, and strategies may underperform compared to other investments or market benchmarks. • Frequency of Trading Risk: Some of the LGA’s strategies require frequent trades to take place and, consequently, portfolio turnover and brokerage commissions, expenses, and other trading costs can be higher for certain Client accounts. • Dependence on the Adviser & Key Personnel: All discretionary investment activities concerning 11  Client accounts will be made by the Adviser and rely on key LGA employees and third-party partnerships. If any of LGA’s key employees leave or become incapacitated for any period, the performance of a Client’s account may suffer. To help mitigate such risks, LGA relies on a key-man playbook with affiliated firm LotusGroup Capital, LLC, and the Adviser has other vital partners who would execute the key-man playbook. • Affiliated Manager Risk: LGA may recommend or allocate Client assets to private funds or investment vehicles managed by an affiliated investment adviser, LGC. This creates a conflict of interest, as LGA and LGC may be each entitled to receive additional compensation or economic benefits from such investments. LGA has an incentive to recommend affiliated investments over unaffiliated alternatives. In such cases, LGC does not charge management fees on LGA Client assets invested in an LGC private fund or investment vehicle. While this practice is intended to mitigate certain conflicts of interest, the inherent conflict of interest still exists. Both LGA and LGC further address this risk through internal policies and procedures, however, Clients should be aware of such conflicts between LGA and LGC. • Solicitor and Referral Risk: LGA may compensate third-party solicitors for referring Clients to the Adviser. This creates a conflict of interest, as such individuals or entities have a financial incentive to recommend LGA’s services. As a result, LGA Clients should be aware that a solicitor’s recommendation may not be solely based on the Client’s needs or the quality of the Adviser’s services. LGA seeks to mitigate these conflicts through compliance with applicable regulations, including providing required disclosures regarding such arrangements and routine review of solicitors and solicitor arrangements in place, however, these conflicts of interest remain. • Alternative Asset Risk: These assets may increase the risk of investment loss and be highly illiquid and not required to provide investors with periodic pricing or valuations. They may involve complex tax structures and delays in distributing important tax information and are not subject to the same regulatory requirements as mutual funds or other registered investment companies. Investors in these products are often charged high fees, which may offset any trading profits; investors may incur asset-based charges and expenses at the fund level and indirect fees, expenses, and asset-based compensation of investment funds in which these funds invest. In many cases, they include underlying investments that are not transparent and are known only to the investment manager. Alternative investment returns may fluctuate and are subject to market volatility; an investor's shares, when redeemed or sold, may be worth more or less than their original cost. An investor could lose all or a substantial amount of their investment. Alternative investment fund account managers often have total trading authority over their funds or accounts; using a single adviser applying (usually) similar trading programs could mean a lack of diversification and, consequently, higher risk. Managers typically seek absolute positive investment performance by targeting a specific range of performance and attempting to produce targeted returns irrespective of the stock market's underlying trends. There can be no assurances that a manager's strategy (hedging or otherwise) will be successful or that a manager will use these strategies concerning all or any portion of a portfolio. Please read the investment's Private Placement Memorandum and associated legal documents and consult your Financial Advisor, tax advisor, and legal counsel for a complete description of the risks associated with this type of investment. • Third-Party Managers Risk: LGA Client accounts may have a portion of their assets invested in private investments managed by third-party managers. The performance of these investments may depend on, in part, the ability of these third-party managers to successfully implement their investment strategies. There is no guarantee that any third-party manager will successfully execute their strategy or achieve their stated investment objective. • Valuation Risk: Certain investments, particularly private investments and illiquid securities, may not have readily available market prices. LGA often will rely on the valuation of private investments that are provided by the third-party managers which manage each respective private investment. As a result, valuations may be based on estimates, calculations, and assumptions provided by third-party managers. Such valuations may differ from actual market values, and investors may not be able to realize these values upon liquidation. • Liquidity and Lock-Up/Redemption Risk: Certain private investments may impose restrictions on withdrawals, including lock-up periods, redemption gates, or limitations on liquidity. As a result, LGA Clients may be unable to access invested capital for extended periods and may be required to remain 12  invested during adverse market conditions. • ETF-related Risk: Investments in ETFs are subject to risks similar to those of the underlying securities or assets held by the ETF, including market risk, liquidity risk, and tracking error risk. Although ETFs are generally designed to track the performance of a specific index or asset class, an ETF’s performance may deviate from its benchmark due to fees, expenses, and market factors. LGA may also invest Client assets in leveraged or inverse ETFs. Leveraged and inverse ETFs involve additional risks and are typically designed to achieve their stated objectives on a daily basis. As a result, such ETF performance over longer periods of time can differ significantly from the performance (or inverse performance) of the underlying index or benchmark. Due to the effects of compounding, these products may experience increased volatility and may incur substantial losses, particularly in volatile market conditions. Leveraged and inverse ETFs are generally considered more suitable for short-term trading rather than long-term investment which LGA closely monitors for applicable Client accounts. • Cybersecurity Risk: In connection with the increased use of technologies such as the Internet and the dependence on computer systems to perform necessary business functions, Client accounts can be susceptible to operational, information security, and related risks due to the possibility of cyber-attacks or other incidents. Cyber incidents can result from deliberate attacks or unintentional events. Cyber- attacks include but are not limited to infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks, or devices that are used to service Client operations through hacking or other means to misappropriate assets or sensitive information, corrupt data, or causing operational disruption. Cybersecurity failures or breaches by the Fund's third-party service providers can cause interruptions and impact the service providers' and the Fund's business operations, potentially resulting in financial losses. The Adviser can incur substantial costs to prevent or address cyber incidents in the future. • Artificial Intelligence Risk: LotusGroup may use Artificial Intelligence (“AI”) to automate operational tasks and enhance research processes. These systems, if and when used, are designed to support and streamline existing processes, with human oversight remaining integral to all critical functions. AI is not used materially in the investment decision making process, which remains under the discretion of LotusGroup investment professionals. The effectiveness of AI depends on factors such as the base model’s training, associated programming accessing the AI model, and the quality of data the AI model references. Any inaccuracies or operational issues within AI driven tools would not impact LotusGroup’s ability to perform its core functions but may affect the speed at which certain tasks are completed. Additionally, LotusGroup may work with third-party vendors that incorporate AI into their services, which could introduce additional risks if those systems encounter issues, are compromised, or deliver inaccurate results. Broader considerations, such as cybersecurity, data reliability, and system limitations, are also inherent in the use of technology. • Pandemic and Global Health Crisis Risk: LGA may be susceptible to risks associated with a pandemic or similar global health crisis. Impacts on critical service providers may create delays in required reporting, make it difficult for LGA to obtain accurate account or other information from third parties, increase operations risks such as trade breaks, and may lead to delays in communication, documentation, and other critical aspects of LGA’s advisory services. These examples are meant to provide examples of potential impacts and LGA does not purport this list to be all inclusive. • Changes in Regulation & Enforcement; Litigation: The businesses of LGA, as well as the financial services industry generally, are subject to extensive regulation, including periodic examinations, by governmental agencies and self-regulatory organizations or exchanges in the United States and foreign jurisdictions in which they operate. These relate to, among other things, antitrust law, anti-money laundering laws, anti-bribery laws, laws about foreign officials, privacy laws concerning client information, and the regulatory oversight of the trading and other investment activities of alternative asset management funds and their investment advisers, including LGC and LGA. Each regulatory body with authority over Clients and LGA has the regulatory powers dealing with many aspects of financial services, including the authority to grant. In specific circumstances, it can cancel permissions to carry on particular activities. Any failure to comply with these rules and regulations could expose LGA to liability or other risks. 13  Past performance is not a guarantee of future returns. Investing involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information this item. Clients may review LGA and its Registered investment advisers such as LGA are required to disclose all material facts regarding any legal or disciplinary events that would be material to a client or prospective client's evaluation of LGA or its management's integrity. LGA does not have any such legal or disciplinary events in its history and, therefore, has no information to disclose concerning Investment Advisor Representatives on www.brokercheck.finra.org or www.adviserinfo.sec.gov. Item 10: Other Financial Industry Activities & Affiliations While LotusGroup Advisors has developed a network of professionals to help support Client needs (e.g., accountants, lawyers, and broker dealers), LotusGroup Advisors and its investment professionals are not affiliated with any of these firms. Some LotusGroup Advisors IARs may be employed at unaffiliated insurance agencies which deal in Life Insurance Products that may be recommended to Clients. In these outside business activity roles, IARs may receive a commission for the sale of an insurance product that is not regulated as a security. In the event that an IAR receives a commission for the sale of an insurance product, a recommendation will only be made if it is determined to be in the best interest of the Client. Furthermore, a conflict can be avoided by the fact that the Client always has the right to act on any insurance product recommendations, and, if the Client chooses to act on such insurance product recommendation, the Client may do so through an insurance broker or agency of their choosing. LGA does not offer insurance products and does not receive any compensation for the life insurance products sold by an IAR as part of their outside business activities. Related Parties LotusGroup Capital, LLC LotusGroup Advisors has an affiliated, SEC registered investment adviser entity that is under common control with LGA, LotusGroup Capital, LLC ("LGC"). LotusGroup Capital's principal owner is Raphael A. Martorello, Managing Member. LGC offers a specific advisory service; it manages privately offered pooled investment vehicles exempt from registration as investment companies under the Investment Company Act of 1940. LGC also provides insurance services consulting to third-party life settlement investors and funds. Mr. Martorello formed and managed both the advisory firm LGC and the private investment funds it manages, LotusGroup Longevity Fund, LLC ("LLF"), and the IncomePlus Funds (“IPF Funds”, as described below). LGC, a Delaware limited liability company launched on October 15, 2018, serves as the Managing Member, the Investment Manager, and the fiduciary of the LLF. As of September 2022, LGC has become the Investment Manager of the IPF Funds (which were previously under the investment management of LGA). The IPF Funds include; LGA IncomePlus Fund L.P. (“IPF”), LotusGroup IncomePlus Fund II L.P. (“IPFII”), LotusGroup IncomePlus Fund III, L.P. (“IPFIII”), and LotusGroup IncomePlus Fund IV, L.P. (“IPFIV”). LGC's clients are LLF and the IPF Funds (together, the “Funds”) to whom LGC provides discretionary advisory services. LGC's role is to perform the sourcing and management of individual investments and the various service providers to the Funds, which seeks to pool investment capital of its investors (for LLF, each a "Member," for the IPF Funds each a “Limited Partner”) for the primary purpose of long-term capital appreciation and a secondary goal of generating income. LLF seeks to achieve its objective by investing primarily in a variety of life settlement contracts with Net Asset Value ("NAV") that increase over time, with potential sales of such contracts to generate gains and eventual maturities that produce realized gains/income to the Fund. The IPF Funds seek to preserve capital by investing Investments that may have different risk and return characteristics than traditional public market investments. Hard 14  assets back most investments, and most deliver attractive current yields ("Income") relative to fixed income options available in the public markets. Additional capital gains accrue upon investment exits ("Plus") for select investments within the Funds. LGC also has a DBA as LotusGroup Life Settlements (“LGLS”). LGLS is primarily a life settlements marketing and educational business line intended to educate insurance agents about life insurance settlements and facilitates introductions to life insurance settlements providers. LGLS does not solicit or manage any investments on behalf of LGC or LGA. If a transaction occurs between an insurance agent and a life settlements provider, LGLS may be entitled to marketing fees for their services. Martorello Money Management, LLC Martorello Money Management, LLC (“MMM”) is an affiliated entity to LGA through a buy-sell transaction and no longer serves as a registered investment adviser. MMM has remained operational for the flow of funds on a financial consulting basis. MMM is compensated by LGA and pays certain LGA personnel a fixed salary and bonus. Additionally, MMM provides funding back to LGA for benefits reimbursements pertaining to LGA personnel. Item 11: Code of Ethics, Participation, or Interest in Client Transactions & Personal Trading As required under Rule 204A-1 of the Investment Advisers Act of 1940, as amended ("Advisers Act"), LGA has adopted a written code of ethics ("Code of Ethics"), which is designed to address and avoid potential conflicts of interest and applies to all Covered Persons. The Code of Ethics may also be applicable to any other person reasonably designated by the LGA Chief Compliance Officer (the "CCO") as a Covered Persons under the compliance program. A full copy of the Code of Ethics will be made available to any LGA Client or prospective Client upon written request. LotusGroup Advisors has developed comprehensive compliance policies and procedures, which include the Adviser’s Compliance Manual, Code of Ethics, and supplemental policies and procedures as appropriate. All Covered Persons are required to attest to their receipt and understanding of LGA’s compliance program documents, including the Code of Ethics, to the CCO on at least an annual basis. The LotusGroup Advisors Investment Team currently consists of various LGA personnel, including several of the Adviser’s IARs. The Investment Team, or other LGA personnel, may invest or trade personally in the same securities as those of LGA’s Clients. LGA seeks to mitigate conflicts of interest inherent when LGA personnel invest in the same securities as LGA Clients. When available, LGA will seek to block trades so that all transactions receive the same execution. When Client accounts are rebalanced, and when block trades are unavailable for all Client transactions, LGA shall typically complete rebalancing orders in a predetermined process based on the alphabetical order of LGA Client last name which neither intentionally benefits nor harms any particular Client. Covered Persons are required to report their personal trading activity to the CCO on a regular basis. Beneficially owned personal trading accounts must be disclosed upon hire and reaffirmed at least annually, holdings in those accounts must be disclosed at least annually, and transactions must be disclosed on a quarterly basis. Quarterly, the CCO performs a Covered Person trading review by reviewing every trade made by the Adviser and is evaluated against everyone on the LGA investment team and all IARs to ensure full compliance with trading policies and procedures, and that no conflicts have occurred. The LGA process is to alert the CCO immediately if a conflict occurs. The CCO will determine the appropriate course of action. Client trades and interests are always placed ahead of and LGA Covered Persons’ personal trading activity. LGA does not engage in transactions directly from a Covered Person account directly to an LGA Client account, or from an LGA Client account directly to a Covered Person account. There may be instances in which a LotusGroup Advisors Client may inquire about or invest in one of the LotusGroup Capital Funds. In such instances, LotusGroup Advisers will maintain its fiduciary duty owed to the Client and will ensure that such an investment is suitable for the Client, disclose any and all applicable fees of such an investment, and discuss the nature of the affiliation between LGA and LGC. Typically, an LGA Client will not pay the usual 15  management fee to LGC for managing these assets. Thus, the client is not double charged management fees for investing in an LGC product. Item 12: Brokerage Practices LotusGroup Advisors suggests that Clients use a LotusGroup Advisors preferred brokerage firm for maintaining funds under management with LotusGroup Advisors. Both retirement and non-retirement accounts are set up and kept for customers with the brokerage. LotusGroup Advisors strives to maintain consistent trading, reporting, and investment operations facilitated by a single broker and their management infrastructure. The preferred broker was selected using the following criteria: • Competitive trading commissions costs, • Customer service levels, • Reporting tools, including cost basis and 1099 reports facilitating tax management strategies, • Personal money management tools - Electronic fund transfer capabilities - Dividend reinvestment programs - Electronic communication delivery capabilities • Financial stability to ensure individual accounts, including primary and backup account insurance. LotusGroup Advisors has chosen Charles Schwab & Co., Inc.(“Schwab”) as its preferred brokerage firm and Custodian for LGA Client accounts. LotusGroup Advisers has no affiliation with Schwab nor any compensation or other arrangements that may create a conflict of interest with this relationship. As a registered broker-dealer and a member of the Securities Investor Protection Corporation (SIPC), Schwab is subject to certain regulations intended to protect assets held in brokerage accounts maintained at Schwab. Schwab Advisor Services serves independent investment advisory firms like ours and includes the custody, trading, and support services of Charles Schwab & Co., Inc. LGA continuously reviews the brokerage capabilities of Schwab against other brokerage firms in the industry. LGA may elect to change to a different preferred brokerage firm if LGA believes that it would be in the clients best interest to do so. LGA may utilize other products or services to assist LotusGroup Advisors in managing and administering Client accounts that are not eligible to be maintained at Schwab. These technologies and services are critical for LotusGroup Advisors to provide the services contracted for with Clients. For 401K, 403B, 457, and 529 accounts under management, LotusGroup Advisors Client accounts remain with their company or state-sponsored plan. Still, the data is incorporated daily into the overall asset allocation model through a portfolio management tool and is also included in the Client's quarterly performance report. LotusGroup Advisors will generally seek to aggregate Client orders when appropriate, taking into account the timing and frequency of trading associated with each investment strategy to ensure the same pricing and execution for all Clients. In certain circumstances LGA may not be able to aggregate, or may choose not to aggregate, Client trades into a single order, such as when initially implementing a new client account or when aggregation is not practical to aggregate orders. However, as soon as this new Client is balanced and, in the system, all new Client orders going forward will have this Client aggregated with others in block trades. LotusGroup Advisors does not receive any soft dollar benefits from Client transactions. Item 13: Review of Accounts LGA’s Investment Team conducts periodic reviews of Client accounts to ensure alignment with each client’s 16  investment objectives and strategy. Tactical strategies are generally reviewed and rebalanced more frequently, typically on a weekly basis, while Global and Index strategies are generally reviewed and rebalanced less frequently, typically on a monthly basis. Private investment holdings are generally reviewed on a quarterly basis, or more frequently as updated information is received from the applicable fund sponsors or general partners. Due to the nature of private investments, including limited liquidity and reliance on sponsor-provided reporting, valuations and performance updates may occur less frequently than for publicly traded securities. The Adviser monitors these investments on an ongoing basis as information becomes available. In addition to these periodic reviews, Client accounts may be reviewed on an as-needed basis in response to market conditions, changes in client circumstances, or updates to LGA’s investment outlook, including third-party research inputs. LotusGroup Advisors’ IARs seek to conduct a minimum of one formal Client review per year. These formal meetings with Clients are meant to go over Client objectives, results from the previous year and since inception, risk profiles, new considerations for the upcoming year, and other relevant factors. Clients are also encouraged to contact LGA if there are any material items to be discussed before the more formal annual review. Further, some Clients request a specific analysis from LGA to help them with financial planning, goal-tracking, scenario analysis, college savings, diversification, insurance reviews, private investment opinions, and other considerations unique to their personal needs and situation. These requests are handled ad-hoc and addressed by LGA’s IARs on a cadence appropriate for the client that may vary as needed). Clients receive the following reports: • LotusGroup Advisors preferred broker-dealer, Schwab, provides monthly account statements, trade confirmations, investor notifications, and year-end tax reports. • LotusGroup Advisors provides quarterly performance reports with since-inception, quarter-to-date, and year-to-date statistics (all reported net of fees). These reports are generated automatically from the Portfolio Management System. Item 14: Client Referrals & Other Compensation LotusGroup Advisors does not accept direct or indirect compensation for using a 3rd party investment product with Clients. LotusGroup Advisors may choose to engage in a Solicitor's Agreement with Solicitors to pay fees for Client referrals. Solicitors serve as independent contractors and not as employees of LotusGroup Advisors. Solicitors solicit and refer Clients to LotusGroup Advisors as individuals or entities suitable and appropriate for the investment advisory services provided by LotusGroup Advisors. Solicitors do not have any authority to accept any Client(s) on behalf of LotusGroup Advisors. LotusGroup Advisors does not have any responsibility to take any prospective client referred by a Solicitor. The solicitation services may also include impersonal advisory services, which include: (i) written materials or oral statements that do not purport to meet the objectives or needs of the specific Client, (ii) statistical information containing no expressions of opinions as to the investment merits of particular securities, and (iii) regular contact, if requested or appropriate, to assist the Solicited Client in understanding the advisory services of LotusGroup Advisors and obtaining or updating Client information on behalf of LotusGroup Advisors. Any specific Client advice will be delivered to the Solicited Client by LotusGroup Advisors, and LotusGroup Advisors shall provide any formal financial planning for the Solicited Client. LGA ensures that any Solicitor arrangement engaged in is dictated by a signed Solicitation Agreement. In general, the Solicitation Agreement establishes disclosure requirements of the Solicitor and those of LGA, compensation arrangements, allowable marketing practices, and oversight requirements, among other items. The Solicitor’s compensation typically comes out of the management fees paid by the client to LGA and is not an additional fee paid by the client. As such, clients do not pay a higher fee than if they had contracted directly with LotusGroup Advisors. 17  Generally, Solicitor compensation may include a flat fee paid initially based on projected management fees and/or a range typically from 0 – 60% of collected client fees. LGA, together with its affiliated entity LotusGroup Capital, may also receive endorsement fees from third-party investment managers subject to an Endorsement Agreement. If such endorsement fees are realized, fees can be generated from investments made by LGA Clients. To mitigate fiduciary conflicts of interest, LGA and LGC refund on a pro-rata basis to LGA Clients endorsement fees generated after appropriate costs incurred by LGA or LGC in conjunction with the applicable LGA Client investment from referral to a third-party manager are subtracted from the net proceeds of the investment. LGA obtains and does not refund endorsements fees for fees generated from investments for non-LGA Client referrals to third-party managers Item 15: Custody LotusGroup does not accept or permit the firm or its Associates to obtain custody of client assets. All client accounts and assets are held by a third-party, unaffiliated custodian. The custodian sends quarterly account statements directly to the clients. We urge clients to carefully review those statements received from the custodian and compare with those received from LotusGroup. LotusGroup Advisors may accept 3rd party checks from client accounts held at Charles Schwab only when prior written approval is received from the client by Schwab. Any 3rd party checks received by LotusGroup Advisors must not be in the name of the client and not that of LotusGroup Advisors, are logged appropriately and sent to the 3rd party typically within twenty-four (24) hours, but in all instances within three (3) business days. Item 16: Investment Discretion LotusGroup Advisor's Clients sign a full trading authorization agreement through the preferred Broker/Dealer. LotusGroup Advisors has the discretion to select, buy, sell, and determine the quantities of the individual positions for each client account. In limited circumstances, LotusGroup Advisors may be required to maintain or solicit a Client’s consent for trades made on positions explicitly discussed during the introductory interview.). LotusGroup Advisors manages a portion of Client assets that the Adviser deems to be non-discretionary. These assets are typically the private investments made by LGA Clients. With regard to LGA Clients pursuing a private investment opportunity, LGA does not place these investments at the Adviser’s discretion. LGA sources and reviews various private investment opportunities and introduces those to appropriate LGA Clients. Any decision to invest in the private placement is at the discretion of the LGA Client as further described in Item 4 of this brochure. Item 17: Voting Client Securities LotusGroup Advisors do not participate in proxy voting for LGA Client accounts. All Clients retain proxy voting authority for all holdings within their accounts. If LotusGroup Advisors were to receive proxy voting authority for a Client account, LotusGroup Advisors would review these matters on a case-by-case basis and seek to vote in a manner that is in the best interest of the Client(s). Due to the nature of the investments typically selected in LGA Client accounts, which typically include ETFs, mutual funds, and other similar products and not direct public equity holdings, it is unlikely that LGA Clients will receive proxies. For such products, the fund manager of these investment companies typically receives, and addresses proxies issued by the underling investments within those respective products. As the account owner, an LGA Client may be contacted directly by phone, email, physical mail, or other means, to obtain their vote on a particular matter for a portfolio holding. Clients are entitled to vote on matters as they see appropriate and are not required to consult with LGA prior to responding. That said, Clients may discuss any proxy 18  voting matters with LGA directly. A copy of LGA’s proxy voting activity, if applicable, as well as LGA’s proxy voting policies and procedures are available to LGA Clients upon request. Item 18: Financial Information LotusGroup Advisors is not aware of any financial conditions that are reasonably likely to impair LGA’s ability to meet our contractual obligations or effectively execute on our business strategy. LGA is not currently nor has it ever been, subject to a bankruptcy petition. LotusGroup Advisors does not require the pre-payment of management fees. 19  Form ADV Part 2B Brochure Supplement - Raphael A. Martorello Investment Advisor Representative RAPHAEL A. MARTORELLO (Individual CRD # 4768833) 1005 South Gaylord Street Denver, CO 80209 Email: info@lgadvisors.com Website: www.lgadvisors.com Phone: 415.793.8041 March 31, 2026 In accordance with federal and state regulations, Form ADV, Part 2B, this “Brochure Supplement” or “Brochure” is on file with the appropriate securities regulatory authorities as required. All the material within this Brochure Supplement must be reviewed by those who are considering becoming a Client of LotusGroup Advisors, LLC (“LotusGroup,” “LGA,” the “Firm,” the “Adviser,” “us,” “we,” or “our”). 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. The information provided in this Brochure is not to be construed as an endorsement or recommendation by state securities authorities in any jurisdiction within the United States or by the SEC. Nothing in this document is to be construed as an offer of securities; please refer to actual fund and investment offering documents for more complete disclosures. Registration of an Investment Advisor does not imply any level of skill or training; investments involve risk, including the possible loss of principal. The oral and written communications of an Adviser provide you with information you may use to determine whether to hire or retain the Adviser. This Brochure provides information about the above Investment Advisor Representative that supplements LotusGroup’s Firm ADV Brochure. You should have received a copy of the Firm’s ADV Brochure that describes the investment advisory services offered through LotusGroup Advisors, the Investment Adviser. Please contact LotusGroup Advisors CCO Amanda N. Cohen directly at 720.593.9861 if you did not receive the Firm’s ADV Brochure or have any questions about the contents of this Brochure Supplement. Additional information about Raphael A. Martorello is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select “Investment Advisor – Individual,” and type in the above Individual CRD #.) 20  RAPHAEL A. MARTORELLO Date of Birth & Educational Background Raphael A. Martorello was born in 1974. He received his bachelor’s degree in Mechanical Engineering and a minor in Economics from The University of Virginia in 1997. Mr. Martorello has fulfilled LotusGroup Advisor’s requirement that its Investment Advisor Representatives hold either a bachelor’s degree and further coursework (i.e., an MBA, a DFP, a CFA, a ChFC, JD, CTFA, EA, or CPA) or possess relevant work experience demonstrating their knowledge of and aptitude for investment management principles. Business Background & Experience 01/2007 to Present LotusGroup Advisors, LLC, Denver, CO Principal, Owner, Managing Partner & Investment Advisor Representative - Manages the LGA Management Team - Sources & invests in private placement opportunities 09/2018 to Present LotusGroup Capital, LLC, Denver, CO Principal, Owner, Managing Member & Investment Advisor Representative - Manages the LGC team & is a Portfolio Manager of the LotusGroup Longevity Fund, LLC, LGA IncomePlus Fund, LP, and the LotusGroup IncomePlus Fund II, LP - Sources & invests in private placement opportunities 03/2004 to Present Martorello Money Management, Denver, CO Partner, Advisor & Investment Advisor Representative - Commercial Investment Experience - Total Investment Experience & Systems Development - Client Service Experience - Operations Experience - Management Experience 03/2000 to 03/2006 ICG Commerce, King of Prussia, PA Director - Practice Responsibility (All-West Coast Clients) - Management Oversight (20 Employees) - Business Process Outsourcing 08/1997 to 04/2000 A.T. Kearney, New York, NY Associate - Management & Business Consulting Professional Designations, Licensing & Exams Raphael A. Martorello does not have any additional professional designations, licensing, or exams to disclose. Disciplinary Information LotusGroup Advisors is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Raphael A. Martorello, providing advice to you. Mr. Martorello does not have a disciplinary history to disclose, which may be material to a client’s or prospective client’s evaluation of this advisory business. There may 21  be items contained on brokercheck.finra.org or www.adviserinfo.sec.gov that you may wish to review and consider in your evaluation of your Investment Advisor Representative’s background. Other Business Activities Raphael A. Martorello is a Principal, Owner, Managing Partner, and an Investment Advisor Representative of LotusGroup Advisors. He dedicates 50% of his time to this activity during trading hours. Outside of his activities at LotusGroup Advisors, Mr. Martorello also participates in the following investment-related other business activities: Name of Outside Business or Organization: LotusGroup Capital, Inc. Address: 1005 South Gaylord Street, Denver, CO 80209 Title: Principal, Owner, Managing Partner & Investment Advisor Representative Description of Outside Business or Organization: Affiliated Registered Investment Advisory firm Description of Duties or Responsibilities: Providing management & investment strategy to leverage research provided to LotusGroup Advisors, LLC and Martorello Holdings, LLC Start Date: 09/2018 Hours Devoted to OBA Monthly: 75% during trading hrs./25% during non-trading hrs. Name of Outside Business or Organization: Martorello Holdings, LLC Address: 1043 S. Vine Street, Denver, CO 80209 Title: Member Description of Outside Business or Organization: Holding company for commercial real estate investment, developing the new HQ office for LotusGroup Advisors & LotusGroup Capital in Denver, CO Description of Duties or Responsibilities: Establishing financing & interacting with the Project Manager, as needed. Start Date: 01/2018 Hours Devoted to OBA Monthly: 0 during trading hrs./1 hour weekly during non-trading hrs. Name of Outside Business or Organization: Martorello Money Management Address: 1005 South Gaylord Street, Denver, CO 80209 Title: Partner Description of Outside Business or Organization: Before 2016, this was an independent Registered Investment Advisor. In January 2016, this organization transitioned all clients into LotusGroup Advisors as part of a business merger. Through the buy-sell transaction, this business was required to de-register as an RIA but to stay open for the flow of funds on a financial consulting base, to pay Raphael A. Martorello’s fixed salary and for the business to provide funding back to LotusGroup Advisors for benefits reimbursements. Description of Duties or Responsibilities: Predominantly administrative within the business and paid to be the Managing Partner of LotusGroup Advisors as a contractor through this business. Start Date: 03/2004 Hours Devoted to OBA Monthly: 0 during trading hrs./1 hour per week during non-trading hrs. (All hours counted at LotusGroup Advisors are technically Martorello Money Management hours since Mr. Martorello’s salary is paid as a contractor through Martorello Money Management). 22  Mr. Martorello's outside business activities do not give him an incentive to recommend investment products based on anything other than a client’s needs. Nevertheless, the potential for receipt of commissions and other compensation can create a conflict of interest. It can provide an incentive for him to recommend products based on the compensation received rather than on the client’s needs. LotusGroup Advisors address this conflict of interest by requiring him to disclose such relationships to clients. Mr. Martorello satisfies this requirement by advising clients of the nature of transactions or associations, his role, and any compensation he received at the time of the relationship’s inception. Mr. Martorello acts in the best interest of clients. Clients are always in no way required to utilize the services of an Investment Advisor Representative of LotusGroup Advisors in connection with such individual's activities outside of LotusGroup Advisors. Additional Compensation The firm's advisors earn a base salary, with most earnings coming from an earned percentage of revenue share collected from client assets managed by the Adviser. Additionally, Mr. Martorello may earn an annual bonus for growing the overall business. Mr. Martorello passively invests in other private businesses, including golf courses, oil exploration, real estate, and private offerings that LGA sources on behalf of clients. Outside of those disclosed herein, he does not receive any additional compensation or economic benefit from any person, company, or organization in exchange for providing clients with advisory services through LotusGroup Advisors. Supervision LotusGroup Advisors takes its compliance and regulatory obligations seriously; supervision is a multi‐tiered process. Amanda N. Cohen is the firm’s Chief Compliance Officer (“CCO”). She oversees and administers the firm’s Compliance Program in coordination with the firm’s Principal and Managing Partner, Raphael A. Martorello. Mr. Martorello directly supervises the LotusGroup Management Team and collaborates on trade and investment decision activity with Ms. Schlemeyer. Raphael A. Martorello is self-supervised as it pertains to client service, investment strategy development, and execution. He is audited by the Firm’s CCO every quarter through LotusGroup’s “Access Person Review” to ensure all personal trades have not benefited at the expense of client trades. Covered Persons (“Associates”) are required to abide fully by all applicable federal and state regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code of Ethics (including any updates to them). LotusGroup Advisors require all Associates to exercise a fiduciary duty to clients by acting in each client’s best interest and always placing client interests first. Associates are required to attest no less than annually to their compliance with and understanding of the above matters, including confirmation and acknowledgment by every Investment Advisor Representative of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required of them. Requirements for State Registered Investment Advisers The following disclosure is provided for your use in evaluating this Investment Advisor Representative’s suitability. A. Raphael A. Martorello has not been involved in any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages over $2,500 involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: 23  theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. B. Raphael A. Martorello has not been the subject of a bankruptcy petition. 24  Form ADV Part 2B Brochure Supplement - Nicholas S. Pirnack, CEPA Investment Advisor Representative NICHOLAS S. PIRNACK, CEPA (Individual CRD #5717464) 1005 South Gaylord Street Denver, CO 80209 Email: info@lgadvisors.com Website: www.lgadvisors.com Phone: 720.325.2327 March 31, 2026 In accordance with federal and state regulations, Form ADV, Part 2B, this “Brochure Supplement” or “Brochure” is on file with the appropriate securities regulatory authorities as required. All the material within this Brochure Supplement must be reviewed by those who are considering becoming a Client of LotusGroup Advisors, LLC (“LotusGroup,” “LGA,” the “Firm,” the “Adviser,” “us,” “we,” or “our”). 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. The information provided in this Brochure is not to be construed as an endorsement or recommendation by state securities authorities in any jurisdiction within the United States or by the SEC. Nothing in this document is to be construed as an offer of securities; please refer to actual fund and investment offering documents for more complete disclosures. Registration of an Investment Advisor does not imply any level of skill or training; investments involve risk, including the possible loss of principal. The oral and written communications of an Adviser provide you with information you may use to determine whether to hire or retain an Adviser. This Brochure provides information about the above Investment Advisor Representative that supplements LotusGroup’s Firm ADV Brochure. You should have received a copy of the Firm’s ADV Brochure that describes the investment advisory services offered through LotusGroup Advisors, the Investment Adviser. Please contact LotusGroup Advisors CCO, Amanda N. Cohen, directly at 720.593.9861 if you did not receive the Firm’s ADV Brochure or if you have any questions about the contents of this Brochure Supplement. Additional information about Nicholas S. Pirnack is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select “Investment Advisor – Individual,” and type in the above Individual CRD #.) 25  NICHOLAS S. PIRNACK, CEPA Date of Birth & Educational Background Nicholas S. Pirnack was born in 1985. He received his B.A. Economics/Minor in Business from Colorado State University in 2009. Mr. Pirnack has fulfilled LotusGroup Advisor’s requirement that its Investment Advisor Representatives hold either a bachelor’s degree and further coursework (i.e., an MBA, a DFP, a CFA, a ChFC, JD, CTFA, EA, or CPA) or possess relevant work experience demonstrating their knowledge of and aptitude for investment management principles. Mr. Pirnack earned his Certified Exit Planning Advisor (“CEPA”) in February 2023. Business Background & Experience 10/2011 to Present LotusGroup Advisors, LLC, Denver, CO Partner, Senior Advisor & Investment Advisor Representative − Over ten years of total client management experience − Current oversight of Advising Team for the firm 08/2009 to 10/2011 Intersecurities, Fort Collins, CO Investment Advisor Representative − Client relationship management − Oversight of 2 advisors 04/2009 to 10/2011 CORE Financial/Transamerica, Fort Collins, CO Financial Advisor & Insurance Agent Professional Designations, Licensing & Exams Nicholas S. Pirnack earned his Certified Exit Planning Advisor (“CEPA”) professional designation in 2023. The CEPA credential is a professional designation for financial advisors and other professionals who wish to support business owners with transitioning out of their business. The professional designation is awarded by the Exit Planning Institute. More information about the CEPA professional designation is available at https://exit-planning-institute.org/. Disciplinary Information LotusGroup Advisors is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Nicholas S. Pirnack, providing advice to you. Mr. Pirnack does not have a disciplinary history to disclose, which may be material to a client’s or prospective client’s evaluation of this advisory business. There may be items contained on brokercheck.finra.org or www.adviserinfo.sec.gov that you may wish to review and consider in your evaluation of your Investment Advisor Representative’s background. Other Business Activities Nicholas S. Pirnack is a Senior Advisor and Investment Advisor Representative who provides advice directly to clients; he does not trade or make investment decisions. Mr. Pirnack dedicates 100% of his time to this activity during trading hours. Outside of his activities at LotusGroup Advisors, Mr. Pirnack also participates in the following investment-related other business activities: Name of Outside Business or Organization: Denver Children's Foundation Address: 8275 E 11th Ave #202684, Denver, CO 80220 Title: Board Director Description of Outside Business or Organization: For the past three decades from its roots as Denver Active 20-30, the Denver Children’s Foundation (DCF) has been changing the trajectories of children in Colorado through financial grants to organizations that directly support at-risk, disadvantaged children in our community. Description of Duties or Responsibilities: Serving a 1-year Director term in 2021-2022 after a 2-year term from 2019-2021, bringing strong expertise in event fundraising and organizational leadership. 26  Start Date: 04/2004 Hours Devoted to OBA Monthly: 0 during trading hrs./5 hour per week during non-trading hrs. Additional Compensation The firm's advisors earn a base salary, with most earnings coming from an earned percentage of revenue share collected from client assets managed by the advisor. Additionally, they may earn an annual bonus for meeting goals set forth by the company. In addition, advisors can earn a percentage of the management fee collected from IncomePlus Fund Class B investors to whom they provide investor relations assistance. Mr. Pirnack does not receive any additional economic benefit from any person, company, or organization in exchange for providing clients with advisory services through LotusGroup Advisors. Mr. Pirnack may earn a percentage of the fees due to LGA for each Business Valuation that he completes on behalf of LotusGroup Advisors. Mr. Pirnack does not receive any additional economic benefit from any person, company, or organization in exchange for providing clients with advisory services through LotusGroup Advisors. Supervision LotusGroup Advisors takes its compliance and regulatory obligations seriously; supervision is a multi‐tiered process. Amanda N. Cohen is the firm’s Chief Compliance Officer (“CCO”). She oversees and administers the firm’s Compliance Program in coordination with the firm’s Principal and Managing Partner, Raphael A. Martorello. Mr. Pirnack is directly supervised by Raphael A. Martorello (T: 720.593.9861), who oversees the advisory activities of all LotusGroup Investment Advisor Representatives Covered Persons (“Associates”) are required to abide fully by all applicable federal and state regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code of Ethics (including any updates to it). LotusGroup Advisors require all Associates to exercise a fiduciary duty to its clients by acting in each client’s best interest and always placing client interests first. Associates are required to attest no less than annually to their compliance with and understanding of the above matters, including confirmation and acknowledgment by every Investment Advisor Representative of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required of them. Requirements for State Registered Investment Advisers The following disclosure is provided for your use in evaluating this Investment Advisor Representative’s suitability. A. Nicholas S. Pirnack has not been involved in any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages over $2,500 involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. B. Nicholas S. Pirnack has not been the subject of a bankruptcy petition. 27  Form ADV Part 2B Brochure Supplement - Stephanie L. Schlemeyer Investment Advisor Representative STEPHANIE L. SCHLEMEYER (CRD #5795426) 1005 South Gaylord Street Denver, CO 80209 Email: info@lgadvisors.com Website: www.lgadvisors.com Phone: 720.897.8553 March 31, 2026 In accordance with federal and state regulations, Form ADV, Part 2B, this “Brochure Supplement” or “Brochure” is on file with the appropriate securities regulatory authorities as required. All the material within this Brochure Supplement must be reviewed by those who are considering becoming a Client of LotusGroup Advisors, LLC (“LotusGroup,” “LGA,” the “Firm,” the “Adviser,” “us,” “we,” or “our”). 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. The information provided in this Brochure is not to be construed as an endorsement or recommendation by state securities authorities in any jurisdiction within the United States or by the SEC. Nothing in this document is to be construed as an offer of securities; please refer to actual fund and investment offering documents for more complete disclosures. Registration of an Investment Advisor does not imply any level of skill or training; investments involve risk, including the possible loss of principal. The oral and written communications of an Adviser provide you with information you may use to determine whether to hire or retain an Adviser. This Brochure provides information about the above Investment Advisor Representative that supplements LotusGroup’s Firm ADV Brochure. You should have received a copy of the Firm’s ADV Brochure that describes the investment advisory services offered through LotusGroup Advisors, the Investment Adviser. Please contact LotusGroup Advisors CCO, Amanda N. Cohen, directly at 720.593.9861 if you did not receive the Firm’s ADV Brochure or if you have any questions about the contents of this Brochure Supplement. Additional information about Stephanie L. Schlemeyer is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select “Investment Advisor – Individual,” and type in the above Individual CRD #.) 28  STEPHANIE L. SCHLEMEYER Date of Birth & Educational Background Stephanie L. Schlemeyer was born in 1989. She received her B.A. Mathematics from Messiah College in 2011. Ms. Schlemeyer has fulfilled LotusGroup Advisor’s requirement that its Investment Advisor Representatives hold either a bachelor’s degree and further coursework (i.e., an MBA, a DFP, a CFA, a ChFC, JD, CTFA, EA, or CPA) or possess relevant work experience demonstrating their knowledge of and aptitude for, investment management principles. Business Background & Experience 01/2018 to Present LotusGroup Advisors, LLC, Denver, CO Partner, Product Manager & Investment Advisor Representative − Manage product toolset such as portfolio management system & reporting − Strategy development & management for public investment models − Public market research − Investment Committee Member on LGA IncomePlus Fund 02/2014 to 12/2018 LotusGroup Advisors, LLC, Denver, CO Senior Analyst, Portfolio Manager & Investment Advisor Representative - Manage investment models − Execute LotusGroup Advisors portfolio strategies − Conduct & assist with primary research on new public investment − opportunities & strategies Investment Advisor Representative 08/2011 to 01/2014 University of Colorado, Denver, CO Data Manager − Perform quality assurance tests on the data to maintain the integrity of the data & evaluate the progress of the programs at the individual grantee sites − Create & edit existing standard operating procedures − Data analysis & report writing for various projects Professional Designations, Licensing & Exams Stephanie L. Schlemeyer does not have any additional professional designations, licensing, or exams to disclose. Disciplinary Information LotusGroup Advisors is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Stephanie L. Schlemeyer, providing advice to you. Ms. Schlemeyer does not have a disciplinary history to disclose, which may be material to a client’s or prospective client’s evaluation of this advisory business. There may be items contained on brokercheck.finra.org or www.adviserinfo.sec.gov that you may wish to review and consider in your evaluation of your Investment Advisor Representative’s background. Other Business Activities Stephanie L. Schlemeyer is a Product Manager who leads the selection and implementation of LotusGroup’s portfolio management systems, collaborates on investment decisions, and executes trades on behalf of clients as needed. Ms. Schlemeyer dedicates 100% of her time to this activity during trading hours. Outside of her activities at LotusGroup, Ms. Schlemeyer has no other investment-related, other business 29  activities to disclose. Additional Compensation The product manager earns a base salary, with some earnings coming from a percentage of revenue share collected from client assets managed. Additionally, Ms. Schlemeyer can earn an annual bonus for meeting goals set forth by the company. Ms. Schlemeyer does not receive any additional economic benefit from any person, company, or organization in exchange for providing clients with advisory services through LotusGroup Advisors Supervision LotusGroup Advisors takes its compliance and regulatory obligations seriously; supervision is a multi‐tiered process. Amanda N. Cohen is the firm’s Chief Compliance Officer (“CCO”). She oversees and administers the firm’s Compliance Program in coordination with the firm’s Principal and Managing Partner, Raphael A. Martorello. Stephanie L. Schlemeyer is directly supervised by Raphael A. Martorello (T: 720.593.9861), who oversees all LotusGroup Investment Advisor Representatives' advisory activities. Covered Persons (“Associates”) are required to abide fully by all applicable federal and state regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code of Ethics (including any updates to them). LotusGroup Advisors require all Associates to exercise a fiduciary duty to its clients by acting in each client’s best interest and always placing client interests first. Associates are required to attest no less than annually to their compliance with and understanding of the above matters, including confirmation and acknowledgment by every Investment Advisor Representative of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required of them. Requirements for State Registered Investment Advisers The following disclosure is provided for your use in evaluating this Investment Advisor Representative’s suitability. A. Stephanie L. Schlemeyer has not been involved in any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages over $2,500 involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. B. Stephanie L. Schlemeyer has not been the subject of a bankruptcy petition. 30  Form ADV Part 2B Brochure Supplement – Brian W. McAuliffe Investment Advisor Representative BRIAN W. McAULIFFE (CRD #5795426) 1005 South Gaylord Street Denver, CO 80209 Email: info@lgadvisors.com Website: www.lgadvisors.com Phone: 847.802.2155 March 31, 2026 In accordance with federal and state regulations, Form ADV, Part 2B, this “Brochure Supplement” or “Brochure” is on file with the appropriate securities regulatory authorities as required. All the material within this Brochure Supplement must be reviewed by those who are considering becoming a Client of LotusGroup Advisors, LLC (“LotusGroup,” “LGA,” the “Firm,” the “Adviser,” “us,” “we,” or “our”). 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. The information provided in this Brochure is not to be construed as an endorsement or recommendation by state securities authorities in any jurisdiction within the United States or by the SEC. Nothing in this document is to be construed as an offer of securities; please refer to actual fund and investment offering documents for more complete disclosures. Registration of an Investment Advisor does not imply any level of skill or training; investments involve risk, including the possible loss of principal. The oral and written communications of an Adviser provide you with information you may use to determine whether to hire or retain an Adviser. This Brochure provides information about the above Investment Advisor Representative that supplements LotusGroup’s Firm ADV Brochure. You should have received a copy of the Firm’s ADV Brochure that describes the investment advisory services offered through LotusGroup Advisors, the Investment Adviser. Please contact LotusGroup Advisors CCO, Amanda N. Cohen, directly at 720.593.9861 if you did not receive the Firm’s ADV Brochure or if you have any questions about the contents of this Brochure Supplement. Additional information about Brian W. McAuliffe is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select “Investment Advisor – Individual,” and type in the above Individual CRD #.) 31  BRIAN W. McAULIFFE Date of Birth & Educational Background Brian W. McAuliffe was born in 1999. He received his Bachelor of Business Administration in Finance from Texas Christian University in 2021. Mr. McAuliffe has fulfilled LotusGroup Advisor’s requirement that its Investment Advisor Representatives hold either a bachelor’s degree and further coursework (i.e., an MBA, a DFP, a CFA, a ChFC, JD, CTFA, EA, or CPA) or possess relevant work experience demonstrating their knowledge of and aptitude for investment management principles. Business Background & Experience 09/2022 to Present LotusGroup Advisors, LLC, Denver, CO Investment Analyst & Investment Advisor Representative − Manage product toolsets such as portfolio management systems & reporting − Public market research and trading 06/2021 to 9/2022 Cigna, Denver, CO Risk and Underwriting Senior Analyst - Member of the Risk Management & Underwriting Leadership Development Program (RULDP) - Analyzed demographic and prior claim history datasets to determine profitable healthcare rates for companies - Actively negotiated rates and terms with sales and broker partners - Evaluated on-going health risk to determine the proper guidelines and measures to mitigate our book of business Professional Designations, Licensing & Exams Brian W. McAuliffe does not have any additional professional designations, licensing, or exams to disclose. Disciplinary Information LotusGroup Advisors is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Brian W. McAuliffe, providing advice to you. Mc. Auliffe does not have a disciplinary history to disclose, which may be material to a client’s or prospective client’s evaluation of this advisory business. There may be items contained on brokercheck.finra.org or www.adviserinfo.sec.gov that you may wish to review and consider in your evaluation of your Investment Advisor Representative’s background. Other Business Activities Mr. McAuliffe is an Investment Analyst who collaborates on investment decisions and executes trades on behalf of clients. Mr. McAuliffe dedicates 100% of her time to this activity during trading hours. Outside of her activities at LotusGroup Mr. McAuliffe has no other investment-related, other business activities to disclose. 32  Additional Compensation. The Investment Analyst earns a base salary, some earnings coming from a percentage of revenue share collected from client assets managed. Additionally, Mr. McAuliffe can earn an annual bonus for meeting goals set forth by the company. Mr. McAuliffe does not receive any additional economic benefit from any person, company, or organization in exchange for providing clients with advisory services through LotusGroup Advisors ‐ Supervision LotusGroup Advisors takes its compliance and regulatory obligations seriously; supervision is a multi tiered process. Amanda N. Cohen is the firm’s Chief Compliance Officer (“CCO”). She oversees and administers the firm’s Compliance Program in coordination with the firm’s Principal and Managing Partner, Raphael A. Martorello. Brian W. McAuliffe is directly supervised by Stephanie L. Schlemeyer (T: 720.593.9861). Covered Persons (“Associates”) are required to abide fully by all applicable federal and state regulations and the firm’s guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code of Ethics (including any updates to them). LotusGroup Advisors require all Associates to exercise a fiduciary duty to its clients by acting in each client’s best interest and always placing client interests first. Associates are required to attest no less than annually to their compliance with and understanding of the above matters, including confirmation and acknowledgment by every Investment Advisor Representative of the firm’s expectations regarding their conduct, given the duties, responsibilities, and principles required of them. Requirements for State Registered Investment Advisers The following disclosure is provided for your use in evaluating this Investment Advisor Representative’s suitability. A. Brian W. McAuliffe has not been involved in any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages over $2,500, involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. B. Brian W. McAuliffe has not been the subject of a bankruptcy petition. 33  Form ADV Part 2B Brochure Supplement – Samuel S. Redman Investment Advisor Representative Samuel S. Redman (Individual CRD # 6852142) 1005 South Gaylord Street Denver, CO 80209 Email: info@lgadvisors.com Website: www.lgadvisors.com Phone: 415.717.5878 March 31, 2026 In accordance with federal and state regulations, Form ADV, Part 2B, this "Brochure Supplement" or "Brochure" is on file with the appropriate securities regulatory authorities as required. All the material within this Brochure Supplement must be reviewed by those considering becoming a client of LotusGroup Advisors, LLC ("LGA"). The information in this Brochure Supplement has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. The information provided in this Brochure Supplement is not to be construed as an endorsement or recommendation by state securities authorities in any jurisdiction within the United States or by the United States Securities and Exchange Commission. Nothing in this Brochure Supplement is to be construed as an offer of securities; please refer to actual fund and investment offering documents for more complete disclosures. Registration of an Investment Advisor does not imply any level of skill or training; investments involve risk, including the possible loss of principal. The oral and written communications of an Advisor provide you with information that you can use to determine whether to hire or retain an Advisor. This Brochure Supplement provides information about Samuel S. Redman that supplements LotusGroup Advisors' Form ADV Part 2A Disclosure Brochure. You should have received a copy of the Firm's Brochure that describes the investment advisory services offered through LotusGroup Advisors, an investment advisory firm. Please contact LotusGroup Advisors’ CCO, Amanda N. Cohen, directly at 720.593.9861 if you did not receive the Firm's Brochure or have any questions about the contents of this Brochure Supplement. Additional information about Samuel S. Redman is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Advisor – Individual," and type in the individual CRD #.) 34  SAMUEL S. REDMAN Date of Birth & Educational Background Samuel S. Redman was born in 1994. He received his bachelor’s degree in business administration with concentrations in Corporate Finance and Investment Analysis in 2017. He has fulfilled LotusGroup Advisors’ requirement that its Investment Advisor Representatives ("IARs") hold either a bachelor's degree or further coursework (i.e., an MBA, a DFP, a CFA, a ChFC, JD, CTFA, EA, or CPA), or possess relevant work experience demonstrating their knowledge of and aptitude for, investment management principles. Business Background & Experience 06/2024 to Present LotusGroup Capital, LLC, Denver, CO Director of Alternative Assets & Investment Advisor Representative - Manages processes, as well as third-party services, custodians, and administrators. - Conducts private investment partner due diligence. - Negotiates strategic terms and finalizes contracts/relationships. - Maintains ongoing relationship management with private partners. - Conducts industry research. 06/2024 to Present LotusGroup Advisors, LLC, Denver, CO Investment Advisor Representative - Provides ongoing relationship management with private investment partners. - Participates in authoring investment blogs. - Registered as an Investment Advisor Representative. 12/2022 to 03/2024 Fidelity Investments, Denver, CO Involvement with downstream trading processes and resolving daily issues. Trader – Digital Assets - Execution and maintaining exposures to express investment views. - - Overview of compliance with trading processes. - Built and maintained tools to enhance trading efficiency. - Monitoring, reviewing, and reporting trading execution quality. 08/2017 to 07/2022 Black Swift Group, Boulder, CO Managing Director Directed multiple facets of key investment management functions and related operations for six private funds, million-dollar client portfolios and alternative investment opportunities. Associate Portfolio Manager - Supervised and provided strategic investment recommendations and research observations directly to the CIO/PM while offering support to the investment and operations/client service staff members. Associate Vice President of Trading - - Managed multiple asset classes for investors from private investments, public equities, and structured credit; discovered, executed, and processed multi-asset trades for all clients and private funds. Investment Analyst Responsible for research and operations work across the RIA business as well as multiple funds across asset classes. 35  Professional Designations, Licensing & Exams Samuel S. Redman does not have any additional professional designations, licensing, or exams to disclose. Disciplinary Information LotusGroup Advisors is required to disclose all material facts regarding any legal or disciplinary event material to your evaluation of Samuel S. Redman, providing advice to you. Mr. Redman does not have a disciplinary history to disclose, which can be material to a client's or prospective client's evaluation of this advisory business. There may be items on brokercheck.finra.org or www.adviserinfo.sec.gov that you can review and consider in assessing your advisor representative's background. Other Business Activities Samuel S. Redman is involved with LotusGroup Advisors affiliated Registered Investment Adviser, LotusGroup Capital, LLC, where he serves as Director of Alternative Assets. Mr. Redman generally splits his time and job functions between LotusGroup Capital (80%) and LotusGroup Advisors (20%). Mr. Redman is not currently engaged in any outside business activities externally from LotusGroup Advisors and LotusGroup Capital that take a significant amount of time or generate a significant amount of income. Conflicts of Interest Disclosure The shared duties of Samuel S. Redman within LotusGroup’s affiliated adviser entities do not give him an incentive to recommend investment products based on anything other than a client's needs. Further, at this time Mr. Redman does not have additional outside business activities that could create such conflicts. Nevertheless, LotusGroup Advisors requires him to disclose the above relationships to clients at the inception of the relationship. Additional Compensation The Investment Advisor Representative earns a base salary, with additional compensation available as a percentage of the revenue share collected from Client accounts for private investments, a percentage of the revenue share generated from Firm advisory Clients, and a percentage share of the management fees collected for the IncomePlus Funds Class B interests. ‐ Supervision tiered process. LotusGroup Advisors takes its compliance and regulatory obligations seriously; supervision is a multi Amanda N. Cohen is the Firm's Chief Compliance Officer ("CCO"). She oversees and administers the Firm's Compliance Program in coordination with the efforts of the Firm's Principal and Managing Member, Raphael A. Martorello. Covered Persons are required to abide fully by all applicable federal and state regulations and the Firm's guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code of Ethics (including any updates to it). LotusGroup Advisors requires all Covered Persons to exercise a fiduciary duty to its clients by acting in each client's best interest and always placing client interests first. Covered Persons are required to attest no less than annually to their compliance with, and understanding of, the above matters, including confirmation and acknowledgment by every Investment Advisor Representative, of the Firm's expectations regarding their conduct, given the duties, responsibilities, and principles required of them. Requirements for State Registered Investment Advisers The following disclosure is provided for your use in evaluating this Investment Advisor Representative's suitability. A. Samuel S. Redman has not been involved in any of the events listed below. 36  1. An award or otherwise being found liable in an arbitration claim alleging damages over $2,500, involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. B. Samuel S. Redman has not been the subject of a bankruptcy petition. 37  Form ADV Part 2B Brochure Supplement – Keaton H. Hamilton Investment Advisor Representative Keaton H. Hamilton (Individual CRD # 5027203) 1005 South Gaylord Street Denver, CO 80209 Email: info@lgadvisors.com Website: www.lgadvisors.com Phone: 949.370.7540 March 31, 2026 In accordance with federal and state regulations, Form ADV, Part 2B, this "Brochure Supplement" or "Brochure" is on file with the appropriate securities regulatory authorities as required. All the material within this Brochure Supplement must be reviewed by those considering becoming a client of LotusGroup Advisors, LLC ("LGA"). The information in this Brochure Supplement has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. The information provided in this Brochure Supplement is not to be construed as an endorsement or recommendation by state securities authorities in any jurisdiction within the United States or by the United States Securities and Exchange Commission. Nothing in this Brochure Supplement is to be construed as an offer of securities; please refer to actual fund and investment offering documents for more complete disclosures. Registration of an Investment Advisor does not imply any level of skill or training; investments involve risk, including the possible loss of principal. The oral and written communications of an Advisor provide you with information that you can use to determine whether to hire or retain an Advisor. This Brochure Supplement provides information about Keaton H. Hamilton that supplements LotusGroup Advisors' Form ADV Part 2A Disclosure Brochure. You should have received a copy of the Firm's Brochure that describes the investment advisory services offered through LotusGroup Advisors, an investment advisory firm. Please contact LotusGroup Advisors’ CCO, Amanda N. Cohen, directly at 720.593.9861 if you did not receive the Firm's Brochure or have any questions about the contents of this Brochure Supplement. Additional information about Keaton H. Hamilton is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Advisor – Individual," and type in the individual CRD #.) 38  KEATON H. HAMILTON Date of Birth & Educational Background Keaton H. Hamilton was born in 1983. She received her bachelor’s degree in Finance and International Business in 2005. She has fulfilled LotusGroup Advisors’ requirement that its Investment Advisor Representatives ("IARs") hold either a bachelor's degree or further coursework (i.e., an MBA, a DFP, a CFA, a ChFC, JD, CTFA, EA, or CPA) or possess relevant work experience demonstrating their knowledge of and aptitude for investment management principles. Business Background & Experience 10/2024 to Present LotusGroup Advisors, LLC, Denver, CO Investment Advisor Representative - Provides ongoing relationship management with private investment partners. - Participates in authoring investment blogs. - Registered as an Investment Advisor Representative. 10/2023 to 10/2024 Bonfire Financial, LLC, Colorado Springs, CO Advisor - Provided ongoing relationship management with private investment partners. - Registered as an Investment Advisor Representative. 2016 to 2017 First Foundation Advisors, Irvine, CA Associate Wealth Advisor - Provided ongoing relationship management with private investment partners. - Registered as an Investment Advisor Representative. 2012 to 2016 HPM Partners, Costa Mesa, CA Vice President - Provided ongoing relationship management with private investment partners. - Registered as an Investment Advisor Representative. 2006 to 2015 Deutsche Bank Securities, Inc, Costa Mesa, CA Assistant Vice President - Provided ongoing relationship management with private investment partners. - Registered as an Investment Advisor Representative. 2005 to 2006 Smith Barney, Newport Beach, CA Client Service Associate - Facilitated the opening, transferring and consolidation of new accounts. Professional Designations, Licensing & Exams Keaton H. Hamilton does not have any additional professional designations, licensing, or exams to disclose. 39  Disciplinary Information LotusGroup Advisors is required to disclose all material facts regarding any legal or disciplinary material to your evaluation of Keaton H. Hamilton, providing advice to you. Mrs. Hamilton does not have a disciplinary history to disclose, which can be material to a client's or prospective client's evaluation of this advisory business. There may be items on brokercheck.finra.org or www.adviserinfo.sec.gov that you can review and consider in assessing your advisor representative's background. Other Business Activities Keaton H. Hamilton does not have any other business activity to disclose. Conflicts of Interest Disclosure The shared duties of Keaton H. Hamilton within LotusGroup’s affiliated adviser entities do not give her an incentive to recommend investment products based on anything other than a client's needs. Further, at this time Mrs. Hamilton does not have additional outside business activities that could create such conflicts. Additional Compensation The Investment Advisor Representative earns a base salary, with some earnings coming from a percentage of revenue collected from client assets managed. As an advisor, she earns a percentage of the revenue collected from client assets managed by the advisor. Additionally, an advisor can make a one-time revenue share for the new clients brought to the firm, paid quarterly on collected payments, and may earn an annual bonus for meeting goals set forth by the company. Mrs. Hamilton does not receive any additional economic benefit from any person, company, or organization in exchange for providing clients with advisory services through LotusGroup Advisors. ‐ Supervision LotusGroup Advisors takes its compliance and regulatory obligations seriously; supervision is a multi tiered process. Amanda N. Cohen is the Firm's Chief Compliance Officer ("CCO"). She oversees and administers the Firm's Compliance Program in coordination with the efforts of the Firm's Principal and Managing Member, Raphael A. Martorello. Covered Persons are required to abide fully by all applicable federal and state regulations and the Firm's guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code of Ethics (including any updates to it). LotusGroup Advisors requires all Covered Persons to exercise a fiduciary duty to its clients by acting in each client's best interest and always placing client interests first. Covered Persons are required to attest no less than annually to their compliance with, and understanding of, the above matters, including confirmation and acknowledgment by every Investment Advisor Representative, of the Firm's expectations regarding their conduct, given the duties, responsibilities, and principles required of them. Requirements for State Registered Investment Advisers The following disclosure is provided for your use in evaluating this Investment Advisor Representative's suitability. C. Keaton H. Hamilton has not been involved in any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages over $2,500, involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: 40  theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. D. Keaton H. Hamilton has not been the subject of a bankruptcy petition. 41  Form ADV Part 2B Brochure Supplement – Xavier Lewis Investment Advisor Representative Xavier Lewis (CRD #6581492) 1005 South Gaylord Street Denver, CO 80209 Email: info@lgadvisors.com Website: www.lgadvisors.com Phone: 720.402.4939 March 31, 2026 In accordance with federal and state regulations, Form ADV, Part 2B, this "Brochure Supplement" or "Brochure" is on file with the appropriate securities regulatory authorities as required. All the material within this Brochure Supplement must be reviewed by those considering becoming a client of LotusGroup Advisors, LLC ("LGA"). The information in this Brochure Supplement has not been approved or verified by the United States Securities and Exchange Commission ("SEC") or by any state securities authority. The information provided in this Brochure Supplement is not to be construed as an endorsement or recommendation by state securities authorities in any jurisdiction within the United States or by the United States Securities and Exchange Commission. Nothing in this Brochure Supplement is to be construed as an offer of securities; please refer to actual fund and investment offering documents for more complete disclosures. Registration of an Investment Advisor does not imply any level of skill or training; investments involve risk, including the possible loss of principal. The oral and written communications of an Advisor provide you with information that you can use to determine whether to hire or retain an Advisor. This Brochure Supplement provides information about Xavier Lewis that supplements LotusGroup Advisors' Form ADV Part 2A Disclosure Brochure. You should have received a copy of the Firm's Brochure that describes the investment advisory services offered through LotusGroup Advisors, an investment advisory firm. Please contact LotusGroup Advisors’ CCO, Amanda N. Cohen, directly at 720.593.9861 if you did not receive the Firm's Brochure or have any questions about the contents of this Brochure Supplement. Additional information about Xavier Lewis is available on the SEC's website at www.adviserinfo.sec.gov. (Click on the link, select "Investment Advisor – Individual," and type in the individual CRD #.) 42  XAVIER LEWIS Date of Birth & Educational Background Xavier Lewis was born in 1989. He received his bachelor’s degree in finance & management in 2013 from Washburn University. He has fulfilled LotusGroup Advisors’ requirement that its Investment Advisor Representatives ("IARs") hold either a bachelor's degree or further coursework (i.e., an MBA, a DFP, a CFA, a ChFC, JD, CTFA, EA, or CPA) or possess relevant work experience demonstrating their knowledge of and aptitude for, investment management principles. Business Background & Experience 2/2025 to Present LotusGroup Advisors, LLC, Denver, CO Investment Advisor Representative - Provides ongoing relationship management with private investment partners. - Participates in authoring investment blogs. - Registered as an Investment Advisor Representative. 11/2015 – 02/25 Trilogy Financial Services Wealth Advisor - Registered as an Investment Advisor Representative. - Provided Financial Investment and Life Insurance Planning - Partnered with clients to develop comprehensive Financial Plans. - Managed 130+ client households - Provided initial and ongoing service for clients and households. Professional Designations, Licensing & Exams Xavier Lewis holds a license to sell Life Insurance Products in the State of Colorado. He does not have any additional professional designations, licensing, or exams to disclose. Disciplinary Information LotusGroup Advisors is required to disclose all material facts regarding any legal or disciplinary material to your evaluation of Xavier Lewis, providing advice to you. Mr. Lewis does not have a disciplinary history to disclose, which can be material to a client's or prospective client's evaluation of this advisory business. There may be items on brokercheck.finra.org or www.adviserinfo.sec.gov that you can review and consider in assessing your advisor representative's background. Other Business Activities Name of Outside Business Organization: Cherry Creek Chamber of Commerce. Title: YP Board President (2020-2023), Executive Board Member (2022-Present) Description of Outside Business Organization: Chamber of Commerce. Description of Duties or Responsibilities: Board Financial Committee attend monthly meetings and events – Report, track, and balance budgets. Profit/Loss, Membership, and event financials. Start Date: 01/2018 Hours Devoted to OBA Monthly: Approximately 3-4 hours per month. Name of Outside Business Organization: Colorado Financial Planners Association. Title: NextGen Committee Member Description of Outside Business Organization: Financial Planning Organization focused on connecting and strengthening future financial professionals. Description of Duties or Responsibilities: Attend Committee Meetings, plan events and engage prospects with new ideas and opportunities. Start Date: 01/2025 Hours Devoted to OBA Monthly: Approximately 1-3 hours per month. Name of Outside Business Organization: Mili Software, Inc. Title: Consultant 43  Description of Outside Business Organization: AI Note taker for Financial Professionals. Description of Duties or Responsibilities: Consulting for design and performance updates Start Date: 04/2024 Hours Devoted to OBA Monthly: 1-2 hours per month. Name of Outside Business Organization: Simplicity UFC Title: Life Insurance Sales Description of Outside Business Organization: Life Insurance sales group Description of Duties or Responsibilities: Provide insurance sales services, participates in selling Life Insurance products. Start Date: 8/1/2025 Hours Devoted to OBA Monthly: 20 hours per month. Conflicts of Interest Disclosure The shared duties of Xavier Lewis within LotusGroup’s affiliated adviser entities do not give him an incentive to recommend investment products based on anything other than a client's needs. Mr. Lewis holds a license to sell Life Insurance Products in the State of Colorado. He participates in an outside business insurance sales activity at Simplicity UFC that sells Life Insurance products, which may conflict with his Investor Advisor Representative duties at LotusGroup Advisors given the life settlement investment strategies provided by LotusGroup Advisors. Mr. Lewis may offer certain investment products to clients that may provide a form of additional compensation to him outside of the compensation he may receive for providing Investment Advisor Representative services at LotusGroup Advisors. Additional Compensation The Investment Advisor Representative earns a base salary, with some earnings coming from a percentage of revenue collected from client assets managed. As an advisor, he earns a percentage of the revenue collected from client assets managed by the advisor. Additionally, an advisor can make a one-time revenue share for the new clients brought to the firm, paid quarterly on collected payments, and may earn an annual bonus for meeting goals set forth by the company. Mr. Lewis may also receive economic benefits from his Life Insurance Sales role at Simplicity UFC, as he may receive a sales commission on selling Life Insurance Products through his State of Colorado Life Insurance Sales license. ‐ Supervision tiered process. LotusGroup Advisors takes its compliance and regulatory obligations seriously; supervision is a multi Amanda N. Cohen is the Firm's Chief Compliance Officer ("CCO"). She oversees and administers the Firm's Compliance Program in coordination with the efforts of the Firm's Principal and Managing Member, Raphael A. Martorello. Covered Persons are required to abide fully by all applicable federal and state regulations and the Firm's guiding principles as outlined in its written supervisory Policies & Procedures Manual and Code of Ethics (including any updates to it). LotusGroup Advisors requires all Covered Persons to exercise a fiduciary duty to its clients by acting in each client's best interest and always placing client interests first. Covered Persons are required to attest no less than annually to their compliance with, and understanding of, the above matters, including confirmation and acknowledgment by every Investment Advisor Representative, of the Firm's expectations regarding their conduct, given the duties, responsibilities, and principles required of them. Requirements for State Registered Investment Advisers The following disclosure is provided for your use in evaluating this Investment Advisor Representative's suitability. E. Xavier Lewis has not been involved in any of the events listed below. 1. An award or otherwise being found liable in an arbitration claim alleging damages over $2,500, involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) 44  d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. 2. An award or otherwise being found liable in a civil, self-regulatory organization, or administrative proceeding involving any of the following: theft, embezzlement, or other wrongful taking of property; a) an investment or an investment-related business or activity; b) fraud, false statement(s), or omissions; c) d) bribery, forgery, counterfeiting, or extortion; or e) dishonest, unfair, or unethical practices. F. Xavier Lewis has not been the subject of a bankruptcy petition. 45