PROMUS ADVISORS

PROMUS ADVISORS CRD# 157484 8226 Douglas Avenue, Suite 650 Dallas, Texas 75225 214‐612-5750 FORM ADV PART 2A BROCHURE March 27, 2026 This Brochure provides information about the qualifications and business practices of Promus Asset Management, LLC, doing business as Promus Advisors. If you have any questions about the contents of this Disclosure Brochure, contact us at 214-612-5750. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Promus Advisors is available on the SEC's website at www.adviserinfo.sec.gov. The CRD # for Promus Advisors is 157484. Promus Advisors is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. 1  Item 2 – Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since our last annual updating amendment dated March 9, 2026, we have amended this Brochure with the following material changes: This Brochure was updated with enhanced disclosure on our firm’s financial planning services and corresponding fees. Please refer to Item 4 (Advisory Business) and Item 5 (Fees and Compensation) for more information. This Brochure was amended with additional disclosures on the qualified custodians whom we recommend to clients for custodial and brokerage service. Please refer to Item 12 (Brokerage Practices) for more information. Please contact us if you have any questions about this Brochure or if you would like to receive a complete copy of our current brochure free of charge at any time, please find our contact information on the cover page of this Brochure. 2  Item 3 ‐Table of Contents ITEM NO. SECTION TITLE PAGE Item 1 1 Cover Page Material Changes 2 Item 2 Item 3 Table of Contents 3 Item 4 Advisory Business 4 Item 5 Fees and Compensation 5 Item 6 Performance-Based Fees and Compensation Side-by-Side Management 7 Item 7 Types of Clients 8 8 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss Disciplinary Information 9 Item 9 Item 10 Other Financial Industry Activities and Affiliations 9 Item 11 Code of Ethics 10 Item 12 Brokerage Practices 10 Item 13 Review of Accounts 11 Item 14 Client Referrals and Other Compensation 12 Custody 12 Item 15 Item 16 Investment Discretion 12 Item 17 Voting Client Proxies 12 Item 18 13 Financial Information 3  Item 4 – Advisory Business Promus Advisors is a Texas based investment management and advisory firm providing comprehensive investment management services. Promus Advisors will offer discretionary and non-discretionary investment advisory services to individuals, businesses, trusts, estates, retirement plans, endowments and foundations, and financial planning, investment consulting with respect to asset allocation, portfolio diversification, portfolio risk, and other general economic and financial topics. As part of our standard services, we typically monitor client accounts daily. Investment advisory services are guided by the objectives or restrictions outlined in each client’s investment management agreement (IMA) and or investment policy statement (IPS). Clients can restrict investment in certain securities or types of securities in their account, as well as providing guidance and direction with respect to the securities maintained, purchased and sold in their account. Promus Advisors may recommend alternative investments such as pooled investment vehicles, hedge funds, private equity funds, limited partnerships, one or more third-party investment manager, active or passive portfolio strategies offered through its non-US affiliate, Bellwether Investment Management, Inc. (“Bellwether”). These portfolios may be traded through an affiliate investment adviser of Bellwether. You will pay a fee to Bellwether in addition to those charged by Promus. Third-party investment managers recommended to clients will have full investment discretion and trading authority over that portion of a client’s account and shall have sole responsibility for the implementation of the third-party strategy’s investment objectives. With respect to the assets held in portfolios managed by third-party investment managers, Promus Advisors will not place orders for transactions in that portion of the client’s account or otherwise exercise trading authority over the third-party account. Promus Advisors routinely monitors the third-party investment managers by a meritocratic management approach. This method emphasizes selection, promotion (or termination), and evaluation of managers based on their demonstrable abilities, performance metrics, and ongoing results. Promus Advisors will perform account monitoring, including contributions/withdrawals, custodian reconciliations, and service requests such as tax loss harvesting Promus Advisors provides an array of personal financial planning services in addition to investment management. Such services include, but are not limited to, business planning, retirement planning, financial planning, personal tax and cash flow planning, estate planning, insurance planning, marriage and divorce planning, college planning, compensation and benefits planning, and the preparation of financial analyses and personal financial statements reflecting net worth, cash flow and debt management, and income tax projections. Financial planning services may be provided as a stand-alone service or as part of the Firm’s investment advisory services. Joshua J. Prince, President, and Robert D. Sewell, CEO, will continue the vision under which Promus Advisors was founded in 2011 to provide investment management services to its clients. To engage, encourage and empower families to define, plan and create their family legacy, through planning, preparation and proper wealth management. Promus Advisors works with its clients to accomplish their goals through integrity, independence and objectivity. As of December 31, 2025, the firm has assets under management of $384,624,254 for 260 accounts. Promus Advisors seeks lifetime clients not simply transactions. The firm believes that with fewer clients, there is quality time available to spend with each client, cultivating deeper client relationships. Promus Advisors recognizes investors want a “trusted advisor” free of conflict. Investors seek conflict-free choices and demand that their advisors have an ability to suggest all suitable solutions, with confidence, and to know the advice received is free of motivation for personal gain or compensation. The firm believes that an advisor, no matter what the planning objective is at hand, should provide servant advice, free of compensation conflict, regardless of the economic environment. Promus Advisors attempts to model this emphatic and unwavering public request with unmatched: 4  • Independence – Promus Advisors strives to remain independent of conflict while serving its clients. Where an unavoidable conflict of interest occurs, Promus Advisors will fully disclose and fairly manage, in our client’s favor, any such unavoidable conflict of interest that may arise during the engagement of the firm. An example of an unavoidable potential conflict of interest could be that the firm receives free products or services other than execution from custodians. • Objectivity – The advice and services provided by Promus Advisors to its clients will be based on • objectivity and impartiality. The best interests of the client will always be the sole criterion for any advice or services provided to the client. Integrity – Promus Advisors recognizes that integrity and honesty are essential characteristics for a long- term relationship with a client. Promus Advisors is committed to ensuring client trust and confidence by the firm’s commitment to ethical and honest business practices. Clients engage Promus Advisors to provide professional management of the challenges and complexities of growing and protecting a family’s assets for generations: Integrate and prioritize strategies outlined above & develop an action plan to implement. • Develop an investment plan, prioritize goals, review and analyze financial statements. • • On-going review and assessment of assumptions incorporating given changes in economic, political and regulatory environment. • Understand the client’s total financial situation, including both short‐ and long‐ term goals, to achieve results for today and in the future. Returns on investments, income needs, risk tolerance, and investment objectives are regularly assessed. • Create and manage a diversified investment Portfolio from a variety of investment choices, unbiased by the source or structure of the investment product or choice. • Collaborate and coordinate with other professionals on decisions that affect the overall wealth management plan, including estate planning attorneys, insurance agents, and tax advisors. • Provide periodic monitoring and review of progress towards the achievement of the client’s goals and objectives. • The firm will offer its services on a discretionary basis, whereby it has authority granted by the client as to the securities to be purchased or sold and the amount of securities to be purchased or sold within a client's account. • The firm will manage client assets on a discretionary basis approved by the client. Note: Clients may impose restrictions on the type of securities invested in the client's account. However, since the firm utilizes mutual funds and other managed portfolios, the client may not restrict the individual securities invested. Item 5 – Fees and Compensation - Advisory Fees For its investment management services, Promus Advisors charges an asset-based fee on the total market value of the client’s assets under management with Promus Advisors. Promus Advisors may elect to receive a fixed fee, hourly rate or a percentage of assets under management for its investment management fee, on any product, or other services performed by Promus Advisors. The following is the firm's fee schedule: Promus Advisors typically receives annual fees based on a percentage of a Client's Portfolio. We may elect to receive a fixed fee or a percentage of assets under management on any products. It would be unfair to assume all clients fit into this one-price-fits-all fee arrangement. In certain unique instances, an alternative fee may be negotiated with a client depending on the facts and circumstances. As such, this fee varies depending on the size and complexity of each client's needs. The firm considers the total value of all of Client’s accounts in applying its minimum annual fee. 5  PROMUS ADVISORS Portfolio Strategy Asset Allocation Investment Policy Custodian Selection Manager Selection FEE SCHEDULE 1.00% ANNUAL FEE ON FIRST $1,000,000 0.75% ANNUAL FEE FROM $1,000,001- $3,000,000 0.65% ANNUAL FEE FROM $3,000,001- $5,000,000 0.55% ANNUAL FEE FROM $5,000,001- $10,000,000 0.45% ANNUAL FEE OVER $10,000,000 ANNUAL FEE EXAMPLES Client’s Portfolio $500,000 $5,000,000 $15,000,000 $25,000,000 Fee $5,000 $38,000 $88,000 $133,000 Investment management fees are calculated using a muti-tiered fee schedule with breakpoints that are applied on a blended basis. This blended fee schedule is used to calculate your fee by weighing your aggregate account value for breakpoints. Householding: Client may elect to aggregate the amounts in the accounts held directly by Client or for the benefit of a spouse, parent, child, or any extended family member for fee calculation purposes. These accounts are deemed to be in the same “Household” and the aggregation process is referred to as “householding” related aggregated accounts. Householding related accounts may collectively qualify the accounts for a fee breakpoint and elimination of minimum fee. The fee breakpoints are set forth in the fee schedules above based on the account value. Householding related accounts does not authorize others in Client’s household to conduct transactions in Client’s account. Third Party Cost: In addition to the fees charged by Promus Advisors, clients may be responsible for additional expenses, such as brokerage fees, commissions, mark-ups and mark-downs, custody fees, tax preparation fees and fees and expenses charged by unaffiliated custodians, as well as investment management fees charged by third- party mutual funds, pooled investment vehicles, and third-party managers. Account assets invested in these types of investment vehicles will be included in calculating the value of the account for purposes of computing the fee Promus Advisors charges for the investment advisory services it provides, and the same assets will also be subject to additional fees and expenses, as set forth in the offering documents of those investment vehicles, including, for example, third party manager fees, if applicable. Investment management fees are assessed and invoiced quarterly in advance following each calendar quarter. Each invoice is presented to the client at the time instructions are presented to the independent custodian to deduct management fees directly from their managed account as per each client’s written authorization. The fees are collected from the client's account carried with the custodian, based on the client's written authorization. 6  When the firm is initially retained, the fee is calculated proportionately with respect to the number of days remaining in the quarter and based on the market value of the Portfolio as of the effective date of the client’s execution of the investment management agreement (IMA) with the firm. Each client has the right to cancel the IMA for complete credit of all management fees accrued within five (5) business days after execution. After the five (5) business day period, the IMA may be terminated by either party by giving thirty (30) days’ written notice. The client will receive a pro‐rata portion of the prepaid fee based on the days remaining in the applicable quarter. For stand-alone ongoing financial planning services, Promus Advisors generally charges a fixed annual fee ranging up to $30,000, depending on the scope and complexity of the services to be provided, as well as the client’s individual circumstances. The annual fee is quoted annually, and billed monthly in arrears. Promus Advisors, in its sole discretion, may negotiate fees or enter into alternative fee arrangements, including project-based services and fees, based on various factors, including the nature of the services, anticipated time and resources required, and other relevant considerations. Financial planning services may be terminated by either party upon written notice to the other. All terms of the financial planning engagement will be detailed in an agreement between the Client and Promus Advisors. Additional Fees and Expenses Clients are responsible for additional fees and expenses. These fees and expenses may be for: Platform fees assessed for providing services such as account reconciliation, billing and performance reporting assessed by the independent custodian. In these cases, the client should consult the custodian's disclosure documents. Customary custodian and transaction clearing fees and expenses such as bank fees, margin interest fees, and national securities exchange fees, wire transfer fees or other costs or fees associated with securities transactions. In these cases, the client should consult the custodian's disclosure documents. Mutual fund fees and expenses, including Client funds awaiting investment that may be placed in a money market fund that may have internal investment management fees and expenses. In these cases, the client should consult the mutual funds prospectus. Promus Advisors does not: Share in any of these additional fees and expenses. Receive any “soft dollar benefits” for any service or research except those noted in Item 12 and eligible pursuant to 28(e) of the Securities and Exchange Act of 1934. Receive any 12b-1 service fees on any mutual funds. Client transactions are conducted on a fully disclosed agency basis. Item 6 – Performance‐Based Fees and Side‐By‐Side Management Promus Advisors does not charge a performance‐based fee, nor does it conduct Side-By-Side Management. A Performance-based fee permits the investment manager to share in the capital gains or capital appreciation of the assets of a client. 7  Item 7 – Types of Clients Promus Advisors serves a variety of clients, including but not limited to, individuals, businesses, trusts, estates, retirement plans, endowments and foundations. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss The Promus Advisors investment philosophy has a fundamental orientation based primarily upon the value investing principles described below: Promus Advisors invests with asset managers that are primarily driven by fundamental, bottom-up security analysis. This means attention is focused on a specific company rather than on the industry in which the company operates or on the economy. Promus Advisors focuses on value‐oriented investment funds and strategies, those in which Promus Advisors believes the financial market has undervalued. This results in opportunities to profit by buying when the market has undervalued an investment. While Promus Advisors typically utilizes active managers, Promus Advisors does allocate portions of the Portfolio to less active managers and index/ETF funds when appropriate for a particular client. Promus Advisors believe in the value of alternative investment strategies that add correlation benefits to a Portfolio of traditional equity and fixed income strategies. This correlation is a statistical measure of how two securities move in relation to each other. In theory, when one class of securities falls another class of securities may rise in market value. Promus Advisors seek out niche, opportunistic strategies within both traditional and non‐traditional asset classes and allocates certain portions of the Portfolio to these niches while maintaining core holdings of equity and fixed income investments. Promus Advisors use various methods and sources to select managers and investment ideas. These methods and sources include third party research, existing manager relationships, database searches, networking with a wide array of other investment professionals, including family offices and other investment advisors, and information gathered from clients and prospective clients. Promus Advisors also utilizes insight and ideas obtained from macroeconomic research, periodicals, news media and numerous investment letters from firms whose various strategies span the investing universe. Additional research tools and methods used for investment analysis will be used depending upon client’s needs and objectives. Diversification is a cornerstone of the Promus Advisors investment philosophy. This philosophy is based on the principle that asset allocation decisions are the largest contributor of risk and return in any given investment strategy. Promus Advisors allocates the assets in a Portfolio to cash, equities, fixed income and alternative investments. Promus Advisors also utilizes the “endowment model” of investing, which further allocates a Portfolio to specific hedge fund strategies, private equity investments, and real estate and natural resources investments. However, in any Portfolio allocation, Promus Advisors is mindful of liquidity constraints and other constraints regarding various alternative strategies and, therefore, Portfolio allocations are always based on what is suitable for a particular client. Asset allocation decisions are unique to each client and are based on several factors. At the beginning of each client relationship, Promus Advisors assesses the objectives and needs of each client based broadly on their assets, liabilities, income needs, and goals. In this process the clients’ preferences and risk tolerance are identified and 8  clarified. The projected return on investment for the Portfolio is based on a variety of factors, such as broad historical index returns, risks and correlations. Of course, Promus Advisors does not guarantee the future performance of the Portfolio or any specific level of performance in the Portfolio, the success of any asset management firm that Promus Advisors may select, or the success of Promus Advisors’ overall management of the Portfolio. The investment decisions and recommendations Promus Advisors makes for the Portfolio are subject to various market, currency, economic, political and business risks and conditions. The investment decisions made by Promus Advisors and/or the asset management firms that Promus Advisors selects will not always be profitable. Investing in securities involves the risk of loss that clients should always be prepared to bear. Item 9 - Disciplinary Information Registered investment advisors are required to disclose all material facts regarding any legal or disciplinary events that would be material to the evaluation of Promus Advisors or its management. Neither Promus Advisors, Joshua J. Prince, or any investment advisor have any disciplinary information to disclose; no legal or disciplinary actions to disclose, and neither the firm, Joshua J. Prince, nor any investment advisor have been the subject of a bankruptcy petition. Item 10 – Other Financial Industry Activities and Affiliations Promus Advisors is not registered, nor does it have an application pending to register, as a broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor. Joshua J. Prince, a supervised management person, or any investment advisor, is not registered, nor does anyone have an application pending to register, as a registered representative of a broker-dealer, futures commission merchant, commodity pool operator, or commodity trading advisor. Promus Advisors has an arm’s length relationship with qualified custodians holding client securities and cash. Promus Advisors does not receive any compensation from any custodian. Promus Advisors has an arm’s length relationship with all the outside managers it may select. Promus Advisors does not receive any compensation from any mutual fund, separately managed account, or other investment managers. Promus Advisors is a related adviser to Bellwether Investment Management Inc., Canada. Bellwether Canada is a registered portfolio manager in the provinces of Alberta, British Columbia, Manitoba, Nova Scotia, Ontario, Quebec, Saskatchewan, and Prince Edward Island, an exempt market dealer in Alberta, Ontario and Quebec, and an investment fund manager in Ontario and Quebec. Promus Advisors is approved as an international adviser exempt from registration in the province/territories of Ontario, Canada, under the Ontario Securities Commission (OSC) and Alberta, Canada, under the Alberta Securities Commission (ASC). Additional information about Promus Advisors is available on the Canadian Securities Administrators’ website at https: www.securities-administrators.ca/nrd/. You can search this site by a unique identifying number, known as a NRD number. The NRD number for Promus Advisors is 81690. 9  Item 11 – Code of Ethics SEC Rule 204A 1 (the “Rule”) under the Investment Advisers Act of 1940, as amended, requires all RIAs to adopt a code of ethics that sets forth standards of conduct and requires compliance with all applicable federal securities laws. The Code of Ethics (the “Code”) adopted by Promus applies to various supervised personnel and other access persons of Promus, including those of certain affiliated companies (collectively, “Covered Persons”). The Code is designed to comply with the Rule and to reflect the fiduciary principles that govern the conduct of Promus and its Covered Persons. The requirements of the Code are in addition to and do not replace a Covered Person’s obligations to comply with Promus’s related policies and procedures All Covered Persons are responsible for, and have agreed, as a requirement of their employment, registration as an Promus IAR or independent contractor to review, be familiar with, and comply with the Code. In addition, Covered Persons are expected to be familiar with and comply with Promus policies and procedures as they apply to the business function(s) they engage in, and to conduct themselves appropriately and consistently with applicable business and/or fiduciary standards. To that end, Promus requires Covered Persons to conduct all business dealings in an ethical fashion and to abide by not only the technical requirements of the Code, but also to the spirit in which it is intended. The Promus Advisors Code of Ethics is available upon request. Item 12 – Brokerage Practices Promus Advisors does not maintain direct custody of client assets. Clients’ assets are maintained in a brokerage account at a “qualified custodian,” generally a broker‐dealer or bank. Promus Advisors is independently owned and operated and is not affiliated with any other custodian or broker-dealer. Brokerage Recommendations While you are free to choose any broker-dealer/custodian or other service provider, clients that engage our firm for portfolio management services must open one or more custodian accounts in their own name at an independent custodian with which we have an existing relationship. In recommending a broker-dealer/custodian we will endeavor to recommend those brokers or dealers that will provide quality services at reasonable fees. The reasonableness of such fees is based on several factors, including the broker's ability to provide professional services, competitive commission rates, volume discounts, execution price negotiations, the custodian's reputation, execution capabilities, and responsiveness to our clients. Promus Advisors maintains brokerage/custodial relationships with Pershing Advisor Solutions LLC (“Pershing”), a BNY Mellon Company, Fidelity Brokerage Services LLC ("Fidelity"), and/or Charles Schwab & Co., Inc. ("Schwab"), among others. These firms were chosen based on their relatively low transaction fees and access to mutual funds and ETFs. We generally do not allow clients to instruct our firm to use one or more particular brokers for the transactions in their accounts. If you choose to direct our firm to use a particular broker, and we accept such appointment, you should understand that this might prevent our firm from aggregating trades with other client accounts and/or otherwise prevent our firm from obtaining favorable net price and execution. Thus, when directing brokerage business, you should consider whether the commission expenses, execution, clearance, and settlement capabilities that you will obtain through your selected broker-dealer/custodian are adequately favorable in comparison to those that we would otherwise obtain for you. Research and Other Soft Dollar Benefits As a registered investment adviser, we may have access to research products and services from your account custodian(s) and/or other brokerage firm. These products may include financial publications, information about 10  particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Such research products and services are provided to all investment advisers that utilize the service platforms of these firms and are considered a benefit to our firm, but are not considered to have been paid with soft dollars. To the extent our firm receives any research products and/or services from your acting custodian/broker-dealer, a conflict of interest arises in that such research and/or services might not directly benefit client accounts. In effort to mitigate this conflict of interest it is our firm's policy to use such research or services to assist in making investment decisions on behalf of client accounts or to assist with our overall responsibility for servicing client accounts, respectively. Clients should also be aware that the commissions charged by a particular broker-dealer for a particular transaction or set of transactions may be greater than the amounts another broker who did not provide research services or products might charge. As a registered investment adviser our firm and representatives of our firm have a fiduciary duty to act in our client's best interest. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Trade Errors In the event a trading error occurs in your account that we are responsible for, our policy is to restore your account to the position it should have been in had the trading error not occurred. Depending on the circumstances, corrective actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. Block Trades We may combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as "block trading"). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not receive preferential treatment. Our firm's strict policy that neither our firm nor persons associated with our firm shall have priority over your account in the purchase or sale of securities or investment products. Where we block trade accounts, we do so only for discretionary accounts. We do not combine orders for non- discretionary accounts. Accordingly, non-discretionary accounts may pay different costs than discretionary accounts pay. If you enter into non-discretionary arrangements with our firm, we may not be able to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs than clients who enter into discretionary arrangements with our firm. Item 13 – Review of Accounts Portfolios are regularly reviewed by Joshua J. Prince, President of Promus Advisors, or an assigned Investment Adviser Representative. The regularity of Portfolio review depends on several factors, including but not limited to the complexity of the client’s needs and Portfolio, and the Promus Advisors representative who is responsible for monitoring and maintaining compliance with client‐specific guidelines. Promus Advisors encourages its clients to meet with a representative of the firm on a regular basis, which may be as frequent as each quarter, to review the performance of the client’s Portfolio (more frequently if necessitated by market conditions, news events, excess cash balances, or any other events Promus Advisors, or the client, deem significant). Clients are encouraged to contact Promus Advisors whenever their financial situation changes (e.g., marriage, divorce, birth, death, change in employment), as this may require a review. 11  Promus Advisors issues periodic reports to clients regarding the asset allocation and the performance of the client’s Portfolio. Clients are encouraged to compare the information prepared by the firm with the information prepared by the independent qualified custodian. In addition to the Promus Advisors periodic reports, clients also receive confirmations for transactions and monthly statements directly from the custodians of their accounts. Custodians issue quarterly statements when no monthly account activity has taken place. Clients may opt to access Portfolio information online from the custodian’s website, if desired. For stand-alone financial planning services, Promus Advisors conducts reviews in accordance with the financial planning agreement and whether services are ongoing. Item 14 – Client Referrals and Other Compensation Promus Advisors a subsidiary of Bellwether Investment Management USA Inc., which is an affiliate of Bellwether Investment Management Inc., a Canada registered portfolio manager; whereby, a referral arrangement is present between Promus Advisors Asset Management, LLC and Bellwether Investment Management Inc., and therefore, from time to time, Promus Advisors may remit referral compensation to Bellwether Investment Management Inc., for such referral. No individual or firm provides an economic benefit to Promus Advisors, or any supervised and management person of Promus Advisors, by providing investment advice or other investment advisory services to the firm's clients. Promus Advisors receives an economic benefit from client qualified custodians in the form of the support products and services made available to independent advisors whose clients maintain accounts at such custodians. The description of these products and services, how they benefit advisors, and the related conflicts of interest are described above (See Item 12 ‐ Brokerage Practices). Item 15 – Custody Promus Advisors does not have custody of client funds or securities; a qualified custodian maintains actual custody of Promus Advisors’ client assets. In most instances, Clients receive statements at least quarterly directly from the custodian that holds and maintains their assets. Statements are sent to the email or postal address provided to the custodian by the client. Promus Advisors urges clients to carefully review such statements and compare such official custodial records to the Portfolio reports provided by Promus Advisors. Item 16 – Investment Discretion Clients enter into a written Investment Management Agreement (IMA) with Promus Advisors, which describes the discretionary authority Promus Advisors has to make all investment decisions regarding the Portfolio and to execute sales, purchases, and reinvestments necessarily to carry out the Client’s investment objectives. In the case of Separately Managed Accounts, Promus Advisors can select, terminate or change asset managers. Promus Advisors does not have the discretion to withdraw cash or securities from the client's accounts. Item 17 – Voting Client Proxies Promus Advisors does not have any authority and does not vote proxies on behalf of its clients. Clients retain the responsibility for receiving information from the custodian and voting for all securities maintained in client Portfolios. If the Portfolio is a pension plan or otherwise covered by the Employment Retirement Income Security Act, the client must designate in writing another fiduciary who will vote proxies for the Portfolio. 12  Item 18 – Financial Information Promus Advisors invoices for management fees only one quarter in advance and therefore it is not required to provide a current balance sheet or other firm financial information. There are no financial conditions that are reasonably likely to impair Promus Advisors’ ability to meet its contractual commitments to clients. Neither Promus Advisors nor any supervised management person has ever been the subject of bankruptcy. 13