SAN BLAS ADVISORY, INC.

Item 1 – Cover Page San Blas Advisory, Inc. IARD# 296929 Mailing Address 3424 Peachtree Road Suite 2200 Atlanta, GA 30326 Investment Advisory Brochure (“ADV Part 2A”) April 23, 2026 NOTICE TO PROSPECTIVE CLIENTS: READ THIS DISCLOSURE BROCHURE IN ITS ENTIRETY All the material within this Brochure must be reviewed by those who are considering becoming a client of our firm. This Brochure provides information about the qualifications and business practices of San Blas Advisory, Inc. (“Advisor”). If you have any questions about the contents of this Brochure, please contact us at (872) 678-8872, ext.: 843. 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. In accordance with federal and state regulations, this Brochure is on file with the appropriate securities regulatory authorities as required. The information provided within 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 United States Securities and Exchange Commission. San Blas Advisory, Inc. is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about San Blas Advisory, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov  Item 2 – ADV 2A: Material changes San Blas Advisory, Inc. (“SBAI”) has made the following material changes since the previous Brochure which was dated February 24, 2026: • SBAI has moved from a State registered investment adviser to an SEC registered investment adviser due to its regulatory assets under management. Currently, our Brochure may be requested from our Chief Compliance Officer John Rowoldt. John’s email is john.rowoldt@sanblassecurities.com, and his phone number is 872-678-8872, ext.: 843. Additional information about San Blas Advisory is also available via the web site www.adviserinfo.sec.gov. The web site also provides information about any persons affiliated with San Blas Advisory who are registered, or are required to be registered, as investment adviser representatives of the firm.  Item 3-Table Contents Item 1 – Cover Page ............................................................................................................................................ 1 ............................................................................................................................................................................ 1 Item 2 – ADV 2A: Material changes .................................................................................................................... 2 Item 4 – Advisory Business ................................................................................................................................. 4 Item 5 – Fees and Compensation......................................................................................................................... 5 Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................................... 7 Item 7 – Types of Clients .................................................................................................................................... 7 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ............................................................... 7 Item 9 – Disciplinary Information ..................................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 12 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading...................... 12 Item 12 – Brokerage Practices ........................................................................................................................... 13 Item 13 – Review of Accounts .......................................................................................................................... 13 Item 14 – Client Referrals and Other Compensation ......................................................................................... 13 Item 15 – Custody ............................................................................................................................................. 13 Item 16 – Investment Discretion........................................................................................................................ 14 Item 17 – Voting Client Securities .................................................................................................................... 14 Item 18 – Financial Information ........................................................................................................................ 14  Item 4 – Advisory Business THE FIRM SBAI is an investment advisory firm registered with the SEC and headquartered in the state of Georgia. SBAI commenced providing investment advisory services and investment in August 2019. SBAI was incorporated in the State of Georgia in March 2018. As of December 31, 2025, SBAI, manages $ 218,880,000 of which $216,537,000 are on a discretionary basis. PORTFOLIO MANAGEMENT PROGRAMS SBAI currently has a correspondent relationship with Charles Schwab. Direct Portfolio management may be offered in discretionary or no n -discretionary accounts and will consist of i nvest m ent advi ser repres ent at i ves ( “ IARs”) investing in firm approved individual equities, mutual funds, ETFs, UITs and options. Our IARs will manage client assets based on each individual’s suitability and objectives. Clients have the capability to impose restrictions on what can be purchased in their accounts. Such as certain securities or types of securities. SBAI and its IARs may also, on a non-discretionary basis, recommend or assist in the selection of other Advisors and third-party money managers (“TPM”) from the Charles Schwab platforms. As of the date of this Brochure, Charles Schwab offers hundreds of TPMs with a wide range of investment styles and objectives, Your SBAI IAR will help you choose a TPM and open an account according to your financial profile and investment goals.  Item 5 – Fees and Compensation SBAI will charge advisory fees based on the Assets Under Management of that account. The advisor and client have discretion to negotiate a discount on advisory fees charged to the client. Accounts can be charged quarterly or monthly in arrears or in advance, depending on what the client agrees to in their advisory agreement. Fees will be deducted from the client’s account at the applicable correspondent firm. For billing purposes, advisory fees will apply to all assets under management, including cash and cash equivalents. The firm will refund prepaid advisory fees based on the value of the assets on the date of withdrawal for the pro rata number of days remaining in the respective month or quarter depending on the billing cycle agreed upon. For billing occurring in advance fees will not be charged six months or more in advance and will not exceed $1,200. SBAI will receive compensation as a percentage of assets under management for referring the Client to the respective program and its money managers. * SBAI has a conflict to recommend TPMs that generate more revenue to SBAI, and that when using a TPM, the client will pay higher fees. PORTFOLIO MANAGEMENT PROGRAMS Charles Schwab Total Annualized fee charged to the client Up to $1 Million $1 Million up to $2 Million $2 Million up to $5 Million $5 Million up to $10 Million $10 Million and up 2.00% 1.75% 1.50% 1.25% 1.00% Charles Schwab Transaction Fees: *Mutual Fund trades- $24.00 for household greater than $500,000 in total. If household is less than $500,000 transaction fee is $31.00. If client sets up electronic statement delivery transaction fee is $24.00; *Dimensional Fund Advisors-$9.99 for mutual fund trades; *Options $6.95 + $.75 per contract; *Fixed Income priced on an individual basis; *Portfolio Management Programs may have other flat fees or expenses such as wire or transfer charges and custodian fees or mutual funds expenses disclosed at account opening or in the prospectus and Hourly Financial Planning and Consulting The Client will be assessed a maximum fee of $200/hour. Fees for hourly financial planning and consulting services are negotiable between the Client and SBAI and can be reduced per agreement between Client and Advisor. Prior to providing any such services, the IAR of SBAI and Client must agree to the amount of compensation negotiated, which will be stated in the Financial Planning Agreement. A portion of the fee will be due and payable to SBAI upon completion of the services or monthly based on the accrued number of hours spent to date on financial planning. The remaining portion are due upon completion of the plan. Lower fees for comparable services may be found from other sources.  If the Client or Advisor wishes to terminate the relationship written notice shall be provided by the Client to SBAI, or vice-versa. Said termination shall be effective immediately upon receipt of the termination notice by the other party. A Client’s death shall not terminate the authority granted to SBAI hereunder until SBAI has received actual notification of said death. The Client will not be eligible for the refund of fees earned by SBAI as hourly financial planning and consultation is billed in arrears. The Client will be responsible for any hourly fees accrued up to the date of termination. FINANCIAL PLANNING SBAI’s Financial Planning services will consist of creating and implementing financial plans for our clients. Our IARs through discussions and correspondence with their clients will get an understanding of their financial goals in order to implement a strategy that meets their objectives. Periodically the IARs will touch basis with their clients to determine if any changes have occurred that validate adjusting their plans. Each Financial Plan will consist of a contract specifying the fees and parameters of the agreement. Comprehensive Financial Planning The purpose of comprehensive financial planning is to conduct a holistic review of the Client’s financial situation, goals, and risk so as to provide advice and recommendations on all aspects of the Client’s financial situation disclosed to SBAI. SBAI and IARs will thoroughly review all pertinent Client information, including condition, tax status, and cash flow concerns, discuss Client objectives and needs, assess risk tolerance, and mutually agree upon a set of assumptions. On the basis of this information, SBAI will provide Client with a customized written report all analyses and recommendations. The Client will be assessed a maximum fee of $15,000. The fee can be negotiated between the Client and SBAI. A portion of the fee will be payable upon execution of an agreement for services with the remaining amount due within 30 days of completion of the service. Lower fees for comparable services may be available from other sources. Limited Financial Planning The purpose of Limited Financial Planning is to target particular area(s) of financial planning services desired by the Client (hereinafter referred to as “Specific Planning Services”). The financial planning activities of SBAI are not a holistic review of the Client’s financial situation, goals, and risk. SBAI will thoroughly review Client information, pertinent to specific planning services, including financial condition, tax status, and cash flow concerns, Client objectives and needs, assess risk tolerance, and mutually agree upon a set of assumptions as it pertains to specific planning services. On the basis of this information, SBAI’s assessment is not a holistic review of the Client’s financial situation, goals, and risk. The Client will be assessed a maximum fee of $200/hour. However, fees are negotiable between the Client and SBAI. Fees are due and payable to SBAI within 30 days of delivery of any written report or may be billed monthly based on the accrued number of hours spent during the prior month of the specific planning services. Lower fees for comparable services may be available from other sources. Hourly Financial Planning & Consulting The purpose of hourly financial planning is to provide a way for Clients to openly discuss financial planning matters affecting them, their families, and/or their businesses. SBAI will review pertinent Client information  provided to it by the Client, discuss Client objectives and needs, and analyze and assess other factors necessary in providing information and recommendations concerning area(s) of financial planning for which the Client seeks advice. ADDITIONAL DISCLOSURES IARs of SBAI in the role of a broker/dealer representative may receive commissions for the sale of investments through an outside brokerage relationship and compensation for the sale of insurance products as insurance agents. Commissions for the sale of investments may be the result of transactions conducted as part of the above-stated programs pursuant to an advisory agreement entered into by the Client or for transactions in Client accounts and assets that are not being managed pursuant to an advisory agreement executed by a Client. Any compensation or commissions received by an agent for insurance transactions are received outside the scope of an advisory agreement executed by a Client. The receipt of commissions and compensation for transactions represents a conflict of interest as the IAR has an incentive to recommend securities and insurance products based on compensation received rather than on the Client’s needs. SBAI has adopted policies for the review of commissions along with the quality of executions as part of its procedures on best execution to mitigate potential negative consequences to the Client, such as the payment of higher commissions relative to the enhanced ability of SBAI and its IARs to service Clients. SBAI has adopted policies prohibiting the recommendation of a money manager/program to a Client solely based on compensation received. SBAI has also adopted practices for the review of accounts to ensure that programs selected are in the best interest of the Client. For financial planning services, SBAI has adopted practices and policies to review financial plans and financial planning services to ensure that services provided are in the best interest of Clients and are consistent with SBAI’s fiduciary duty to Clients. Clients have the option to purchase investment products recommended by SBAI or its IARs in their capacity as registered representatives of the broker/dealer affiliate or through other broker/dealers or registered representatives not affiliated with this firm. SBAI and its IARs are primarily compensated through fees discussed above and not commissions from advisory clients of SBAI. In programs with commission charges, where transactions are effected through a brokerage account established through SBAI’s outside broker dealer, the advisory fees charged to Clients have been reduced to offset commission or markup charges. Item 6 – Performance-Based Fees and Side-By-Side Management SBAI does not permit the charging of performance-based fees – that is, fees based on a share of capital gains or capital appreciation of assets (such as a client that is a hedge fund or other pooled investment vehicle). We also do not participate in side-by-side management, where an advisor manages accounts that are both charged a performance-based fee and accounts that are charged another type of fee, such as an hourly or fixed fee or an asset-based fee. Item 7 – Types of Clients SBAI provides investment advisory services and investment advice to individuals, high net worth individuals, and businesses. SBAI requires the applicable new account documents to open an account with our firm. There is currently no minimum account size to open an account with our firm. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss  METHODS OF ANALYSIS SBAI may utilize a wide variety of sources and tools for analyzing securities and providing advice. This includes, among others, print media (newspapers, journals, and magazines); third party research; corporate rating services; annual reports; company press releases; filings with the SEC; sales literature of product sponsors; and information generally available through the Internet. Software or web-based programs for security analysis may also be utilized. SBAI may use technical, fundamental, qualitative, or a combination of analysis methods in making recommendations to a Client and/or making investment transactions for a Client’s account. Technical Analysis Technical analysis is the forecasting of future price movements of a given security based on an examination of past price movements. With this method of analysis, there is a general belief that one can identify a trend and conduct transactions based on a trend to generate profits. Price movements may be examined based on the movements on a security or relative to other securities, industry benchmarks, and competitors. Further, price movements may be applied to varying time frames. The primary tools used in technical analysis are charts of price movements. Technical Analysis is a viable tool to use for stock analysis but is not always a full indicator of where future securities prices may go. Fundamental Analysis Fundamental analysis is a method of evaluation that attempts to measure the value of a security by examining economic, industry, and company condition. Fundamental analysis typically focuses on key statistics in a company’s financial statements to determine the valuation of a security. Common tools used in fundamental analysis are the review of financial ratios and financial statements. Fundamental Analysis is a viable tool to use for stock analysis but is not always a full indicator of where future securities prices may go. Qualitative Analysis Qualitative analysis is a method of evaluating non-quantifiable factors of a security such as the quality of management, labor relations, and the strength of research and development factors not readily subject to measurement. The risk of qualitative analysis is that by itself it does not factor in the attributes of fundamental or technical analysis. It is a limited approach that must be utilized with fundamental and/or technical analysis in making recommendations or selections of securities. Qualitative Analysis is a viable tool to use for stock analysis but is not always a full indicator of where future securities prices may go. INVESTMENT STRATEGIES Under the Portfolio Management Programs, SBAI may employ a variety of investment strategies and securities to tailor a portfolio that meets the needs of its Clients. Accordingly, there is no uniform investment strategy applied for all Clients. However, among the strategies that may be utilized with a Client are as follows: An asset allocation program utilizing mutual funds and/or exchange-traded funds to provide 1. customers broad-based diversification among asset and sector classes; and, Investing in financially strong, undervalued stocks of companies. Additional strategies or 2. methods may be employed based on the needs and desires of the Client.  Asset Allocation Utilizing Mutual Funds and Exchange Traded Funds Asset allocation utilizing mutual funds and exchange-traded funds is primarily utilized to provide customers broad-based diversification among asset and sector classes. This strategy enables Clients to indirectly invest in the securities of indexes, sectors, industries, and compilations of companies thus limiting downside risk and non-systematic risk typically associated with investing in a security of a particular company. This is also a more cost-effective approach than trying to invest in individual securities of companies to replicate the composition of an index, sector, or industry. Asset allocation programs utilizing mutual funds and exchange-traded funds involve risks. 1) Exchange traded funds and mutual funds may not be able to replicate the performance of underlying index or sector because of expenses, composition, or other factors. 2) Mutual funds and exchange traded funds possessing international investments are subject to the risk of capital loss due to unfavorable fluctuations in currency exchange rates, difference in accounting principles, or economic or political instability in other nations. 3) News or performance affecting an industry or market sector may negatively impact the performance of an entire mutual fund or exchange traded fund. 4) The use of leverage exchange traded funds may result in greater losses or gains as such exchange traded funds increase or decrease at a multiple (i.e. 2x or 3x) of most exchange traded funds. In using mutual funds, as part of an asset allocation program or not, the Client may be subject to sales loads, otherwise known as commissions, in the purchase or sale of a mutual fund. Sales loads vary widely based on the underlying portfolio, class of share selected, and dollar amount invested. SBAI and its IARs will seek to purchase mutual funds possessing no sales load, and will seek to purchase the lowest-cost share class available at the time of purchase that is in the best interest of the Client’s anticipated holding period for the fund. For no-load funds or mutual funds possessing a sales load, a Client’s mutual fund holding will be subject to annual fees that are assessed by the mutual fund. Sales loads and annual fees negatively impact the net performance of a mutual fund. The objectives and positions of mutual funds vary in nature and type. Accordingly, the performance of mutual funds may deviate significantly to the performance of market benchmarks, such as the Dow Jones Industrial Average or the Standard and Poor’s’ 500 Index. Investments in Strong, Undervalued Companies A strategy that may be employed by our IARs is to seek opportunities to invest in companies that are financially strong, yet undervalued. IARs could look for potential buying opportunities of stocks of companies who they have researched and determined that the stock price is not reflective of the underlying value and strength of the company. Investments in financially strong, undervalued stocks of companies involve risks. 1) By investing in securities of individual companies, Clients will generally possess a lower level of diversification than would otherwise be available by investing in a mutual fund based on a broad-based, market index. A lack of diversification may result in a portfolio being more adversely impacted by news and/or events affecting a company or its industry. 2) Appreciation or the growth rate in the price of the security may be lower than other types of securities, including stocks. It is common that the stock price of many companies may not appreciate as much as a growth or aggressive stock, such as a stock of a technology company. 3) Stock investing may result in substantial or total losses. 4) The individual stock may not perform or increase as well as or at the time a recommendation/purchase takes place. In using stocks as an investment vehicle, the Client is advised that use of stocks of companies may result in a commission charge based on the program selected. Clients are advised that stocks may fluctuate widely due to firm specific events, financial market events, political events, and changes in regulations. The degree  to which a stock may fluctuate is not certain or predictable; however, it is noted that some stocks move in more correlation to overall stock markets. Conversely, the investment in financially strong, undervalued stocks may be indicative of stocks whose price movement has been generally less than that of the overall markets. Investing in individual securities provides less diversification by themselves than investments in multiple stocks, a mutual fund comprised of securities of multiple companies or issuers, or using multiple types of investment vehicles (i.e. stocks, bonds, mutual funds, etc.). For any strategy employing the frequent trading of securities, investment performance may be negatively impacted due to increased transactions costs (i.e. commissions) as well as higher tax rates due to differentials in tax rates between short-term and long-term holdings. Clients are advised to be mindful of these potential negative consequences. Turnkey Asset Management Program Strategies Under the Turnkey Asset Management Programs, specific strategies may be employed by the money managers managing the account. Information concerning such strategies may be found by accessing the Form ADV of the money manager and by requesting additional information concerning the program. RISK OF LOSS AND ADDITIONAL RISKS Investing in securities involves risk of loss that Clients should be prepared to bear. There can be no guarantee of success with the strategies or programs offered by the firm. Past performance is not a guarantee of future returns. For Turnkey Asset Management Programs, risks of investing are further discussed in the Form ADV of the money manager. As risk is present in any form of investing, some of the more common risks that a Client may be exposed to are: • Interest-Rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s underlying circumstances. For example, political, economic and social conditions may trigger market events. • Inflation Risk: When any type of inflation is present, a dollar today will buy more than a dollar next year, because purchasing power is eroding at the rate of inflation. • Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities. • Dividend Risk: The risk that the dividend rate offered by a company for an investment in their stock may change due to decisions by the company on whether eliminate or decrease a dividend offered with an investment in a stock. • 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 they can generate 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 is like. • Default Risk: The inability of an issuer of repay fixed income securities or meet continuing payment obligations.  • Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. • Financial Risk: Excessive borrowing to finance a business’ 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 may result in bankruptcy and/or a declining market value. • Long-term Trading - Long term trading allows for a longer time for prices of securities to fluctuate. This may result a Client receiving an execution price at the time of exiting a position that is lower than the price of the security at some point during the holding of such security. Further, by holding a security for a longer length of time, SBAI may not be able to take advantage of short-term trading that could be profitable to a Client. • Short-term trading – Short term trading, particularly frequent trading, can affect investment performance particularly through increased brokerage and other transaction costs and taxes due to differential in tax rates between short-term and long-term holdings. Clients are advised to be mindful of these potential negative consequences. Further, short-term trading creates the potential for sudden losses in addition to gains. • Margin Risk - The use of margin transactions results in higher costs and generally holds a greater risk. The increased costs are due to interest owed by a Client in borrowing money for effecting and maintaining transactions in securities. The use of margin allows SBAI the ability purchase an increased number of securities, which due to their inherent risk, can result in greater fluctuation in the value of a portfolio or exposure to any one security. • Short Sales – Short sales are when a Client sells a security for which it does not own in anticipation that the price of the underlying security will go down in value so that it can be repurchased to close the outstanding short sale and obtain in a profit in the security. The risk is that the underlying security may go up in value and cannot be bought at a price lower than for which it was sold thus resulting in a loss to the Client. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of SBAI or the integrity of the SBAI’s management. Any such disciplinary information for the company and the company’s IARs would be provided herein and publicly accessible by selecting the Investment Advisor Search option at http://www.adviserinfo.sec.gov SBAI as an entity does not have any disclosures to date. Below are the disclosures in relations to individual IARs: • Scott Bremus (CRD No. 4073006) – was fined $10,000 and suspended by FINRA for six months from October 16, 2023 through April 15, 2024 for participating in a private securities transaction without proving written notice to, or obtaining written approval from his firm. • Alex Mckenzie(CRD No. 2642827 ) In 2003, a supervised person of the firm consented to a disciplinary action by the National Association of Securities Dealers (NASD), now FINRA, involving allegations of excessive commissions and markups under NASD Rules 2110 and 2440. Without admitting or denying the allegations, the individual agreed to a $25,000 fine, a two-week suspension, and restitution of $78,575.53 to affected customers. Additional information and disclosures not required to be reported here can be found at https://www.investor.gov/ and/or https://brokercheck.finra.org/ by searching utilizing the name or CRD number of SBAI or any of its IARs.  Item 10 – Other Financial Industry Activities and Affiliations SBAI currently has affiliation by common principals with San Blas Securities which is a registered Broker/ Dealer with FINRA. SBAI can use San Blas Securities’ clearing relationship to conduct securities transactions. Some of our IARs may also be registered with San Blas Securities. In conducting insurance transactions, IARs of SBAI will receive commissions and premiums for sales of life and health insurance as well as annuities. Such compensation is split with the insurance agent, who may also be an IAR of SBAI, in conducting the transaction. IARs of SBAI may also receive compensation from the sale of insurance products and annuities conducted away from SBAI, who will not receive any compensation for such transactions. This presents a conflict of interest as SBAI and its IARs have an incentive to recommend providing financial planning services or otherwise in the role of an insurance agent, insurance products based on compensation received rather than the Client’s needs. SBAI has adopted policies requiring all insurance transactions be in the best interest of Clients based on information ascertained from the Client. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading SBAI has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its Clients. The Code of Ethics includes provisions relating to the confidentiality of Client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. Clients or prospective clients may request a copy of the firm's Code of Ethics by contacting the Chief Compliance Officer, John Rowoldt, at (872) 678-8872, ext.: 843. Subject to satisfying this policy and applicable laws, officers, directors and IARs of SBAI may trade for their own accounts in securities which are recommended to and/or purchased for firm Clients. This presents a conflict of interest as IARs of SBAI could receive an execution for a transaction for an account in which they have financial interest that is superior to that received by a Client. To address this conflict, the Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the supervised persons of SBAI will not interfere with 1) making decisions in the best interest of advisory clients and2) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Further, SBAI requires IARs, in conducting accounts in which they have beneficial ownership or control, to only affect transactions in their accounts after all allocations have been made to Clients unless their order is entered in concert with other Client orders at the same time to receive the same execution price. Neither SBAI nor any of its supervised persons, including IARs, maintain a material financial interest in any securities recommended to a Client for purchase. Supervised persons are prohibited from making recommendations in securities in which they have a material financial interest. It is SBAI policy to not permit SBAI or its affiliated broker/dealer to affect any agency cross securities transactions for Client accounts. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. It is SBAI policy to not effect principal transactions for Client accounts through its affiliated broker/dealer. Principal transactions are generally defined as transactions where an adviser, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any client.  Item 12 – Brokerage Practices SBAI, in providing services to Clients, requires the use of certain broker-dealers and custodians for the entering and routing of transactions for execution. SBAI has an arrangement with and recomm ends that Clients use Charl es Schwab to serve as broker-dealer and custodian. Charles Schwab is the broker- dealer and custodian of client accounts that are managed by other Advisors or TPMs. By directing brokerage, SBAI may be unable to achieve most favorable execution of Client transactions. This practice may cost Clients more money. SBAI’s IARs in directing orders for the purchase or sale of securities may aggregate orders for clients. Aggregating purchases/sales would be applied in situations where the purpose is to achieve best execution for clients. Aggregate purchases/sales will be conducted in a manner where there are no systematic advantage or disadvantages for the client’s accounts. Item 13 – Review of Accounts The CCO and any designee may appoint reviews selected accounts on a periodic basis. In such a review, the CCO is evaluating transaction history relative to the Client’s profile and the underlying investment adviser representative’s compliance with SBAI policies and fiduciary standards. Additional account reviews may be triggered by a specific client request; a customer complaint; or, as needed, based on activity levels within an account. A sample of financial plans will be reviewed as needed by the CCO. IARs of SBAI are responsible for continuously monitoring Client accounts in considering the Client’s profile, various events (i.e. political, market, etc.), and changes in securities and companies that are currently being held by a Client. IARs providing financial planning services are responsible for reviewing such financial plans in accordance with any contractual agreements entered by the Client. At the present time, SBAI does not provide any reports regarding the assets and account(s) of Clients. The qualified custodian provides no less than quarterly account statements concerning the Client’s assets. Item 14 – Client Referrals and Other Compensation SBAI does not receive any economic benefit from anyone or any entity other than the Client, except for compensation SBAI may receive in connection with Turnkey Asset Management Programs. As discussed in Section 5, SBAI will receive compensation as a percentage of assets under management for referring the Client to the respective program and its money managers. This presents a conflict of interest as the Advisor and its IARs may be entitled to greater compensation by recommending one Turnkey Asset Management Program versus another in lieu of what program is in the best interest of the Client. SBAI has adopted policies prohibiting the recommendation of a money manager/program to a Client solely based on compensation received. SBAI requires all recommendations of money managers/programs to be in the best interest of the Client based on the information ascertained from the Client by SBAI and its IARs. SBAI does not compensate any entity or persons as marketers in referring Clients to SBAI for services. Item 15 – Custody Pursuant to the written client authorization in the client agreement, the qualified custodian will directly debit your account(s) for the payment of SBAI advisory fees. The ability to deduct our fees from client accounts  causes SBAI to exercise limited custody over your funds or securities. We do not have physical custody over any of your funds and/or securities. Your funds and securities will be held with a bank, broker dealer, or other independent qualified custodian. Clients will receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains Client’s investment assets. SBAI urges you to carefully review such statements. SBAI does not currently provide alternative statements. Item 16 – Investment Discretion SBAI may receive discretionary authority from the Client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold, and commission rates to be applied. SBAI obtains such authority through the execution of an advisory agreement which provides for and Client consents to discretionary authority being granted to SBAI. The Client reserves the right, with agreement by SBAI, to request and have their assets managed on a non-discretionary basis. In all cases, discretion is to be exercised in a manner consistent with the stated investment objectives for the Client’s account. When selecting securities and determining amounts, SBAI observes the investment policies, limitations and restrictions of the Clients for which it advises. Investment guidelines and restrictions must be provided to the firm in writing. SBAI recommends on the selection of brokers/dealers to be used, unless agreed to otherwise by the Client and SBAI. SBAI will frequently recommend its outside broker/dealer, San Blas Securities, to serve as a broker/dealer, through which SBAI has discretion on the amount of commissions to be paid subject to the terms and conditions of the program in which the Client enters. Item 17 – Voting Client Securities As a matter of policy and practice, SBAI does not have any authority to and does not vote proxies on behalf of separately managed account Clients. Clients retain the responsibility for receiving and voting proxies for securities maintained in Client portfolios. SBAI may provide advice to Clients regarding the clients’ voting of proxies. All proxies or other solicitations for proxy voting come directly from the custodian or transfer agent and not from the firm. Clients having questions about proxies or other solicitations may contact their IAR at SBAI. Contact information for the IAR is provided for in the ADV Part 2B, which provides details concerning the IAR. Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about the firm’s financial condition. SBAI has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. Further, SBAI has not been subject to any bankruptcy petition at any time. SBAI does not charge more than $1,200 in fees per client more than six months in advance.