Soltis Investment Advisors, LLC

SOLTIS INVESTMENT ADVISORS, LLC SEC File No. 801-71833 20 North Main, Suite 400 St. George, Utah 84770 An SEC Registered Advisory Firm1 Established 1993 FIRM BROCHURE, MARCH 2026 This brochure provides information about the qualifications and business practices of Soltis Investment Advisors, LLC (“Soltis”). If you have any questions about the content of this brochure, please contact us at (435) 674-1600 and/or via our website at www.soltisadvisors.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about Soltis is available on the SEC’s website at www.adviserinfo.sec.gov. 1 SEC registration does not and should not imply any certain level of skill or training.  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 2 ITEM 2. MATERIAL CHANGES Soltis has created an affiliated entity called Soltis Tax Solutions, LLC in order to provide clients with tax and related services. Please refer to item 10 for further information.  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 3 Table of Contents ITEM 4. ADVISORY BUSINESS ........................................................................................................................ 4 ITEM 5. FEES AND COMPENSATION .............................................................................................................. 6 ITEM 6. PERFORMANCE-BASED FEES and SIDE-BY-SIDE MANAGEMENT ..................................................... 8 ITEM 7. TYPES OF CLIENTS ............................................................................................................................ 8 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ......................................... 9 ITEM 9. DISCIPLINARY INFORMATION ........................................................................................................ 13 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ..................................................... 13 ITEM 11. CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL TRADING .......... 13 ITEM 12. BROKERAGE PRACTICES ............................................................................................................... 14 ITEM 13. REVIEW OF ACCOUNTS ................................................................................................................ 18 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION ....................................................................... 18 ITEM 15. CUSTODY ...................................................................................................................................... 19 ITEM 16. INVESTMENT DISCRETION .......................................................................................................... 20 ITEM 17. VOTING CLIENT SECURITIES ......................................................................................................... 20 ITEM 18. FINANCIAL INFORMATION ........................................................................................................... 20 PRIVACY NOTICE .................................................................................................................................. 21  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 4 ITEM 4. ADVISORY BUSINESS Soltis was founded in 1993 and is indirectly owned by its partners and affiliates, Soltis employees, and by funds managed by Estancia Capital Management, LLC ("Estancia") and LLR Management HoldCo, L.P. (d/b/a LLR Partners) ("LLR"). Soltis provides its Clients2 with the following Advisory Services. 1. Review of Investment Goals and Objectives. Each Client is provided an Investment Policy Statement or similar document as a result of this review which details the Client’s investment guiding principles, risk tolerance, portfolio asset allocation, and other relevant factors as appropriate. 2. Asset Allocation Recommendation and Investment Selection. Based on the Client’s Investment Policy Statement or similar document, Soltis recommends a portfolio strategy, which includes a general allocation by Asset Class (i.e. stocks, bonds, cash, and alternative investments) in combination with risk characteristics and return expectations. Soltis’ portfolios are developed (based on Modern Portfolio Theory Principles and other methods and techniques) to provide diversification by both Asset Class and Style to seek to maximize the risk-adjusted return based on the Client’s risk-return profile. Securities are selected based on a continuous qualitative and quantitative review of their valuations, performance relative to appropriate market indices, and their respective peer group and expected performance. Securities are either retained or replaced based on performance and other factors as determined by Soltis’ investment selection and monitoring criteria. Soltis has conducted due diligence on certain independent registered investment advisers and enters into written sub-advisory agreements to provide Investment Advisory Services to a selected portion of Soltis’ Client portfolios, as appropriate. Soltis may also enter into additional written sub-advisory agreements with other third-party registered investment advisers, from time to time, as it deems appropriate and in the best interests of its Clients. Soltis will monitor the selected sub- adviser(s) and may, from time to time and in its sole discretion, hire and/or replace any sub-adviser as part of its engagement to manage the Client’s portfolio(s) consistent with the Client’s objectives. The Client receives a copy of the disclosure document (Form ADV, Part 2, or other disclosure document in lieu of Part 2) of sub-advisers selected to manage all, or a portion of, a Client’s account assets. 3. Financial Planning and Consulting Services. Soltis may provide its Clients with a broad range of financial planning and consulting services, which may include advice on non-investment related matters. These services can include retirement plan analysis, retirement income analysis, estate preservation, charitable giving and asset protection strategies. In performing its services, Soltis is not required to verify any information received from the Client or from the Client’s other professionals (e.g., attorney, accountant, etc.) and is expressly authorized 2 That meet the minimum account threshold of $750,000.00 or greater  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 5 to rely on such information. Soltis may recommend the services of itself and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if Soltis recommends its own services or the services of its affiliates. The Client is under no obligation to act upon any of the recommendations made by Soltis under a financial planning or consulting engagement or to engage the services of any such recommended professional, including Soltis itself or any of its affiliates. The Client retains absolute discretion over all such implementation decisions and is free to accept or reject any of Soltis’ recommendations. Clients are advised that it remains their responsibility to promptly notify Soltis if there is ever any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Soltis’ previous recommendations and/or services. Soltis, in its sole discretion, may agree to provide advisory services to Clients that do not meet its minimum account size threshold. In these circumstances, not all of the above-referenced services may be available or provided in the same manner. Specific advisory services will be set forth in the Client Investment Advisory Agreement. 4. Pension/401(k) Consulting Advisory Services. Soltis also provides investment planning, implementation advice, and portfolio management assistance to 401(k) retirement and pension plans. As part of its services, Soltis works with its Clients to develop Investment Policy Statements which include asset allocation and investment recommendations. Soltis delivers written reports for review and discussion, on a quarterly basis, which include performance evaluations of each investment option and each portfolio, comparative performance for established benchmarks and for peer institutions, and assessment of asset allocation and if needed, for rebalancing. Additionally, Soltis’ relationship managers present reports to Clients or to Clients’ Investment Committees on at least an annual basis. The Soltis relationship manager will also assist its Client and/or the Client’s Investment Committee with regular reviews and updates of Investment Policy Statements including asset allocation, fund manager selection, and selection of appropriate benchmarks. Other services provided may include custodian review and analysis, ongoing research and education, and portfolio manager searches, including non-traditional asset classes. In addition, Soltis now provides limited 3(16) Plan Administrator services on behalf of Retirement Plans. Such services generally involve the review and approval of participant loan requests and disbursements, consulting on proper usage of forfeitures and ERISA budget accounts, filing Form 5500, and consulting on overall plan administration. In 2019, Soltis began to provide discretionary management services to its Pension and 401(k) Clients through the use of Collective Investment Trusts / Funds (“CIT / CIF”). CIT / CIFs look and act very much like mutual funds. However, CIT / CIFs are issued by a bank and are not registered with the Securities and Exchange Commission. The CIT / CIF units are not registered under the Investment Company Act of 1940, as amended, or other applicable law and are not securities registered under the Securities Act of 1933, as amended or applicable securities laws. CIT / CIFs are regulated by federal banking regulators, such as the Office of the Comptroller of the Currency and state banking regulators. CIT / CIF’s are only available to qualified retirement trusts such as 401k, Profit Sharing, Defined Benefit and government retirement plans. CIT / CIFs  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 6 offer the same kind of diversification as a mutual fund but also add an additional layer of fiduciary protection. CIT / CIFs generally provide a retirement vehicle that is much lower in cost than the typical mutual fund. In certain situations involving retirement plans, a conflict of interest may arise if Soltis receives compensation in connection with assets held in accounts on its wealth management platform that it would not have received if those assets had remained in a retirement plan or at another financial institution. For example, Soltis may receive advisory fees when providing services to an individual in connection with an IRA or other account held with Soltis. Soltis does not recommend or advise clients to roll over assets from a retirement plan, including a 401(k) plan managed by Soltis, to an IRA or other account managed by Soltis. Instead, Soltis provides education to clients regarding their available options upon separation from service or other distributable events, including maintaining assets in a current plan, rolling assets to a new employer’s plan, taking a distribution, or transferring assets to an IRA. Soltis may also discuss the services and investment solutions available on its wealth management platform. Clients who choose to transfer or roll over retirement assets to accounts managed by Soltis do so voluntarily. All such clients acknowledge in Soltis’ advisory agreement that the decision to roll over assets was made independently and was not the result of a recommendation by Soltis. No client is under any obligation to roll over retirement plan or IRA assets to an account advised by Soltis. To the extent Soltis provides services to retirement plans or plan participants, it will comply with applicable law, including the Investment Advisers Act of 1940 (the “Advisers Act”) and, where applicable, the Employee Retirement Income Security Act of 1974 (“ERISA”). Soltis addresses potential conflicts of interest through policies and procedures designed to ensure that clients receive fair and balanced information to support informed decision-making. Firm Advisory Assets As of December 31, 2025, Soltis provided advisory services with respect to approximately $12.99 billion dollars of client assets, which comprises approximately $12.04 billion in Assets Under Management and approximately $0.95 billion of Assets Under Advisement. ITEM 5. FEES AND COMPENSATION Soltis receives its compensation in the form of advisory fees as set forth below. As a policy, Soltis does not receive direct compensation from its recommended managers or other investments. Investment Advisory Fees Soltis’ investment advisory fees are computed quarterly based on the market value of the assets in the Client’s account. The investment advisory fee is billed and payable in advance on the first day of each calendar quarter and equals the market value of the assets in the Client’s account as of the last business day of the prior calendar quarter multiplied by the fee schedule below. Notwithstanding the foregoing, if the effective date of a Client’s investment advisory agreement is a date other than the first day of a calendar quarter, the first invoice will bill the Client (a) in  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 7 arrears for the period from the effective date to the end of the partial calendar quarter based upon the market value of the assets in the account as of the effective date, and (b) in advance for the first full calendar quarter, based upon the market value of the assets in the account as of the last business day of the partial calendar quarter. Annual % Fee Schedule Assets Under Management Up to $1,000,000 $1,000,000 - $2,000,000 $2,000,000 - $5,000,000 $5,000,000 - $10,000,000 Over $10,000,000 Marginal Fee Rate 1.25 1.15 .90 .80 To be negotiated with Client The above fees may vary depending upon the services provided and can be negotiated on an individual basis. Soltis’ annual management fee is exclusive of, and in addition to, brokerage commissions, transaction fees and other related costs and expenses that the Client may incur, including those by unaffiliated third-party custodians, investment managers/sub-advisers and investment funds. Soltis will not receive any portion of these commissions, fees and costs. For certain “qualified” accounts; performance-based fees may be offered. If the Client requests additional personal administrative or other special services (as distinguished from Soltis’ customary investment advisory services), Soltis may bill the Client separately for such other services at an hourly or fixed rate to be negotiated with the Client. Lower fees for comparable services may be available from other service providers. Investment advisory fees will be automatically deducted from Client’s brokerage accounts. If Client desires to make annual payments rather than quarterly, or wishes to pay the investment advisory fee directly rather than have it deducted from their account, the Client must notify Soltis of such intent in writing prior to the billing date. Financial Planning and Consulting Fees Soltis may charge fixed fees and monthly fees for financial planning and consulting services. These fees are negotiable, but generally range from $500 to $50,000 on a fixed fee basis and $2,500 to $6,000 per month on a monthly basis depending upon the level and scope of the professional financial planning and/or the consulting services required. If the Client engages Soltis for investment advisory services, Soltis may offset all or a portion of its fees for those services for the financial planning and/or consulting services. Prior to engaging Soltis to provide financial planning and/or consulting services, the Client is required to enter into a written agreement with Soltis setting forth the terms and conditions of the engagement. Self-Directed Fees If an account that forms part of a broader Client relationship with Soltis is self-directed (i.e., the Client directs trading in that account), and Soltis’ services related to that account are limited to trade execution and quarterly reporting, no investment advisory fee will be charged on the assets held in that account, and instead, Soltis may charge an account fee equal to the higher of $300 per  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 8 year or 0.25% per annum billed in the same manner as described above. The Client is responsible for all transaction fees and commission charges related to the account as described above. Sub-Advisory Fees Soltis may refer Clients to independent investment managers to act as sub-advisers in its sole discretion, subject to the investment guidelines provided by Soltis. The independent managers will arrange for the execution of securities transactions for the accounts through brokers or dealers that they believe will provide best execution. All or a portion of the account transactions may be placed away from the Client’s custodian if the independent managers believe this will result in best execution. Each independent manager’s advisory fee is payable in addition to Soltis’ fee and is debited separately by the custodian or is debited by Soltis and paid to the sub-adviser. Pension/401(k) Consulting Services Fees Soltis may determine to provide certain fiduciary consulting services to plan sponsors on a fixed fee basis. This fee generally starts at $25,000 but will be determined based on the scope of the services provided and risk associated with such services. ITEM 6. PERFORMANCE-BASED FEES and SIDE-BY-SIDE MANAGEMENT Soltis offers performance-based fees to “Qualified Clients” (as defined under the Advisers Act) under which a portion of the management fee is contingent upon the performance of specified asset classes outperforming their respective mutually agreed upon benchmarks. This fee arrangement may raise potential conflicts of interest. The performance-based fee may provide an incentive for Soltis to make investments that are riskier or more speculative than would be the case absent a performance fee arrangement. In addition, where Soltis charges performance-based fees and also provides similar services to accounts not being charged a performance-based fee, there could potentially be an incentive to favor accounts paying a performance-based fee. In order to mitigate any apparent conflict of interest, Soltis’ does not differentiate its investment management processes or strategies between performance fee and pure asset-based fee Clients. As such, Soltis is able to ensure that the investment advice provided to Clients is not affected by the structure of the fee that the Clients pay to Soltis. ITEM 7. TYPES OF CLIENTS Soltis provides investment advisory services to the following Clients: • Individuals and High Net Worth Individuals; • Institutions/Corporations; • Trusts, Endowments, Charitable Organizations & Foundations; and • Pension & 401(k) Plans In general, Soltis requires a minimum Client account size of $750,000. As previously discussed, in certain situations, Soltis may waive such minimum account size requirements in its sole discretion.  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 9 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Soltis utilizes a Manager or Investment Selection due-diligence process that includes both a Qualitative and Quantitative Evaluation. Based on this review, Soltis recommends the securities or combination of securities whose performance and investment characteristics are consistent with the Client’s stated investment objectives and risk profile as determined in the Client’s Investment Policy Statement or similar document. Quantitative Evaluation: Utilizing computer databases and security pricing services, Soltis monitors and analyzes the performance of selected securities, money managers, mutual fund managers and Exchange Traded Funds (ETFs). Managers are selected based on an number of criteria including performance in each respective asset class. Managers are evaluated on cost, performance relative to their respective asset class index, and their performance relative to peer group in terms of risk-adjusted return. Performance is measured in both positive and negative markets, in the short term (1-3 years), and in the long term (over a full market cycle). Generally, managers have at least 5 years proven, successful experience as a manager, and must have at least $50 million in assets under management. However, Soltis may select managers that don’t meet these criteria if other due diligence factors are satisfied. ETFs are selected based on asset class, sector, or market exposure to implement selected investment themes. When selecting individual equity securities for Client portfolios, Soltis employs valuation screens such as PE ratios, PEG ratios and earnings yield. In addition, fundamental analysis is performed on each company’s balance sheet strength, earnings and dividend history, debt to capital levels, as well as an analysis of the business strategy for each company. When selecting individual fixed income securities, Soltis considers credit quality, duration and Client-specific tax status. Qualitative Evaluation: Soltis also considers a number of qualitative factors in its evaluation of investment managers which includes some combination of the following: Industry Experience, Technical Knowledge and Application Investment Management Process (Theory and Implementation) • Education and Professional Designations • • Economic/Investment Research Capability • Scale Economies • Personnel to Support and Execute • • Client Communication & Service • Adherence to stated Investment Process, Style, and Objectives • Performance Measures • Business Evaluation of Manager Managers and other investments that meet Soltis’ Quantitative and Qualitative criteria are eligible to be included in the portfolio developed to accomplish the goals and objectives of each Client. Investments are replaced when they fail to comply with Soltis’ standards or are incompatible with Soltis’ forward-looking investment outlook. Clients are apprised of all investment changes.  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 10 Soltis does not guarantee the performance of any account or any specific level of performance, the success of any investment decision or strategy that Soltis may use, or the success of Soltis’ overall investment management. All investment decisions made for the Clients’ account by Soltis are subject to various market, currency, economic, political, and business risks, and those investment decisions will not always be profitable. Soltis will manage only the securities, options, cash, and other investments held in the Client’s account. However, in making investment decisions for the account, Soltis may consider other securities, options, cash, or other investments owned by the Client. Risk of Loss All investment strategies have certain risks that are borne by the investor. Soltis’ investment approach is mindful that investing in securities involves the risk of loss that Clients should be prepared to bear. Investment risks that Clients face include but are not limited to: • 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 particular underlying circumstances. • 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. • Credit Risk: The issuer of a bond or other debt security may fail to make timely interest or principal payments, which could reduce the value of the investment. • Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. Securities vary in the sensitivity of their prices to changes in inflation. • Foreign Investment and Currency Risk: Non-U.S. investments are subject to additional risks, including differences in accounting standards, political instability, changes in foreign regulations, and fluctuations in the value of the dollar against the currency of the investment’s originating country. • Emerging Markets Risk: Investments in emerging markets may be subject to higher political, economic, and currency risks than investments in developed markets. • 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. • 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 utility, which generates its income from a steady stream of customers who buy electricity regardless of the economic environment.  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 11 • 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 and private investment funds are not as liquid. Illiquidity affects both a Client’s ability to access assets in its account to meet spending needs, as well as their ability to rebalance their portfolio. In addition, investment funds in which client assets are invested may offer more liquidity than its underlying investments can support. This may result in the imposition of gates, delays in withdrawals, or forced sales of assets at unfavorable prices. • 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. • Valuation Risk: Certain investments may not have active markets. These investments may use estimated valuations using models or manager judgment, valuations that may be updated only quarterly or less frequently and valuations that may not reflect real-time market conditions. • Concentration Risk: Portfolios that are concentrated in particular asset classes, sectors, geographic region or securities may be more susceptible to adverse economic or market events affecting those areas. • Derivatives Risk: The use of derivatives for hedging or investment purposes may involve leverage, valuation challenges, counterparty risk, and the potential for significant losses. • Management Risk: The success of a Client’s portfolio depends on the ability of Soltis and the investment managers and funds with which it invests to select appropriate securities and manage risk effectively; there is no guarantee that these decisions will be profitable. • Cybersecurity and Operational Risk: Failures or breaches of electronic systems, including those of service providers, could result in financial losses or disruptions to account access. • Pandemic and Geopolitical Risk: Global events, such as pandemics, natural disasters, or geopolitical conflicts, may adversely affect financial markets and the performance of investments. Risk Factors relevant to certain instruments utilized include: Structured Notes: Structured notes are fixed income instruments that are issued by financial institutions with returns that are linked to or based on, among other things, equity indices, a single equity security, a basket of equity securities, interest rates, commodities, debt securities, exchange traded funds, and/or foreign currencies (a “Structured Note”). The security, asset, or index on which a Structured Note is based is often called the "Reference Instrument." Structured Notes have a fixed maturity date and include two components – a bond component and an embedded derivative. While some Structured Notes offer substantial protection of invested principal, others offer limited or no principal protection.  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 12 The embedded derivatives within Structured Notes adjust the note's risk/return profile by including additional modifying structures that can increase potential returns. The return performance of a Structured Note typically tracks the return profile of the underlying debt obligation and the derivative that is embedded within it. Instead of simply paying straight fixed or floating interest, Structured Notes can offer interest payments that are tailored to specific indices and/or rates. The derivative securities that are embedded in the Structured Note can also positively or negatively affect the redemption value and final maturity of the security. Depending on complexity, risk profile, and numerous other factors, Structured Notes often pay interest or coupon rates that are above the prevailing market rate. Many Structured Notes cap or limit the amount of upside participation in the Reference Instrument or underlying asset, particularly in cases where the Structured Note offers principal protection or pays interest that is above-market. Structured Notes are typically issued by investment banks or their affiliates and feature a fixed maturity date. Structured Notes are not suitable for everyone. All investors assume full credit risk of the security’s issuer and/or guarantor. This means that the investor may lose all the monies invested, including all initial amounts invested as principal protection may not apply, if the issuer and/or the guarantor become insolvent or fail in any way. Each Structured Note involves varying degrees of risk and unique suitability issues that investors must consider before investing in such securities. Structured Notes involve important legal and tax consequences and investment risks, which each investor should discuss with qualified financial, accounting, and tax advisors regarding the suitability of the specific Structured Note in light of each investor’s particular circumstances Private Placements and Alternative Investments: These include unregistered securities such as private equity, private real estate, private credit, venture capital, hedge funds, interests in limited partnerships and limited liability companies and similar offerings. These offerings are often subject to legal or other restrictions on transfer and redemptions since a liquid market often does not exist for these types of securities. Investors might not be able to redeem when desired and realize previously provided market value or even fair value when sold. Determining the fair market value of private investments can be difficult and the expense of owning private investments and partnerships is generally higher than when compared to public offerings. These investments are subject to a variety of risks as outlined in the offering materials for each particular investment. Their value will generally fluctuate with among other things the financial conditions of the obligors on or issuers of assets, general economic conditions, the condition of certain financial markets, political developments and developments or trends in the particular industries invested in. With respect to synthetic securities, the value is often also impacted by the financial condition of the related synthetic security counterparties and the obligors or issuers of the underlying obligations. Private investments are subject to lower reporting requirements and are less transparent and less liquid than  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 13 traditional investments. Alternative investments may also raise tax issues that investors should discuss with their tax advisors. While the above information provides a synopsis of certain factors that may affect a client’s investments, this list is not exhaustive. All investment programs have certain risks that are borne by the investor. Soltis’ investment approach keeps the risk of loss in mind, and seeks investments with return potential that adequately compensates its Clients for the risks. Clients should understand that there are inherent risks associated with investing and depending on the risk occurrence; clients may suffer LOSS OF ALL OR PART OF THE CLIENT’S PRINCIPAL INVESTMENT. ITEM 9. DISCIPLINARY INFORMATION This item requests information relating to legal and disciplinary events in which Soltis or any supervised persons, as defined by the Advisers Act, have been involved that are material to Client’s or prospective Client’s evaluations of Soltis’ advisory business or management. There are no reportable material legal or disciplinary events related to Soltis or any of its supervised persons. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Soltis’ affiliate, Soltis Tax Solutions, LLC (“Soltis Tax”), may provide tax return preparation and filing services to Soltis’ clients. If a client elects to engage Soltis Tax to provide such tax services, the client will be requested to engage Soltis Tax pursuant to a separate engagement letter. In such event, Soltis Tax may or may not charge a separate fee for the preparation or filing of the tax returns of Soltis’ clients; fees for such services may be bundled into the investment advisory fee a client pays to Soltis. A client is not required to use Soltis Tax’s services, and if the client elects not to use Soltis Tax services the client may be able to negotiate a lower overall investment advisory fee with Soltis. Because there may be no identifiable portion of the investment advisory fee attributable to the tax services provided by Soltis Tax, however, opting out of the tax services provided by Soltis Tax does not necessarily mean that a client’s investment advisory fee will be lower, and any reduction in fee will be negotiated by Soltis in its sole discretion. ITEM 11. CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS AND PERSONAL TRADING Soltis has implemented an investment policy relative to personal securities transactions by its employees. This investment policy is part of Soltis’ overall Code of Ethics which serves to establish a standard of business conduct for all of Soltis’ Associated Persons that is based upon fundamental principles of openness, integrity, honesty and trust. A copy of the Code of Ethics is available upon request. In accordance with Section 204A of the Advisers Act, Soltis also maintains and enforces written policies reasonably designed to prevent the misuse of material non-public information by Soltis or any person associated with Soltis.  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 14 Soltis has adopted procedures to implement and monitor the firm’s policy on personal securities transactions, which include the following: • The firm’s Chief Compliance Officer maintains a list of the firm's Investment Adviser Representatives which is updated periodically. • Employees are required to identify any personal investment accounts and any accounts in which the employee has a beneficial interest, including any accounts held by immediate family members residing with the employee, confirm holdings upon hire, quarterly thereafter and upon opening or closing any account(s). These accounts are reviewed using Soltis’ compliance monitoring software. • Employees must report all required information for covered personal securities transactions within ten (10) days of being hired and within thirty (30) days of the end of each calendar quarter to the Compliance Officer or other designated officer. • The Chief Compliance Officer, or his designee, maintains appropriate records of the firm's Investment Adviser Representatives, and reports of personal securities transactions, among other things. • The Chief Compliance Officer, or his designee, will review all employees’ reports of personal securities transactions for compliance with the firm’s policies, including the Insider Trading Policy, regulatory requirements and the firm’s fiduciary duty to its Clients, among other things. ITEM 12. BROKERAGE PRACTICES 1. Research and Other Soft Dollar Benefits: Although not a material consideration when determining whether to recommend that a Client utilize the services of a particular broker-dealer/custodian, Soltis may receive from a broker- dealer/custodian (or a mutual fund company), without cost (and/or at a discount) support services and/or products, certain of which assist Soltis to better monitor and service Client accounts maintained at such institutions. Included within the support services that may be obtained by Soltis may be investment-related research, pricing information and market data, software and other technology that provide access to Client account data, compliance and/or practice management- related publications, discounted or gratis consulting services, discounted and/or gratis attendance at conferences, meetings, and other educational and/or social events, marketing support, computer hardware and/or software and/or other products used by Soltis in furtherance of its investment advisory business operations. As indicated above, certain of the support services and/or products that may be received assist Soltis in managing and administering Client accounts. Others do not directly provide such assistance but rather assist Soltis to manage and further develop its business enterprise. Soltis’ Clients do not pay more for investment transactions effected and/or assets maintained at a particular broker-dealer/custodian as a result of this arrangement. There is no corresponding  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 15 commitment made by Soltis to any particular broker-dealer/custodian or to any other entity to invest any specific amount or percentage of Client assets in any specific mutual funds, securities or other investment products as a result of the above arrangement. 2. Directed Brokerage: The Client may direct Soltis to use a particular broker-dealer (subject to Soltis’ right to decline and/or terminate the engagement) to execute some or all transactions for the Client’s account. In such event, the Client will negotiate terms and arrangements for the account with that broker- dealer, and Soltis will be unable to seek better execution services or prices from other broker- dealers or be able to "bunch" the Client’s transactions with orders for other Client’s accounts managed by Soltis. As a result, the Client may pay higher commissions or other transaction costs or greater spreads or receive less favorable net prices on transactions for the account than would otherwise be the case. 3. Bunched Orders: Soltis seeks to execute orders for its Clients fairly and equitably. Soltis follows written procedures pursuant to which it may, for Clients who permit it, and to the extent consistent with Best Execution, combine purchase or sale orders for the same security for multiple Clients (sometimes called “bunching”) so that they can be executed at the same time. The procedures for bunching trades may differ depending on the particular strategy or type of investment. Soltis is not required to bunch or aggregate orders if it determines that bunching or aggregating is not practicable. When Client orders are bunched by Soltis, the order will be placed with the broker-dealer custodian for execution. When a bunched order is completely filled, Soltis generally will allocate the securities purchased or proceeds of sale among participating accounts based on the purchase or sale order. Adjustments or changes may be made by Soltis under certain circumstances, such as to avoid odd lots or excessively small allocations. If the bunched order is filled at different prices, through multiple trades, generally all such participating accounts will receive the average price. When a bunched order is partially filled, Soltis’ procedures provide that the securities are to be allocated in a manner deemed fair and equitable to Clients. Securities must be allocated proportionately based upon the relative size of the particular Client’s pre-trade designation. 4. Participation in Fidelity Wealth Advisor Solutions®: Soltis participates in the Fidelity Wealth Advisor Solutions® Program (the “WAS Program”), through which Soltis receives referrals from Strategic Advisers LLC (“Strategic Advisers”), a registered investment adviser and Fidelity Investments company. Soltis is independent of and not affiliated with Strategic Advisers or any Fidelity Investments company. Strategic Advisers does not supervise or control Soltis, and Strategic Advisers has no responsibility or oversight for Soltis’ provision of investment management or other advisory services. Under the WAS Program, Strategic Advisers acts as a solicitor for Soltis, and Soltis pays referral fees to Strategic Advisers for each referral received based on Soltis’ assets under management attributable to each client referred by Strategic Advisers or members of each client’s household. The WAS Program is  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 16 designed to help investors find an independent investment adviser, and any referral from Strategic Advisers to Soltis does not constitute a recommendation by Strategic Advisers of Soltis’ particular investment management services or strategies. More specifically, Soltis pays the following amounts to Strategic Advisers for referrals: the sum of (i) an annual percentage of 0.10% of any and all assets in client accounts where such assets are identified as “fixed income” assets and (ii) an annual percentage of 0.25% of all other assets held in client accounts. In addition, Soltis has agreed to pay Strategic Advisers an annual program fee of $50,000 to participate in the WAS Program. These referral fees are paid by Soltis and not the client. To receive referrals from the WAS Program, Soltis must meet certain minimum participation criteria, but Soltis has been selected for participation in the WAS Program as a result of its other business relationships with Strategic Advisers and its affiliates, including Fidelity Brokerage Services, LLC (“FBS”). As a result of its participation in the WAS Program, Soltis has a conflict of interest with respect to its decision to use certain affiliates of Strategic Advisers, including FBS, for execution, custody and clearing for certain client accounts, and Soltis could have an incentive to suggest the use of FBS and its affiliates to its advisory clients, whether or not those clients were referred to Soltis as part of the WAS Program. Under an agreement with Strategic Advisers, Soltis has agreed that Soltis will not charge clients more than the standard range of advisory fees disclosed in its Form ADV 2A Brochure to cover solicitation fees paid to Strategic Advisers as part of the WAS Program. Pursuant to these arrangements, Soltis has agreed not to solicit clients to transfer their brokerage accounts from affiliates of Strategic Advisers or establish brokerage accounts at other custodians for referred clients other than when Soltis’ fiduciary duties would so require, and Soltis has agreed to pay Strategic Advisers a one-time fee equal to 0.75% of the assets in a client account that is transferred from Strategic Advisers’ affiliates to another custodian therefore, Soltis has an incentive to suggest that referred clients and their household members maintain custody of their accounts with affiliates of Strategic Advisers . However, participation in the WAS Program does not limit Soltis’ duty to select brokers on the basis of best execution. 5. Charles Schwab & Co.: Charles Schwab & Co. (“CS&Co”) acts as a custodian for certain Soltis clients. Following is a more detailed description of CS&Co.’s support services. CS&Co.’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of Client assets. The investment products available through CS&Co. include some to which Soltis might not otherwise have access or that would require a significantly higher minimum initial investment by Soltis Clients. CS&Co.’s services described in this paragraph generally benefit the Client and the Client’s account. CS&Co. also makes available to Soltis other products and services that benefit Soltis but may not directly benefit the Client or its account. These products and services assist Soltis in managing and administering Soltis Clients’ accounts. They include investment research, both Schwab’s own and that of third parties. Soltis may use this research to service all or some substantial number of Soltis Clients’ accounts, including accounts not maintained at CS&Co. In addition to investment research, CS&Co. also makes available software and other technology that: provide access to Client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple Client  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 17 accounts; provide pricing and other market data; facilitate payment of Soltis fees from Clients’ accounts; and assist with back-office functions, recordkeeping, and Client reporting. CS&Co. also offers other services intended to help Soltis manage and further develop Soltis’ business enterprise. These services include educational conferences and events; technology, compliance, legal, and business consulting; publications and conferences on practice management and business succession; and access to employee benefits providers, human capital consultants, and insurance providers. CS&Co. may provide some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to Soltis. CS&Co. may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. The availability of services from CS&Co. benefits Soltis because Soltis does not have to produce or purchase them. Soltis does not have to pay for these services, and they are not contingent upon Soltis committing any specific amount of business to CS&Co. in trading commissions or assets in custody. With respect to the Service, as described above under Item 4 Advisory Business, Soltis does not pay certain fees so long as Soltis maintains certain minimum Client asset levels and meets other conditions. In light of Soltis’ arrangements with CS&Co., Soltis may have an incentive to recommend that Clients maintain their accounts with CS&Co. based on Soltis interest in receiving CS&Co.’s services that benefit Soltis business rather than based on the Client’s interest in receiving the best value in custody services and the most favorable execution of transactions. This is a potential conflict of interest. It is Soltis’ belief, however, that Soltis’ selection of CS&Co. as custodian and broker is in the best interests of Soltis Clients. It is primarily supported by the scope, quality, and price of CS&Co.’s services and not Schwab’s services that benefit only Soltis. Soltis has adopted policies and procedures designed to ensure that Soltis’ use of CS&Co.’s services is appropriate for each Client. Tyler Finlinson, President of Soltis, serves on the Schwab Retirement Business Services Advisory Board (the “Board”). In certain situations where it is in the best interests of the client, Soltis may recommend that its employee benefit plan sponsor clients establish accounts with CS&Co. and/or Charles Schwab Bank (collectively “Schwab”) to maintain custody of the employee benefit plan sponsor clients’ employee benefit plans’ assets and effect trades for the accounts established at Schwab for such plans. Further, Charles Schwab Bank may also serve as directed trustee for an employee benefit plan’s assets. The Board consists of representatives of independent investment advisory or independent recordkeeping firms who have been invited by Schwab management to participate in meetings and discussions of Schwab Retirement Business Services’ services for independent investment advisory and/or recordkeeping firms and their employee benefit plan sponsor clients. Board members serve three-year terms. Board members enter nondisclosure agreements with Schwab under which they agree not to disclose confidential information shared with them. This information generally does not include material nonpublic information about the Charles Schwab Corporation, whose common stock is listed for trading on the New York Stock Exchange and the NASDAQ stock market (symbol SCHW). The Board meets in person approximately twice per year and has periodic conference calls scheduled as needed. Board members are not compensated by Schwab for their service, but Schwab does pay for or reimburse Board members’ travel, lodging, meals and other incidental expenses incurred in attending Board meetings.  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 18 ITEM 13. REVIEW OF ACCOUNTS Soltis provides its Clients with a Quarterly Performance Review. This Review includes the Client’s portfolio performance over various periods consistent with the Client’s Investment Policy Statement or similar document. Adjustments are made as necessary to the Client’s portfolio based on this review. Portfolio performance measures are calculated and reported on a uniform and consistent basis according to industry conventions. Clients generally receive comprehensive annual reviews which may include the following: • Portfolio performance in terms of investment goals and objectives • Compliance with the Client’s Investment Policy Statement or similar document • Comparison of portfolio performance with relevant asset class indices • Reallocation of assets among new or additional asset classes, securities or independent investment managers Soltis also provides Clients with regular communications which provide a natural forum for Soltis to share market commentary, asset allocation shifts, investment selection changes, tax strategies, and new investment opportunities. The above-referenced reviews may differ in substance or frequency for those Soltis Clients that do not meet its minimum account size. Specifics of these services will be set forth in the Client agreement. ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION As discussed in Item 12 Brokerage Practices, Soltis participates in the WAS Program, wherein Strategic Advisers acts as a Solicitor/Endorser for Soltis, and Soltis pays referral fees to Strategic Advisers for each referral received based on Soltis’ assets under management attributable to each Client referred by Strategic Advisers or members of each Client’s household. For more information regarding this arrangement please refer to Item 12 Brokerage Practices. Soltis receives an economic benefit from Schwab in the form of the support products and services it makes available to Soltis. These products and services, how they benefit Soltis, and the related conflicts of interest are described above under Item 12 Brokerage Practices. The availability to Soltis of Schwab’s products and services is not based on Soltis giving particular investment advice, such as buying particular securities for Soltis’ Clients. Soltis currently has agreements with other third parties to act as compensated Endorsers for the Firm. Under these Endorsement Agreements, Soltis pays the Endorser between 20 and 60 percent of the advisory fees paid by referred Clients to Soltis. The percentage of the advisory fee to be paid to the Endorser is jointly determined by Soltis and the Endorser, primarily based upon the projected amount of investment advisory services and fees generated by the referred clients. Soltis’ Advisory fees do not differ between referred and non-referred accounts but are determined based on the level of assets managed. Certain terms of the agreement with the Endorser are  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 19 disclosed in writing to referred Clients in a Disclosure Statement in accordance with Rule 206(4)- 1 (Marketing Rule) of the Advisers Act. From time to time, Soltis hosts client conferences, educational events, or similar gatherings for clients and prospective clients. These events are designed to provide market insights, investment updates, and educational content to assist Clients in understanding Soltis’ investment philosophy and services. Certain third parties including sub-advisers, custodians, fund sponsors, or other service providers used or recommended by Soltis may contribute to or sponsor portions of these events. Sponsorships may include financial support or in-kind contributions (such as covering venue, meal, or material costs). Such sponsorships present a potential conflict of interest because they may create an incentive to favor, utilize, or recommend the products or services of those sponsors over other service providers that do not provide similar support. To mitigate these conflicts, Soltis: • Does not condition participation in or recommendations of any service provider on such sponsorships; • Discloses sponsor participation to attendees where appropriate; and • Continues to make all investment and manager selections based solely on the best interests of its Clients and in accordance with its fiduciary duty. ITEM 15. CUSTODY Soltis does not maintain physical custody of any Client assets. However, Soltis’ Advisory Agreement authorizes Soltis to debit the Client’s account for the amount of its advisory fee and directly remit that fee to Soltis in accordance with applicable custody rules. The custodians recommended by Soltis have agreed to send a statement to the Client, at least quarterly, indicating all amounts disbursed from the account including the amount of management fees paid directly to Soltis. In addition, Soltis also sends periodic supplemental reports to Clients. Clients should carefully review the statements sent directly by the Custodians and compare them to those received from Soltis. Soltis evaluates the asset protection, product offerings, execution capabilities, reporting, and fee structure of available Custodians. Soltis provides value to its individual Clients by passing on the benefits of its institutional economies to offer institutionally priced products and services in many cases. Unless directed otherwise, Soltis shall generally recommend several nationally recognized, SEC registered and Financial Industry Regulatory Authority (“FINRA”) member broker- dealer/custodians for its Client investment management assets. The ultimate choice of custodian rests with the Client. The SEC issued a no-action letter on February 21, 2017 (the "SEC No-Action letter") stating that an adviser with a Standing Letter of Authorization ("SLOA") arrangement with a Client to transfer assets to a third-party is deemed to have custody of those assets. Accordingly, the adviser is required to comply with the SEC’s Custody Rule (“Custody Rule”). However, the SEC does  Soltis Investment Advisors, LLC (SEC #801-71833) March 2026 Page 20 provide relief from enforcement of the Custody Rule’s “annual surprise audit” requirement if the adviser follows and satisfies the guidance provided in the SEC’s no-action letter. Soltis effects third party asset transfers in Client accounts using a SLOA. Soltis has instituted procedures and controls such that it can comply with the requirements set forth in the SEC No- Action letter and avoid the annual surprise audit requirement. ITEM 16. INVESTMENT DISCRETION Soltis typically is granted discretionary authority by the Client at the outset of an advisory relationship to select the investments to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular Client account. When selecting securities and determining amounts, Soltis observes the investment policies, limitations and restrictions of the Clients for which it advises. Investment guidelines and restrictions must be provided to Soltis in writing and must be accepted by Soltis. ITEM 17. VOTING CLIENT SECURITIES Soltis has adopted formal proxy voting policies and procedures in compliance with Advisers Act Rule 206(4)-6. These proxy voting policies and procedures are designed to ensure that proxies are voted in the best interests of Clients and are available to Clients upon request. Clients may also obtain voting information from Soltis regarding their securities. independent Prior to voting, Soltis will verify whether an actual or potential conflict of interest with Soltis or any interested person exists in connection with the subject proposal(s) to be voted upon. If a material conflict of interest exists, Soltis will determine whether it is appropriate to disclose the conflict to the affected Clients, to give the Clients an opportunity to vote the proxies themselves, or to address the voting issue through other objective means such as voting in a manner consistent with a predetermined voting policy or receiving an third party voting recommendation. ITEM 18. FINANCIAL INFORMATION Based upon Soltis’ business practices, use of a qualified custodian and advisory fee procedures, the SEC does not require the disclosure of financial information. Please be advised that there are no known financial conditions that would impair Soltis’ ability to meet contractual commitments to Clients. Soltis has not been the subject of any bankruptcy petition or filing.  SOLTIS INVESTMENT ADVISORS, LLC PRIVACY NOTICE March 31, 2026 Soltis is an SEC-registered investment adviser committed to protecting the confidentiality and security of client information. We comply with the privacy and safeguarding provisions of the Gramm-Leach- Bliley Act (“GLBA”) and Regulation S-P, as amended, and maintain written policies and procedures reasonably designed to protect customer information. AN IMPORTANT NOTICE CONCERNING OUR CLIENTS’ PRIVACY CLIENT INFORMATION WE COLLECT: We collect and develop personal information about you, and some of that information is non-public personal information (“Client Information”). This information may include: Financial information and account data Investment objectives and transaction history Information received from account applications and other forms Information developed in servicing your account • Personal and household information • • • • Client Information may include “customer information” and “sensitive customer information” as those terms are defined under Regulation S-P, such as Social Security numbers, driver’s license or passport numbers, account numbers, and other information that could permit unauthorized access to your financial accounts. HOW WE USE AND SHARE INFORMATION We use Client Information to: • Provide investment advisory services • Process transactions • Service and maintain accounts • Comply with legal and regulatory requirements We may share Client Information with our affiliates, including Soltis Tax Solutions, LLC for purposes of marketing our services to you or providing services to you, as permitted by law. Clients may opt out of our sharing of their “eligibility information,” which includes information about creditworthiness, income/assets, investment experience, and account history, with our affiliates for marketing purposes by notifying us at any time, and we will honor such request promptly in accordance with applicable law. We do not sell Client Information and do not disclose such information to non-affiliated third parties except as permitted or required by law. DATA SECURITY: We restrict access to Client Information to those representatives and employees who need the information to perform their job responsibilities within our firm. We maintain a written information security program that includes administrative, technical, and physical safeguards designed to protect Client Information through its lifecycle including its disposal. These safeguards include risk assessments, access controls, encryption where appropriate, monitoring and testing of systems, secure disposal of information, and oversight of service providers, in accordance with applicable federal regulations.  DATA INCIDENT RESPONSE AND NOTIFICATION: We maintain written policies and procedures designed to detect, respond to, and recover from unauthorized access to or use of Client Information. If we determine that your sensitive Client Information has been accessed or used without authorization in a manner that presents a risk of harm or inconvenience, we will provide you with notice as required by Regulation S-P and other applicable laws. USE AND DISCLOSURE OF CLIENT INFORMATION: To administer, manage and service Client accounts, process transactions and provide related services to your accounts, it is necessary for us to provide access to Client Information within our firm and to non-affiliated companies such as other investment advisors, broker/dealers and custodians. Service providers with access to Client Information are required to maintain appropriate safeguards and to notify us of any unauthorized access or use of such information. We may also provide Client Information outside of our firm as permitted by law, such as to government entities, consumer reporting agencies or other third parties in response to subpoenas. FORMER CLIENTS: If the account with our firm is closed, we will continue to operate in accordance with the principles stated in the Client Privacy Notice.