Summa Global Advisors, LLC

JUNE 09, 2026 UPDATED: JUNE 2026  FORM ADV PART 2A BROCHURE JUNE 09, 2026 SUMMA GLOBAL ADVISORS 12901 SE 97TH AVE, STE 390 CLACKAMAS, OR 97015 (503) 636.2022 INFO@SUMMAGLOBAL.COM This Form ADV Part 2A brochure provides information about the qualifications and business practices of Summa Global Advisors, LLC (“Summa”). If you have any questions about the contents of this brochure, please contact us at (503) 636.2022 or info@summaglobal.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Summa is available on the SEC’s website at www.adviserinfo.sec.gov.  ADV 2A Page 3 ITEM 2: SUMMARY OF MATERIAL CHANGES Summa has had no material changes since the last annual updating amendment to this brochure in March 2025. We will update this brochure and summarize in this Item 2 (or a separate standalone summary of material changes) the occurrence of any material changes with respect to our business practices in accordance with applicable law. All current clients will receive a Summary of Material Changes to this and subsequent Brochures within 120 days of the close of our fiscal year (i.e., December 31) and certain additional updates regarding material changes concerning our firm and our business practices as they may occur. Updated information concerning these changes will be provided to you free of charge. A Summary of Material Changes is also included within our brochure found on the SEC’s website at www.adviserinfo.sec.gov. To request the latest brochure (ADV 2), please give us a call at (503) 636.2022 or email info@summaglobal.com. Our Brochure will be provided to you free of charge. Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 4 ITEM 3: ADV 2A TABLE OF CONTENTS Item 2: Summary of Material Changes ..............................................................................................................................................3 Item 3: ADV 2A Table of Contents ......................................................................................................................................................4 Item 4: Advisory Business ....................................................................................................................................................................5 Firm Description ............................................................................................................................................................................................................... 5 Principal Owners ............................................................................................................................................................................................................... 5 Types of Services ............................................................................................................................................................................................................... 5 Individual Client Needs and Restrictions .......................................................................................................................................................................... 5 Assets Under Management ................................................................................................................................................................................................ 5 Item 5: Fees and Compensation ...........................................................................................................................................................6 Summa Fee Schedule ....................................................................................................................................................................................................... 6 Separate Account Manager (SAM) Fees ............................................................................................................................................................................ 6 Other Fees .......................................................................................................................................................................................................................... 6 Termination of Service .......................................................................................................................................................................................................... 7 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 Analysis and Strategies .................................................................................................................................................................................................... 7 Economic Benefits Received ............................................................................................................................................................................................. 8 Risk of Loss ......................................................................................................................................................................................................................... 8 Item 9: Disciplinary History .................................................................................................................................................................8 Item 10: Other Financial Industry Activities and Affiliations .....................................................................................................8 Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading .........................................9 Participation or Interest in Client Transactions ............................................................................................................................................................. 9 Item 12: Brokerage Practices ..............................................................................................................................................................9 Broker Selection ................................................................................................................................................................................................................ 9 Trading Practices ........................................................................................................................................................................................................... 10 Item 13: Review of Accounts ............................................................................................................................................................. 11 Reporting* ...................................................................................................................................................................................................................... 12 Item 14: Client Referrals and Other Compensation ..................................................................................................................... 12 Item 15: Custody .................................................................................................................................................................................. 12 Item 16: Investment Discretion ........................................................................................................................................................ 12 Item 17: Voting Client Securities ...................................................................................................................................................... 12 Item 18: Financial Information ......................................................................................................................................................... 13 Privacy Policy........................................................................................................................................................................................ 14 Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 5 ITEM 4: ADVISORY BUSINESS Firm Description Summa Global Advisors, LLC (“Summa”) was founded in November of 2008 to provide customized portfolio management for individuals and families. We provide continuous service and advice to our clients concerning their financial situation and the investments under supervision. Based in the Portland metropolitan area, we strive to build long-term relationships with clients to achieve their financial goals and objectives. This partnership includes portfolio management, wealth management, and various aspects of financial planning. Principal Owners Summa is owned by Summa Global Holdings, Inc. (“SGH”). SGH, in turn, is owned and controlled by Henry Yu, President, and Valerie Tucker, Vice President and Secretary, whose ownership percentages are as follows: Henry Yu, 60%; and Valerie Tucker, 40%. Types of Services PORTFOLIO MANAGEMENT Summa adopts portfolio management processes that are consistent with the objectives and guidelines established within each client relationship. When providing individual financial advice, we take into account the client’s net worth, asset holdings, risk tolerance, time horizon, liquidity requirements, estate plan, tax liabilities, and any other relevant considerations. In addition, we may provide investment advice regarding asset allocation, income requirements, and other related matters. These services are rendered upon client request or at such times as we determine that the investment, or reinvestment, of assets is appropriate. FINANCIAL AND RETIREMENT PLANNING For clients who utilize Summa’s portfolio management services, financial and retirement planning is included in their fees. Should a client desire financial planning only, this service is offered under a separate contract in a Financial Planning Services Agreement and is billed based on the scope and complexity of the review. Individual Client Needs and Restrictions Summa selects securities for each client to create a portfolio that meets their individual investing needs and preferences. As a result, no two accounts are exactly the same. These securities may include some or all of the following: stocks, no-load open-end mutual funds or closed-end funds (CEFs), exchange-traded funds (ETFs), master limited partnerships (MLPs), non-traded securities, individual bonds, and cash equivalents. The client may, if they wish, impose reasonable restrictions regarding investing in certain geographical locations, companies, or industries. The client may also request that we buy certain securities on their behalf or give an opinion about investing in a particular company. On occasion, Summa may suggest utilizing non-traded securities or Separate Account Managers1 in order to reach a certain financial objective, such as reducing taxes or maximizing income, or to diversify the investment strategy of a portfolio. Assets Under Management As of December 31, 2025, Summa managed $132,880,161 in discretionary assets and $11,243,237 in non-discretionary assets. Discretionary assets include accounts managed by Summa internally as well as assets managed by Separate Account Managers (SAMs). 1 For more information, please see Separate Account Managers under Item 8 Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 6 ITEM 5: FEES AND COMPENSATION All of Summa’s income is derived from the fees received for the services we provide. We encourage clients to allow direct fee deduction from their accounts. This helps streamline the billing process and minimize the cost to the client. If there are extenuating circumstances, we can make an exception to these procedures and bill the client in another manner. Invoices are included as part of the quarterly Portfolio Reports delivered to clients. Separate invoices can be provided upon request. To give clients time to review their reports, verify the fee amounts, and contact us with questions, we withdraw fees five business days after mailing the invoices. All invoices include the fee rate, the market value on which it is computed, and the amount of the fee to be deducted. Summa Fee Schedule Summa charges an annual fee based on a percentage of the client's assets. Clients are billed quarterly, and in advance, based upon the market value of their assets at the end of the previous quarter. STANDARD FEE SCHEDULE ▪ 1.00% of market value up to $1,000,000 ▪ 0.75% of market value from $1,000,001 to $2,000,000 ▪ 0.50% of market value from $2,000,001 to $5,000,000 ▪ Negotiable over $5,000,000 The actual percentage charged to each client is negotiable and depends on several factors. Summa will not change fees without a 30-day advanced written notice. On occasion, we consult on investment and financial planning issues for a one-time fixed fee ranging between $1,000 and $20,000 depending on the scope and complexity of the review. Upon engagement, a non-refundable deposit of 50% is required with the balance due upon completion. Separate Account Manager (SAM) Fees Summa charges an annual fee of 0.50% on separately managed accounts under its care. The SAM will also charge their own fees on these accounts. These fee schedules can be provided upon request and should also be provided by the SAM as part of their management agreement with the client. Other Fees In addition to the stated management fees that Summa charges, clients may incur additional, trading- related expenses charged to their accounts by the custodian at which their account is held. These will be reported on their monthly broker account statements and trade confirmations and may include the following: ▪ ▪ commissions for equity or fixed income trades (charged by the broker executing the trades); transaction fees on certain mutual funds that are not on the broker’s no-transaction-fee fund list. These funds are usually of institutional class with the lowest expense ratio compared with other classes of the same fund, when available; ▪ prime brokerage fee on trades executed through a third-party broker (primarily bond transactions). Other administrative fees such as wire fees and margin interest expenses are non-investment related and are usually incurred while executing a client request. Summa will keep these expenses to a minimum by letting the client know when a request has a custodian-related processing fee and advising them on any alternatives that may be less expensive. These additional fees are not received by or paid to Summa, but to the custodian, and are deducted directly from the client account in which the transaction occurs. We do not have any employees who receive, directly or indirectly, any Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 7 compensation from the transaction of securities or investments that are purchased or sold in your account. For more information and details about brokerage practices, refer to Item 12. Termination of Service Summa bills quarterly and in advance. Upon termination, a refund will be issued to the client for any unearned fees. The refund will be calculated on a pro-rata basis. If terminated within 5 business days of the signing of the contract, or the beginning of a quarter, no fees will be charged. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge any performance-based fees. ITEM 7: TYPES OF CLIENTS Summa’s clients are primarily individuals and families. We also advise several family trusts and charitable foundations. Minimum account size is $500,000, but we reserve the right to waive the minimum. ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES, AND RISK OF LOSS Analysis and Strategies Summa’s goal is to tailor investment strategies to meet the individual needs of each client. To accomplish this goal, we communicate with clients regularly to discuss their personal and financial goals, gifting desires, and charitable interests. This information, along with financial information such as income needs, risk tolerance, time horizon to invest, the size and arrangement of estate, and tax minimization strategies, allows us to build an investing framework upon which to structure the client’s portfolio. We build client portfolios with securities that have appreciation potential and diversification value. The attractiveness of a security is based upon the quality of its fundamentals. In all cases, quality, sustainable, well-run businesses are what we seek to choose for clients. For smaller accounts, Summa normally utilizes ETFs and mutual funds to build the asset allocation necessary for the specific client’s need. For larger accounts, asset allocation is built using individual equities, mutual funds, ETFs, and bonds as well as separate account managers for specific mandates. Since Summa believes in the benefits of long-term investing, all purchases are made with the intention of holding the security long-term. There may be instances, however, when a change in the client’s situation, the valuation of the security, a fundamental shift in the business or industry, or change of expected returns of a security or the whole asset class, would cause us to hold a particular security for only a short time. We also utilize passive investments and/or active managers to add specific exposure to a client’s portfolio. The passive investments are index-based while the active investments may include mutual funds, ETFs, non-traded securities, and other money managers. INCOME STRATEGY We vary the duration (length/maturity dates) of our fixed income holdings in an effort to increase returns and limit potential losses. Additionally, we may choose to diversify the income allocation of a client’s portfolio into various assets which have low historical correlations to equities. These may include active or passive allocations to alternatives, high- yield stocks or bonds, convertibles, or REITs, in addition to traditional fixed-income holdings. Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 8 When selecting strategies for a client’s fixed income allocation, we consider the following: 1) whether the strategy is appropriate for the client’s goals, 2) whether the cash flow is stable and predictable, and 3) whether there is a proven track record or performance data. We also consider the quality of holdings and the cost to clients (such as management fees and/or expense ratios). We only utilize no-load or load-waived mutual funds. EQUITIES Summa’s equity selection process consists of two aspects: fundamental and technical. The fundamental aspect focuses on evaluating the economic and business environment and the quality of a company (i.e. company fundamentals, consistent growth, and reasonable valuations). The technical approach looks at the overall market trends, price movements, trading volume, various technical indicators, and charts. When selecting strategies for a client’s equity allocation, we consider the following: 1) whether the strategy is appropriate for client’s goals, 2) whether the investment philosophy is similar or complementary to Summa’s as well as the client’s and, 3) whether there is a proven track record or performance data. SEPARATE ACCOUNT MANAGERS Summa may, at times, suggest the use of Separate Account Managers (SAMs) to further diversify investments, achieve specific portfolio objectives, and/or enhance tax efficiency. Our goal is to utilize managers who have a history of applying strict buy-and-sell disciplines within their asset class and strategy. We provide ongoing monitoring of these managers to verify that they are achieving portfolio objectives. Fees for separate account managers are paid in addition to our fees. We reduce the fees we charge on these accounts in order to reduce the total expense to the client. Not all of our clients will be able to utilize SAMs, who generally have their own minimum account size requirements. OTHER SECURITIES Summa does not limit investments to common stocks or equity mutual funds. Exchange-traded funds (ETFs), master limited partnerships (MLPs), non-traded securities and real estate investment trusts (REITs), to name a few, are other equity securities that will be utilized if they meet certain selection criteria. We strive to remain objective in the decision-making process through independent thinking and synthesizing comments and opinions by analysts, industry experts, and economists. Economic Benefits Received Custodians offer research, business practice advice, and compliance guidance in return for using their services. Risk of Loss ALL INVESTMENTS INVOLVE RISK. While we seek to protect our clients from loss, it is inevitable that, at some point, portfolio holdings will lose value. ITEM 9: DISCIPLINARY HISTORY Summa and its employees have no reportable disciplinary history. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Summa and its employees do not have any other financial industry activities or affiliations. Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 9 ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS, AND PERSONAL TRADING Summa abides by a code of ethics that establishes rules of conduct for all employees. Our employees are prohibited from engaging in fraudulent, deceptive, or manipulative conduct. Compliance involves more than acting with honesty and good faith alone; it means that we have a duty to act solely in the best interest of our clients. Our code of ethics is distributed to each employee at the time of hire and annually. Employees must acknowledge that they have read and agree to act according to the code. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interests ahead of yours. Our employees are subject to the following specific fiduciary obligations when dealing with clients: ▪ The duty to have a reasonable, independent basis for the investment advice provided; ▪ The duty to obtain best execution for a client’s transactions where the firm is in a position to direct brokerage transactions for the client; ▪ The duty to ensure that investment advice is suitable to meeting the client’s individual objectives, needs and circumstances; and ▪ A duty to be loyal to clients. *A copy of our code of ethics is available upon request. Participation or Interest in Client Transactions Summa employees and their related persons may buy or sell for themselves securities that we also recommend for clients. Summa’s employees must always put client interests ahead of their own. Client accounts shall be given priority in the transaction of securities. Employees are restricted from any new purchases and sales until all client trades have been executed. Our employees are required to obtain preapproval for all exchange-traded securities transactions to avoid conflicts. Various exceptions exist for personal securities trades that do not involve potential conflicts, such as Treasury bonds, open-end mutual funds, and certificates of deposit (CDs). All employees are prohibited from trading on any non-public (insider) information. Any violation of this prohibition will be grounds for dismissal. Summa will disclose to clients any conflict of interest which could reasonably be expected to impair the rendering of unbiased and objective advice. ITEM 12: BROKERAGE PRACTICES Broker Selection Currently we work primarily with two custodians: Charles Schwab & Co. (Schwab) and Fidelity Investments (Fidelity). Summa is independently owned and operated and not affiliated with either Schwab or Fidelity. The decision to use these broker/dealers was made upon consideration of several factors including the following: service quality, trade execution capability, electronic account data access, pricing, research reports, and the overall expense to clients. Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 10 Both Schwab and Fidelity, on occasion, provide us with discounts on various practice management tools, including seminars, software, and other business needs. These services listed above are provided to us, by the broker, at no extra cost to the client. The availability of these services benefits us because we do not have to produce them or pay for them. We believe that the recommendation of Schwab and Fidelity as custodians and brokers is in the best interest of our clients. TECHNOLOGY AND ACCESS Summa receives technological support from Schwab and Fidelity in the form of daily data downloads and electronic access to client accounts. Additionally, these broker/dealers provide individual clients online access to their accounts. Summa can help clients set up online access to their accounts. BEST EXECUTION It is Summa's policy to deal fairly and honestly with clients and to use best efforts to obtain the most favorable execution. We have adopted standards to help ensure that we are providing the best service possible to our clients. These standards address the monitoring of trades, compliance with federal mandates, and our fiduciary obligation with respect to executing discretionary trades on behalf of clients. We also monitor broker/dealers’ institutional platforms and custodial services to provide our clients with the best capabilities and services available. DIRECTED BROKERAGE Although we recommend that clients establish accounts at Schwab or Fidelity, it is ultimately the client’s decision where to custody assets. Summa is independently owned and operated and not affiliated with either Schwab or Fidelity. Clients may direct us to use a different brokerage firm but should understand that their decision may result in certain costs or disadvantages. These costs and disadvantages may include higher commissions and account maintenance fees as well as increased difficulty in trading and reporting. Other negative effects could include reduced ability to negotiate volume discounts, or provide best execution, and the inability to aggregate trades with those of other clients. Also, some brokers/custodians do not provide access to the least expensive mutual fund classes or ETFs that we prefer. Trading Practices COMMON STOCKS AND EXCHANGE-TRADED FUNDS When Summa decides to purchase or sell securities for a particular strategy, the trading often involves several accounts. In these circumstances, we aggregate trades to ensure fairness in execution and pricing across client accounts. When trades result from reviews of individual client accounts, then aggregation of trades will be less likely as the timing of review, investment strategy, and securities involved may not coincide with other planned trades for the day. Summa neither benefits nor receives any incentives whether trades are aggregated or not. If and when it is assessed, clients pay the commission directly to the custodian for executing the trades. BONDS Summa’s purchase and sale of individual bonds is different from the process of buying and selling equities. While fixed income mutual funds, ETFs, and closed-end funds are listed and traded on the major exchanges, individual fixed-income issues are purchased from or sold to brokers or dealers. Each broker/dealer maintains an inventory of bonds (bond positions) that it owns as a principal and holds for resale to its customers. The number and value of bonds that each broker holds varies, depending on the brokerage firm’s size, financial strength, and involvement in the bond market. For our clients, we first search the broker’s inventory where client assets are custodied for lower costs and simplicity. If an appropriate issue (quality, quantity, and price) cannot be obtained, we then contact a third-party broker who is not affiliated with any custodian to see if comparable bonds can be found. Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 11 Bonds are purchased after determining the desired type of issuer, sector, maturity, coupon and yield objectives. The broker is asked to offer all such issues available, noting the required block size for all clients using that broker and/or custodian. Sometimes it is in the client’s best interest for us to trade with an outside broker because it can give clients access to better- priced, more attractive securities from several dealers. By aggregating the purchases or sales of a broader base of clients, including those who use other brokers and/or custodians, Summa may be able to find additional bonds available in larger blocks, resulting in better overall prices. PRIME BROKERAGE When appropriate, Summa will ask permission from clients to add prime brokerage to their accounts. This allows us to place trades with brokers other than the client account’s custodian. Prime brokerage is subject to minimum account value and carries a small processing fee assessed by the custodian. It is primarily used for fixed income transactions. CASH SWEEP PROGRAM Investment portfolios often include a cash allocation to maintain liquidity, manage risk, and provide funds for opportunistic investments. Cash allocations can serve as a buffer against market volatility and ensure funds are readily available for future investment opportunities or withdrawals. Sweep programs automatically transfer uninvested cash from a brokerage account into a money market fund or other short-term investment vehicle at the custodian. This process is automated and occurs regularly, often at the end of each business day. While the cash is held in the sweep account, it earns interest. This ensures that even idle cash generates some return, albeit typically lower than other investment options. By automating cash movement, sweep programs reduce the need for manual transfers, saving time and minimizing the risk of human error in managing cash balances. Sweep accounts provide quick access to cash for reinvestment or withdrawals, enhancing liquidity management within the portfolio. Minimizing manual cash management tasks reduces administrative burdens for investors and advisors, allowing them to focus on strategic investment decisions. Sweep programs often offer lower interest rates than short-term investments like high-yield savings accounts or CDs. This is due to their liquidity and convenience. While convenient, the lower interest rates mean that investors can miss out on higher returns if cash is kept in the sweep account for extended periods. The advisor uses sweep programs strategically to manage cash flows within a portfolio, ensuring that cash is readily available for investment opportunities without sacrificing significant returns. Sweep accounts can also be used to facilitate regular transactions, such as automatic withdrawals for living expenses or periodic investments in other asset classes. While sweep programs offer convenience and liquidity, they require careful consideration as part of an overall investment strategy. Advisors and clients should weigh the benefits of liquidity and automation against the potential for higher returns through alternative cash management strategies. ITEM 13: REVIEW OF ACCOUNTS Summa begins each client relationship with a full financial review. This review is an integral part of understanding what must be done to implement the client-specific investment strategy. We maintain close contact with the client throughout this process. All accounts under management are monitored continually by our portfolio managers to watch for changes happening in the holdings, in the market, or in the client’s financial situation. We communicate and/or meet with clients on an ongoing basis to discuss their financial needs and any alterations that should be made to their investment objectives. Should the communications reveal a change in the client’s circumstances, interests, or objectives, their accounts will be reviewed as part of the process of adjusting their individual investment strategy. We also perform a thorough review of a client’s accounts and investment strategy upon notification of major life events such as marriage, divorce, birth of a child, or death of spouse to accommodate these changes in the client’s investment approach. Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 12 Reporting* Summa delivers reports of the client’s accounts at the end of each calendar quarter electronically and/or via post-mail, based on the client’s preference. These reports include the following: TOTAL PORTFOLIO OVERVIEW: ▪ Consolidated Portfolio Allocation Chart, by asset class ▪ Consolidated Portfolio Summary, by asset class FOR EACH ACCOUNT INDIVIDUALLY: Individual Account Performance Review Individual Account Holdings Statement ▪ ▪ BILLING INVOICE *A sample copy of Summa’s quarterly report is available upon request. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Summa is not currently compensating anyone for client referrals. ITEM 15: CUSTODY All client accounts are custodied at unaffiliated, qualified broker/dealers. We do not have hands-on access to client assets. Generally, monthly account statements are provided by the custodian. If there is no activity in the account, the broker will send statements quarterly. The custodians notify us if they experience any difficulties with delivery to clients. Clients are encouraged to carefully review these statements and compare them to Summa’s quarterly reports. We do not act as a qualified custodian for client assets or accounts. Under the Adviser’s Act, however, Summa is deemed to have custody of client assets if written authorization, such as a Standing Letter of Authorization (SLOA), to transfer funds between client accounts or to deduct management fees is provided. Any other asset movements to third parties must be separately authorized by the client. ITEM 16: INVESTMENT DISCRETION In most cases, Summa has discretionary authority of investments on the accounts it advises. A “discretionary” account is one in which Summa will determine which securities are to be bought or sold, as well as the size and timing of these transactions. The client may, if they wish, impose reasonable restrictions regarding investing in certain geographical locations, companies, or industries. The client may also request that we buy certain securities on their behalf or give an opinion about investing in a particular company. ITEM 17: VOTING CLIENT SECURITIES Summa accepts proxy-voting responsibility and regularly votes, by default, to support the management recommendations of the subject company. When Summa votes a client’s proxy, clients do not direct the vote. Summa will always vote in support of the recommendation of management which eliminates a conflict of interest that could apply if Summa voted based on factors that may or may not be more beneficial to the firm verses the Client. Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 13 Summa does not vote on the following proxies: 1) proxies that arrive after the meeting date; 2) proxies for securities held in a non-discretionary and/or unsupervised portion of a client's account (unless client directs otherwise); 3) proxies that are managed and/or voted by a Separate Account Manager (SAM). If you would like to know how we voted proxies in your account, please contact us. ITEM 18: FINANCIAL INFORMATION Because we do not require or solicit prepayment of client fees six months or more in advance, this item is inapplicable. We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to our clients and have not been the subject of a bankruptcy proceeding. Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 14 PRIVACY POLICY OUR COMMITMENT TO YOU Summa Global is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your investment advisor as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. Summa Global (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. Summa Global does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. WHY YOU NEED TO KNOW Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. WHAT INFORMATION DO WE COLLECT FROM YOU? Employment Information and or Government ID Date of birth Social security or taxpayer identification number Assets and liabilities Name, address and phone number(s) Income and expenses E-mail address(es) Investment activity Account information (including other institutions) Investment experience and goals WHAT INFORMATION DO WE COLLECT FROM OTHER SOURCES? Custody, brokerage and advisory agreements Account applications and forms Other advisory agreements and legal documents Investment questionnaires and suitability documents Transactional information with us or others Other information needed to service your account HOW DO WE PROTECT YOUR INFORMATION? To safeguard your personal information from unauthorized access and use we maintain physical, procedural and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com  ADV 2A Page 15 HOW DO WE SHARE YOUR INFORMATION? Summa Global shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No SERVICING OUR CLIENTS. We may share non-public personal information with non-affiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, consultants or other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. No Not Shared MARKETING PURPOSES. Summa Global does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where Name of Firm or the Client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Yes Yes AUTHORIZED USERS. Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s). No Not Shared INFORMATION ABOUT FORMER CLIENTS. Summa Global does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients. Other Important Information Information for California, North Dakota, and Vermont Customers. In response to applicable state law, if the mailing address provided for your account is in California, North Dakota, or Vermont, we will automatically treat your account as if you do not want us to disclose your personal information to non-affiliated third parties for purposes of them marketing to you, except as permitted by the applicable state law. CHANGES TO OUR PRIVACY POLICY We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. YOUR RIGHT TO OPT OUT Pursuant to applicable data privacy laws you may exercise your right to opt out of: • The sale or sharing of your personal data; • Targeted advertising or cross-context behavioral advertising; • Profiling in furtherance of automated decision-making. ANY QUESTIONS? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (503) 636-2022 or by email at info@summaglobal.com Summa Global | wealth redefined 12901 SE 97th Ave, Ste 390, Clackamas, OR 97015 | 503.636.2022 | summaglobal.com