TEVIS INVESTMENT MANAGEMENT, LLC

Item 1. Cover Page PART 2A OF FORM ADV FIRM BROCHURE October 15, 2025 TEVIS INVESTMENT MANAGEMENT LLC 5700 West Plano Parkway, Suite 3800 Plano, TX 75093 Phone: (972) 971-2169 Fax: (972) 767-3501 www.tevisinvest.com This brochure provides information about the qualifications and business practices of Tevis Investment Management LLC. If you have any questions about the contents of this brochure, please contact Ryan Tevis, Chief Compliance Officer, by telephone at (972) 971-2169 or by email at ryan@tevisinvest.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 Tevis Investment Management LLC also is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD#: 167750. Please note that the use of the term “registered investment adviser” and description of Tevis Investment Management LLC and/or our associates as “registered” does not imply a certain level of skill or training. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees.  Item 2. Material Changes A. If we amend our brochure and it contains material changes from our last annual update, we are required to identify and discuss those changes. 1) Since our last annual amendment filing dated February 2024, there have been no material changes to our Firm Brochure. We will provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Our Brochure may be requested by contacting us at our main number above. Additional information about Tevis is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s website provides information about any persons affiliated with Tevis who are registered, or are required to be registered, as investment adviser representatives of Tevis. 2  Item 3. Table of Contents Item 1. Cover Page ......................................................................................................................................................... 1 Item 2. Material Changes .............................................................................................................................................. 2 Item 3. Table of Contents .............................................................................................................................................. 3 Item 4. Advisory Business .............................................................................................................................................. 4 Item 5. Fees and Compensation ................................................................................................................................... 5 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 ............................................................................ 8 Item 9. Disciplinary Information .................................................................................................................................. 18 Item 10. Other Financial Industry Activities and Affiliations ........................................................................................ 18 Item 11. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading .................................... 19 Item 12. Brokerage Practices ....................................................................................................................................... 20 Item 13. Review of Accounts or Financial Plans ........................................................................................................... 22 Item 14. Client Referrals and Other Compensation ..................................................................................................... 23 Item 15. Custody ......................................................................................................................................................... 23 Item 16. Investment Discretion ................................................................................................................................... 24 Item 17. Voting Client Securities .................................................................................................................................. 24 Item 18. Financial Information ..................................................................................................................................... 25 3  Item 4. Advisory Business A. Description of our advisory firm, including how long we have been in business and our principal owner(s). 1) Tevis Investment Management LLC is dedicated to providing our clients with a wide array of investment advisory services. We specialize in comprehensive portfolio management and financial planning and consulting. Our firm is a limited liability company formed in the State of Texas. I have been in business since 2000 and registered as an investment adviser since 2012. The firm is owned by William Ryan Tevis, President. B. Description of the types of advisory services we offer. 1) Comprehensive Portfolio Management: Our Comprehensive Portfolio Management service encompasses asset management as well as providing financial planning/financial consulting to clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person, if possible, otherwise via telephone conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds, mutual funds, individual stocks or bonds, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least quarterly. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Our firm requires an account minimum of $500,000.00 to open an account, but may be waived at our discretion. 2) Independent Managers We may utilize Independent Money Managers, where we may design an investment portfolio and provide ongoing corresponding comprehensive Portfolio Management services on a fee- only basis for a percentage of assets in conjunction with another investment advisory firm. This compensation is typically equal to a percentage of the overall investment advisory fee charged by our firm. The advisory fee paid to Independent Managers shall be negotiable in certain circumstances but shall never exceed the overall amount in our published fee statement. Before selecting other advisers, we make sure that the other advisers are properly licensed or registered. 4  3) Financial Planning We provide a variety of financial planning and consulting services to individuals, families and other clients regarding the management of their financial resources based upon an analysis of the client’s current situation, goals, and objectives. Generally, such financial planning services will involve preparing a financial plan or rendering a financial consultation for clients based on the client’s financial goals and objectives. This planning or consulting may encompass one or more of the following areas: Investment Planning, Retirement Planning, Estate Planning, Charitable Planning, Education Planning, Corporate and Personal Tax Planning, Cost Segregation Study, Corporate Structure, Real Estate Analysis, Mortgage/Debt Analysis, Insurance Analysis, Lines of Credit Evaluation, Business and Personal Financial Planning. Implementation of the recommendations will be at the discretion of the client. C. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs of clients, whether clients may impose restrictions on investing in certain securities or types of securities. 1) We offer individualized investment advice to clients utilizing our firm’s Comprehensive Portfolio Management services. Additionally, we offer general investment advice to clients utilizing our Financial Planning and consulting service. D. Restrictions on Investing in Certain Securities or Types of Securities: 1) Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Additionally, we will manage legacy positions within our portfolio management. E. Is there a different brochure that we need to deliver to our wrap fee clients? 1) We do not sponsor or participate in a wrap fee program. Clients pay our advisory fee and separate transaction and custody costs. F. Disclosure of the amount of client assets we manage on a discretionary basis and the amount of client assets we manage on a non-discretionary basis. 1) As of December 31, 2024, discretionary assets under management were $198,844,912 and non-discretionary assets under management were $7,616,784. Item 5. Fees and Compensation We are required to describe our brokerage, custody, fees, and fund expenses so you will know how much you are charged and by whom our advisory services provided to you. Our fees are generally negotiable. A. Description of how we are compensated for our advisory services provided to you. 1) Comprehensive Portfolio Management: 5  Maximum Fee Schedule Assets Under Management Annual Percentage of Assets Charge $0 to $500,000 $500,001 to $1,000,000 1.75% 1.50% $1,000,001 to $3,000,000 1.25% $3,000,001 to $10,000,000 1.10% Over $10,000,00 Negotiable Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of your account on the last day of the previous quarter. In addition to our advisory fee, you will pay custody, brokerage and transaction costs charged by your custodian or broker. Investments such as mutual funds and ETFs bear their own internal expenses. We do not receive any portion of these fees. You can find more information about transaction costs and fund expenses in your custodial agreement and in fund prospectuses 2) Independent Managers: In addition to, Clients pay 25 basis points to 75 basis points of the overall advisory fee to Independent Managers for their services, the Independent Manager will deduct their fee from client accounts quarterly in arrears based on the value of the account on the last business day of the quarter. 3) Financial Planning and Consulting: Financial Planning and Consulting services are included in the advisory fees listed above for Comprehensive Portfolio Management. B. Description of whether we deduct fees from clients’ assets or bill clients for fees incurred. 1) Comprehensive Portfolio Management: Our firm’s fees are billed on a pro-rata annualized basis quarterly in advance based on the value of your account on the last day of the previous quarter. Fees will be automatically deducted from your managed account. In rare cases, we will agree to direct bill clients. The initial fee is due on the first of the calendar quarter following the day the account is funded and is prorated according to the number of days remaining in the calendar quarter. Thereafter, the quarterly fee is based on the account asset value on the last day of the respective calendar quarter. Fees are calculated by first calculating the annual fee and then pro-rating by the number of days in the quarter (actual/365). As part of this process, you understand and acknowledge the following: i. Your independent custodian sends statements at least quarterly to you showing all disbursements for your account, including the amount of the advisory fees paid to us; 6  and ii. You provide authorization permitting us to be directly paid by these terms. C. Description of any other types of fees or expenses clients may pay in connection with our advisory services, such as custodian fees or mutual fund expenses. 1) Clients may incur transaction charges for trades executed in their accounts. These transaction fees are separate from our fees and will be disclosed by the firm that the trades are executed through. Tevis Investment Management’s fees are exclusive of brokerage commissions, transaction fees, 12b-1 fees and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer fees, transfer taxes, lost certificate fees, wire transfer and electronic fund fees, postage, and handling for paper delivery of statement and trade confirmations, margin and pre-payment fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to our fee, and Tevis Investment Management or its Investment Advisor Representatives shall not receive any portion of these commissions, fees, and costs. Please see Item 12 for more information regarding brokerage practices. Some mutual funds pay 12(b)-1 service fees (normally 0.25% per year) to the Custodian. The mutual funds the Firm could purchase or recommend offer a variety of share classes, including some that do not charge 12(b)-1 fees and are, therefore, less expensive. These fee arrangements will be disclosed upon request of a client and are available in the applicable fund‘s prospectus. Typically, we do not recommend mutual funds that charge 12(b)-1 fees when other share classes are available. However, there are instances in which we would recommend a mutual fund that carries a 12(b)-1 fee, even when a lower-cost share class is available for the same fund. For example, a lower-cost class share may not be available to Tevis Investment Management’s due to investment minimums. In other cases, mutual funds charging 12(b)-1 fees are transferred back to the client. In which case the Firm may recommend the client holds the existing share class, instead of selling the fund and buying a lower-cost share, which could result in a tax liability. In addition, mutual funds charging 12(b)-1 fees will be recommended when the overall cost is seen as a benefit to the client if the anticipated transaction fees exceed the anticipated 12(b)-1 fees. When recommending a particular mutual fund share class, the different available share classes are compared and reviewed along with the anticipated investment timeframe, potential tax consequences, future anticipated transactions, and other costs to determine the best selection for the client at that time. Tevis Investment Management does not receive any part of the fees charged by Mutual Funds. D. We must disclose if client’s advisory fees are due quarterly in advance. Explain how a client may obtain a refund of a pre-paid fee if the advisory contract is terminated before the end of the billing period. Explain how you will determine the amount of the refund. 7  1) We charge our advisory fees quarterly in advance. In the event that you wish to terminate our services, we will refund the unearned portion of our advisory fee to you via check. You need to contact us in writing and state that you wish to terminate our services. Upon receipt of your letter of termination, we will proceed to close out your account and process a pro-rata refund of unearned advisory fees. E. Commissionable securities sales. 1) We do not sell securities for a commission. In order to sell securities for a commission, we would need to have our associated persons registered with a broker-dealer. We have chosen not to do so. Item 6. Performance-Based Fees and Side-By-Side Management A. If we or any of our supervised persons accepts performance-based fees, fees based on a share of capital gains on or capital appreciation of the assets of a client, we are required to disclose this fact. 1) We do not charge performance fees to our clients. Item 7. Types of Clients A. Description of the types of clients to whom we generally provide investment advice, such as individuals, trusts, investment companies, or pension plans. If we have any requirements for opening or maintaining an account, such as a minimum account size, disclose the requirements. 1) We have the following types of clients: Individuals; • • High Net Worth Individuals; • Trust Accounts; • Pension and Profit-Sharing Plans; • Corporations, limited liability companies and/or other business types. 2) We do not have requirements for opening and maintaining accounts or otherwise engaging us. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss A. Description of the methods of analysis and investment strategies we use in formulating investment advice or managing assets. 1) Methods of Analysis: • Charting. In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when how long the trend may last and when that trend might reverse. 8  • Fundamental Analysis. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. • Technical Analysis. We analyze past market movements and apply that analysis to the presenting an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement. • Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. 2) Investment Strategies we use: • Long-term purchases. When utilizing this strategy, we may purchase securities with the idea of holding them for a relatively long time (typically held for at least a year). A risk in a long-term purchase strategy is that by holding the security for this length of time, we may not take advantages of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. • Short-term purchases. When utilizing this strategy, we may also purchase securities with the idea of selling them within a relatively short time (typically a year or less). We do this in an attempt to take advantage of conditions that we believe will soon result in a price swing in the securities we purchase. • Trading. We purchase securities with the idea of selling them very quickly (typically within 30 days or less). We do this in an attempt to take advantage of our predictions of brief price swings. • Short sales. We borrow shares of a stock for your portfolio from someone who owns the stock on a promise to replace the shares on a future date at a certain price. Those borrowed shares are then sold. On the agreed-upon future date, we buy the same stock and return the shares to the original owner. We engage in short selling based on our determination that the stock will go down in price after we have borrowed the shares. If we are correct and the stock price has gone down since the shares were purchased from the original owner, the client account realizes the profit. • Margin transactions. Margin and short strategies are used only in eligible accounts with client consent. When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your brokerage firm. If you choose to borrow funds through a margin account, securities purchased are the firm's collateral for the loan to you. If the securities in your account decline in value, so does the value of the collateral supporting your loan, and, as a result, the firm can take action, such as issue a margin call and/or sell 9  securities or other assets in any of your accounts held with the member, in order to maintain the required equity in the account. Investing with margin is characterized by unique risks including amplified losses due to increased leverage; margin calls; forced liquidations; and additional fees including margin interest charges. In order to manage margin risk, we recommend leveraging responsibly (borrowing less than the amount available); keeping a diversified portfolio; and monitoring the account and evaluating risk regularly. Before investing on margin, be sure to read the Margin Disclosure Statement provided by your custodian. 3) Risk of Loss: Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and your account(s) could enjoy a gain, it is also possible that the stock market may decrease, and your account(s) could suffer a loss. It is important that you understand the risks associated with investing in the stock market, are appropriately diversified in your investments, and ask us any questions you may have: • Active Management Risk Due to its active management, a portfolio could underperform other portfolios with similar investment objectives or strategies. • Allocation Risk A portfolio may use an asset allocation strategy to pursue its investment objective. There is a risk that a portfolio’s allocation among asset classes or investments will cause a portfolio to lose value or cause it to underperform other portfolios with a similar investment objective or strategy or that the investments themselves will not produce the returns expected. • Alternative Risk Alternative investments include other additional risks. Lock-up periods and other terms obligate Clients to commit their capital investment for a minimum period, typically no less than one or two years and sometimes up to 10 or more years. Illiquidity is considered a substantial risk and will restrict the ability of a Client to liquidate an investment early, regardless of the success of the investment. Alternative investments are difficult to value within a Client’s total portfolio. There may be limited availability of suitable benchmarks for performance comparison; historical performance data may also be limited. In some cases, there may be a lack of transparency and regulation, providing an additional layer of risk. Some alternative investments may involve the use of leverage and other speculative techniques. As a result, some alternative investments may carry substantial additional risks, resulting in the loss of some or all the investment. Using leverage and certain other strategies will result in adverse tax consequences for tax-exempt investors, such as the possibility of unrelated business taxable income, as defined under the U.S. Internal Revenue Code. • Capitalization Risk Small-cap and mid-cap companies may be hindered due to limited resources or less diverse products or services. Their stocks have historically been more volatile than the stocks of larger, more established companies. • Call Risk Some bonds allow the issuer to redeem the bond before its maturity date. If an issuer exercises this option during declining interest rates, the proceeds from the bond may have 10  to be reinvested in an investment offering a lower yield and may not benefit from an increase in value due to declining rates. Callable bonds are also subject to increased price fluctuations during market illiquidity or rising interest rates. Finally, the capital appreciation potential of a bond will be reduced because the price of a callable bond may not rise much above the price at which the issuer may call the bond. • Commodity Risk The fluctuation in the prices of commodities causes uncertainties about future market values and the size of future income. These commodities may be grains, metals, gas, electricity, etc. • Company Risk The risk related to a Firm’s business plans, stock valuation, profitability, accounting practices, growth strategy, and other factors particular to a company rather than the overall market. Some of these risks cannot be predicted, such as the retirement or death of a senior executive, which may lead to negative performance in the future. • Concentration Risk Strategies concentrated in only a few securities, sectors or industries, regions or countries, or asset classes could expose a portfolio to greater risk. They may cause the portfolio value to fluctuate more widely than a diversified portfolio. Overexposure to certain sectors or asset classes (e.g., MLPs, REITs, etc.) may be detrimental to an investor if there is a negative sector move. • Credit Risk The credit rating of an issuer of a security is based on, among other things, the issuer’s historical financial condition and the rating agencies’ investment analyses at the time of rating. An actual or perceived deterioration of the ability of an issuer to meet its obligations would harm the value of the issuer’s securities. • Currency Risk If an account invests directly in non-U.S. currencies or in securities that trade in and receive revenues in non-U.S. currencies or in derivatives that provide exposure to non- U.S. currencies, it will be subject to the risk that those currencies will decline in value relative to the U.S. dollar. Currency rates in foreign countries may fluctuate significantly over short periods for several reasons, including changes in interest rates, intervention (or the failure to intervene) by U.S. or foreign governments, central banks, or supranational entities such as the International Monetary Fund, or by the imposition of currency controls or other political developments in the United States or abroad. As a result, an account’s investments in non-U.S. currency-denominated securities may reduce the account's returns. Foreign currency exchange transactions are conducted on a spot (i.e., cash) basis at the spot rate prevailing in the foreign currency exchange market or through entering forward contracts to purchase or sell the currency. • Cybersecurity Risk Increased Internet use makes a portfolio susceptible to operational and informational security risks. In general, cyber incidents can result from deliberate attacks or unintentional events. Cyberattacks include but are not limited to infection by computer viruses or other malicious software code, gaining unauthorized access to systems, networks, or devices through “hacking” or other means to misappropriate assets or sensitive information, corrupting data, or causing operational disruption. Cybersecurity failures or breaches of third-party service providers may cause disruptions at third-party 11  service providers and impact our business operations, potentially resulting in financial losses; the inability to transact business; violations of applicable privacy and other laws, regulatory fines, or penalties; reputational damage; unanticipated expenses or other compensation costs; or additional compliance costs. Our Firm has an established business continuity and disaster recovery plan and related cybersecurity procedures designed to prevent or reduce the impact of such risks; there are inherent limitations in such plans and systems due in part to the evolving nature of technology and cyberattack tactics. • Deflation Risk When inflation or expectations are low, the value and income of an account’s investments in inflation-linked securities could fall, resulting in losses. • Digital Asset & Crypto Currency Risk Digital assets and the securities derived from them (including ETFs and mutual funds) are highly speculative and historically subject to extreme price volatility. Prices can fluctuate significantly over short periods due to market sentiment, regulatory developments, technological advancements, or macroeconomic events. The legal and regulatory environment for cryptocurrencies and digital asset investments is rapidly evolving. Changes in regulation - either domestically or globally - could adversely affect the value, liquidity, or legality of certain digital asset-based funds. Future actions by regulatory authorities may restrict or otherwise impact the operation, marketing, or underlying holdings of these funds. • Equity Risk Equity instruments are subject to equity market risk, the risk that common stock prices fluctuate over short or extended periods. Equity securities have greater price volatility than fixed-income securities. The market price of equity securities may increase or decrease, sometimes rapidly or unpredictably. Equity securities may decline in value due to factors affecting markets, industries, sectors or geographic regions represented in those markets, or individual security concerns. • Event Risk The possibility is that an unforeseen event will negatively affect a company or industry and, thus, increase security volatility. • Emerging Markets Risk The risks of foreign investing are heightened for securities of companies in emerging market countries. In most cases, emerging market countries' economic and political structures do not compare favorably with the U.S. or other developed countries regarding wealth and stability. Their financial markets often lack liquidity. In addition to all the risks of investing in foreign developed markets, emerging market securities are susceptible to governmental interference, local taxes on investments, restrictions on gaining access to sales proceeds, and less efficient trading markets. These factors can make emerging market investments more volatile and less liquid than investments in developed markets. • ETF & ETN Risk ETFs and ETNs are, by definition, portfolios of securities. Although the unsystematic risk associated with investments in ETFs and ETNs may be low relative to investments in securities of individual issuers, some events can trigger sharp, and sometimes adverse, price movements in ETFs and ETNs unrelated to the markets' general activities. These include unexpected dividends, changes to regular dividend amounts, events announcements of rights offerings, and possible unexpected revisions to the net asset values of the ETF and ETN. ETFs are subject to market risk, whereas ETNs are subject to 12  both market risk and the credit risk of the issuer of the ETN. Further, certain Client accounts may hold (or short-sell) positions in volatility-related ETFs and ETNs. Leveraged ETFs and mutual funds, sometimes labeled “ultra” or “2x,” for example, are designed to provide a multiple of the underlying index’s return, typically daily. Inverse products are designed to provide the opposite of the underlying index's return, typically daily. These products differ and can be riskier than traditional ETFs and mutual funds. Although these products are designed to provide returns that correspond to the underlying index, they may not be able to exactly replicate the performance of the index because of fund expenses and other factors. This is referred to as a tracking error. Continual re-setting of returns within the product may add to the underlying costs and increase the tracking error. As a result, this may prevent these products from achieving their investment objective. In addition, compounding of the returns can produce a divergence from the underlying index over time, particularly for leveraged products. Return distortions may be magnified in highly volatile markets with significant positive and negative swings. Some deviations from the stated objectives to the positive or negative are possible and may or may not correct themselves over time. These products use various strategies to accomplish their objectives, including swaps, futures contracts, and other derivatives. These products may not be diversified and can be based on commodities or currencies. These products may have higher expense ratios and be less tax-efficient than more traditional ETFs and mutual funds. • Fixed Income & Debt Risk Debt securities are affected by changes in interest rates. When interest rates rise, the value of debt securities is likely to decrease. Conversely, when interest rates fall, the values of debt securities are likely to increase. The values of debt securities may also be affected by changes in the issuing entities' credit rating or financial condition. • Foreign Investing Risk Investments in securities of foreign issuers may involve risks, including adverse fluctuations in currency exchange rates, political instability, confiscations, taxes, restrictions on currency exchange, difficulty in selling foreign investments, and reduced legal protection. These risks may be more pronounced for investments in developing countries. • Frequent Trading Risk A portfolio Manager may actively and frequently trade investments in a portfolio to carry out its investment strategies. Frequent trading of investments increases the possibility that a portfolio, as relevant, will realize taxable capital gains (including short-term capital gains, which are typically taxable at higher rates than long-term capital gains for U.S. federal income tax purposes), which could reduce a portfolio's after-tax return. Frequent trading can also mean higher brokerage and other transaction costs, which could reduce a portfolio's return. The trading costs and tax effects of portfolio turnover can adversely affect its performance. • Geographic Concentration Risk If an account concentrates its investments in a particular geographic region or country, its performance is closely tied to the market, currency, social, political, economic, environmental, and regulatory conditions within that country or region. These conditions include anticipated or actual government budget deficits or other financial difficulties, levels of inflation and unemployment, fiscal and monetary controls, and political and social instability in such countries and regions. As a result, the account is likely to be more volatile than an account with more geographically diverse investments. 13  Industry or Sector Risk • An account that focuses its investments in specific industries or sectors is more susceptible to developments affecting those industries and sectors than a more broadly diversified fund. Issuers in a single industry can react similarly to market, economic, industry, social, political, regulatory, and other conditions. For example, suppose an account has significant investments in technology companies. In that case, the account may perform poorly during a downturn in one or more industries or sectors that heavily impact technology companies. Interest Rate Risk • When interest rates increase, the value of the account’s investments may decline, and the account’s share value may decrease. This effect is typically more pronounced for intermediate and longer-term obligations. This effect is also typically more pronounced for mortgages and other asset-backed securities since the value may fluctuate more significantly in response to interest rate changes. When interest rates decrease, the account’s current income may decline. Issuer Risk • The risk is that an issuer of a security may perform poorly, and therefore, the value of its securities may decline. Poor management decisions, competitive pressures, technological breakthroughs, reliance on suppliers, labor problems or shortages, corporate restructurings, fraudulent disclosures, natural disasters, or other events, conditions, or factors may cause inferior performance. • Legacy Holding Risk Investment advice may be offered on any investment a Client holds at the start of the advisory relationship. Depending on tax considerations and Client sentiment, these investments will be sold over time, and the assets invested in the appropriate strategy. As with any investment decision, there is the risk that timing with respect to the sale and reinvestment of these assets will be less than ideal or even result in a loss to the Client. • Liquidity Risk Low trading volume, large positions, or legal restrictions are some conditions that could limit or prevent a portfolio from selling securities or closing positions at desirable prices. Securities that are relatively liquid when acquired could become illiquid over time. The sale of any such illiquid investment might be possible only at substantial discounts or might not be possible at all. Further, such investments may take more work to value. • Management Risk An account is subject to the risk that judgments about the attractiveness, value, or potential appreciation of the account’s investments may prove to be incorrect. If the selection of securities or strategies fails to produce the intended results, the account could underperform other accounts with similar objectives and investment strategies. • Market Risk Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events will cause the value of securities to rise or fall. Because the value of investment portfolios will fluctuate, there is the risk that you will lose money, and your investment may be worth less upon liquidation. Due to a lack of demand in the marketplace or other factors, an account may only be able to sell some or all the investments promptly or may only be able to sell assets at desired prices. 14  • Municipal Bond Risk Investments in municipal bonds are affected by the municipal market and the factors in the cities, states, or regions where the strategy invests. Issues such as legislative changes, litigation, business and political conditions relating to a particular municipal project, municipality, state, or territory, and fiscal challenges can impact the value of municipal bonds. These matters can also impact the ability of the issuer to make payments. Also, the public information about municipal bonds is less than that for corporate equities or bonds. Additionally, supply and demand imbalances in the municipal bond market can cause deterioration in liquidity and a lack of price transparency. • Mutual Fund or ETF Risk Our models and accounts may use certain ETFs and mutual funds to invest primarily in alternative investments or strategies. Investing in these alternative investments and strategies may only be suitable for some of our Clients. These include special risks, such as those associated with commodities, real estate, and leverage, selling securities short, use of derivatives, potential adverse market forces, regulatory changes, and potential ill- liquidity. Special risks are associated with ETFs that invest principally in real estate securities, such as sensitivity to changes in real estate values or changes in interest rates and price volatility due to the ETF’s concentration in the real estate market. The risks with mutual funds include the costs and expenses within the fund that can impact performance, change of Managers, and the fund straying from its objective (i.e., style drift). Mutual funds have certain costs associated with underlying transactions and operating costs, such as marketing and distribution expenses and advisory fees. Mutual fund costs and expenses vary from fund to fund and will impact a mutual fund’s performance. Additionally, mutual funds typically have different share classes, as further discussed below, that trade at different Net Asset Values (“NAV”) as determined at the daily market close and have different fees and expenses. • Non-Liquid Alternative Investment Risk From time to time, our Firm will recommend to certain qualifying Clients that a portion of such Clients’ assets be invested in private funds, private fund-of-funds, or other alternative investments (collectively, “Non-liquid Alternative Investments”). Non-liquid Alternative Investments are not suitable for all our Firm’s Clients. They are offered only to those qualifying Clients for whom our Firm believes such an investment is suitable and in line with their overall investment strategy. Non-liquid Alternative Investments typically are available to only a limited number of sophisticated investors who meet the definition of “accredited investor” under Regulation D of the Securities Act of 1933, as amended (the “Securities Act”), or “qualified Client” under the Investment Advisers Act of 1940 or “qualified purchaser” under the Investment Company Act of 1940. Non-liquid Alternative Investments present special risks for our Firm’s Clients, including, without limitation, limited liquidity, higher fees and expenses, volatile performance, no assurance of investment returns, heightened risk of loss, limited transparency, additional reliance on underlying management of the investment, special tax considerations, subjective valuations, use of leverage and limited regulatory oversight. When a Non-liquid Alternative Investment invests part or all of its assets in real estate properties, there are additional risks that are unique to real estate investing, including but not limited to: limitations of the appraisal value, the borrower’s financial conditions (if a loan has obtained the underlying property), including the risk of foreclosures on the property; neighborhood values; the supply of and demand for properties of like kind; and certain city, state or federal regulations. Additionally, real estate investing is also subject to possible loss due to uninsured losses 15  from natural and artificial disasters. The above list is not exhaustive of all risks related to an investment in Non-liquid Alternative Investments. A more comprehensive discussion of the risks associated with a particular Non-liquid Investment is set forth in that fund’s offering documents, which will be provided to each Client subscribing to a Non-liquid Alternative Investment for review and consideration. It is important that each potential, qualified investor carefully read each offering or private placement memorandum before investing. • Options Risk Transactions in options carry a high degree of risk. A small market movement will have a proportionately larger impact, which may work for or against the investor. The placing of certain orders, which are intended to limit losses to certain amounts, may not be effective because market conditions may make it impossible to execute such orders. Selling ("writing" or "granting") an option entails greater risk than purchasing options. Although the premium received by the seller is fixed, the seller may sustain a loss well more than that amount. The seller will also be exposed to the risk of the purchaser exercising the option and will be obliged to settle it in cash or to acquire or deliver the underlying investment. The risk may be reduced if the option is "covered" by the seller holding a corresponding position in the underlying investment or a future on another option. • Performance of Underlying Manager Risk We select the mutual funds and ETFs in the asset allocation portfolios. However, we depend on the Manager of such funds to select individual investments in accordance with their stated investment strategy. • Pre-Payment Risk Like call risk, this risk is associated with the early unscheduled principal repayment on a fixed-income security. When the principal is returned early, future interest payments will not be paid. The proceeds from the repayment may be reinvested in securities at a lower prevailing rate. • Real Estate Securities & Related Derivatives Risk The Fund may gain exposure to the real estate sector by investing in real estate-linked derivatives, REITs, and common, preferred, and convertible securities of issuers in real estate-related industries. Each of these types of investments are subject to risks similar to those associated with direct ownership of real estate, including loss to casualty or condemnation, increases in property taxes and operating expenses, zoning law amendments, changes in interest rates, overbuilding and increased competition, variations in market value, and possible environmental liabilities. REITs are subject to management fees and other expenses, and so the Fund, when investing in REITs, will bear its proportionate share of the costs of the REITs’ operations. An investment in a REIT or a real estate-linked derivative instrument that is linked to the value of a REIT is subject to additional risks, such as inferior performance by the manager of the REIT, adverse changes to the tax laws or failure by the REIT to qualify for tax-free pass-through of income under the Code. In addition, some REITs have limited diversification because they invest in a limited number of properties, a narrow geographic area, or a single type of property. Furthermore, REITs are not diversified because they only operate in the real estate business and are heavily dependent on cash flow. Also, the organizational documents of a REIT may contain provisions that make changes in control of the REIT difficult and time-consuming. • Reinvestment Risk The possibility of investing a bond’s cash flows at a rate lower than the expected rate of 16  return assumed at the time of buying the bond. Reinvestment risk is high for bonds with long maturities and high coupons. • Sector Risk The danger is that the stocks of many companies in one sector (like health care or technology) will fall in price simultaneously because of an event that affects the entire industry. • Securities Lending Risk Securities lending involves the risk that the fund loses money because the borrower fails to return the securities promptly. The fund could also lose money if the value of the collateral provided for loaned securities, or the value of the investments made with the cash collateral, falls. These events could also trigger adverse tax consequences for the fund. • Short Sale Risk A short sale is affected by selling a security that the seller does not own or selling a security that the seller owns but which it does not deliver upon consummation of the sale. To make delivery to the buyer of a security sold short, the prime broker or Custodian must borrow the security on behalf of the seller. In so doing, it incurs the obligation to replace that security, whatever its price may be, at the time it is required to deliver it to the lender. The seller must also pay to the lender of the security any dividends or interest payable on the security during the borrowing period and may have to pay a premium to borrow the security. This obligation must, unless the seller then owns or has the right to obtain, without payment, securities identical to those sold short, be collateralized by a deposit of cash or marketable securities with the lender. Short selling is subject to the theoretically unlimited risk of loss because there is no limit on how much the price of a security may appreciate before the “short” position is closed out. Further, short sales of securities involve a form of investment leverage, and the amount of the portfolio’s potential loss is theoretically unlimited. See Borrowing and Leverage Risk. • Socially Responsible Investing & ESG Risk Clients utilizing responsible investing strategies and environmental, social responsibility, and corporate governance (ESG) factors may underperform strategies that do not utilize responsible investing and ESG considerations. Responsible investing and ESG strategies may operate by excluding certain issuers' investments or by selecting investments based on compliance with factors such as ESG. This strategy may exclude certain sectors or industries from a Client’s portfolio, potentially negatively affecting the Client’s investment performance if the excluded sector or industry outperforms. Responsible investing and ESG are subjective by nature. Our Firm may rely on analysis and ‘scores’ provided by third parties in determining whether an issuer meets our Firm’s standards for inclusion or exclusion. A Client’s perception may differ from our Firm or a third party on how to judge an issuer's adherence to responsible investing principles. • Timing Risk The risk is that the investment needs to perform better after its purchase or sale. Moreover, if the Client requires redemption, the Client may face a loss due to poor overall market performance or security performance at that time. • Value Investing Risk Value investing risk is the risk that value stocks do not increase in price, not issue the anticipated stock dividends, or decline in price, either because the market fails to 17  recognize the stock’s intrinsic value or because the expected value was misgauged. If the market does not recognize that the securities are undervalued, the prices of those securities might not appreciate as anticipated. They also may decline in price even though they are already undervalued in theory. Value stocks are typically less volatile than growth stocks but may lag behind growth stocks in an up market. B. Our practices regarding cash balances in client accounts, including whether we invest cash balances for temporary purposes and, if so, how. 1) We generally invest client’s cash balances in money market funds, FDIC Insured Certificates of Deposit, and/or government backed debt instruments. Ultimately, we try to achieve the highest return on our client’s cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to comprehensive portfolio management. Item 9. Disciplinary Information A. If there are legal or disciplinary events that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management, we must disclose all material facts regarding those events. 1) Neither the Adviser nor any management persons have any disciplinary information to disclose. Item 10. Other Financial Industry Activities and Affiliations A. Our firm or our management persons are required to disclose if we or any of our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer, disclose this fact. The details are as follows: 1) Our firm has nothing to disclose. B. Description of any relationship or arrangement that is material to our advisory business or to our clients, that we or any of our management persons have with any related person listed below. We are required to identify the related person and if the relationship or arrangement creates a material conflict of interest with clients, describe the nature of the conflict and how we address it. 1) Associated persons may be licensed insurance agents and may recommend insurance products and receive commissions and other compensation if products are purchased. Thus, a potential conflict of interest exists between the interests of associated persons and those of the advisory clients. However, clients are under no obligation to act upon any recommendations of the associated persons. C. If we recommend or select other investment advisers for our clients and receive compensation directly or indirectly from those advisers that creates a material conflict of interest, or if we have other business relationships with those advisers that create a material conflict of interest, we are required to describe these practices and discuss the material conflicts of interest these practices 18  create and how we address them. 1) Our firm does from time to time recommend the use of other investment advisers. We are not compensated directly or indirectly by these advisors. There is no conflict of interest. Item 11. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading A. We are required to provide a description of our Code of Ethics adopted and offer to provide a copy of our Code of Ethics to any client or prospective client upon request. 1) We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment adviser is considered a fiduciary. As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. B. If our firm or a related person recommends to clients, or buys or sells for client accounts, securities in which the firm or a related person has a material financial interest, we are required to describe our proactive and discuss the conflicts of interest that may arise. 1) See Item 11A of this Brochure. It is the firm policy to not recommend securities in which the firm or a related person has a material financial interest. C. If our firm or a related person invests in the same securities (or related securities, e.g., warrants, 19  options or futures) that our firm or a related person recommends to clients, we are required to describe our practice and discuss the conflicts of interest this presents and generally how we address the conflicts that arise in connection with personal trading. 1) See Item 11A of this Brochure. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. D. If our firm or a related person recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that you or a related person buys or sells the same securities for our firm’s (or the related person's own) account, we are required to describe our practice and discuss the conflicts of interest it presents. We are also required to describe generally how we address conflicts that arise. 1) See Item 11A of this brochure. Related persons of our firm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Item 12. Brokerage Practices A. Description of the factors that we consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). 1) We typically recommend Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. We consider a range of factors when recommending a custodian, including trading capabilities, costs, service, financial stability and the quality of reporting. Our firm is independently owned and operated and is not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as a custodian, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. The custodian makes available to us certain products and services that assist our firm in managing client accounts. These services generally are available to independent advisers at no charge or at a discount and may include research, technology, trading, reporting, practice management and educational conferences. These benefits create a conflict of interest because they provide an incentive for us to recommend that clients custody assets with this custodian. We mitigate this conflict by basing our recommendation on the overall quality and cost of services provided to clients and by reviewing our custodian recommendation periodically. Products and services available to the Firm from Schwab 20  Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms like us. Schwab provides our firm and our clients with access to institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services described below are generally available on an unsolicited basis (i.e., we do not have to request them) and at no charge to us. Here is a more detailed description of Schwab’s support services: Services that Benefit Clients Directly Schwab’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 Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit each client. Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit a specific client. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts. In addition to investment research, Schwab also makes available software and other technology that: • Provides access to client account data (such as trade confirmations and account statements); • Facilitates trade execution and allocate aggregated trade orders for multiple client accounts; • Provides pricing and other market data; • Facilitates payment of our fees from our clients’ accounts; and • Assists with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include (among others) the following: • Educational conferences and events • Technology, compliance, legal, and business consulting • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants and insurance providers • Schwab will provide some of these services itself or will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these 21  services or pay all or a part of a third-party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our Interest in Schwab's Services The availability of the services described above from Schwab benefits us because we do not have to produce or purchase them. They are not contingent upon our firm committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate our recommendation of Schwab as a custodian and broker is in the best interest of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services, and not Schwab’s services that benefit only us. B. Discussion of whether, and under what conditions, we aggregate the purchase or sale of securities for various client accounts in quantities sufficient to obtain reduced transaction costs (known as bunching). If we do bunch orders when we have the opportunity to do so, we are required to explain our practice and describe the costs to clients of not bunching. 2) We do not aggregate the trades of clients since trading decisions are based on the particular needs of each client. The decision not to aggregate trades means that clients cannot benefit from reduced transactions fees on aggregated trades; as a result, clients may pay different prices for the same security on the same day.”. Third-party managers selected by us may conduct block trades, however their practices are reflected in their own ADV Brochures. 3) We do not accept directed brokerage, all client accounts are managed through our recommended custodian. Item 13. Review of Accounts or Financial Plans A. Review of client accounts or financial plans, along with a description of the frequency and nature of our review, and the titles of our employees who conduct the review. 1) We review accounts on at least a quarterly basis for our clients subscribing to Comprehensive Portfolio Management. The nature of these reviews is to learn whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio Managers will conduct reviews. 2) Financial planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. We do not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. B. Review of client accounts on other than a periodic basis, along with a description of the factors that trigger a review. 22  1) We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. C. Description of the content and indication of the frequency of written or verbal regular reports we provide to clients regarding their accounts. 1) We do not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when we contact clients who subscribe to Comprehensive Portfolio Management. 2) Financial Planning is reviewed with clients upon discussion of their portfolio management as an incidental service to Portfolio Management clients. Item 14. Client Referrals and Other Compensation A. If someone who is not a client provides an economic benefit to our firm for providing investment advice or other advisory services to our clients, we must generally describe the arrangement. For purposes of this Item, economic benefits include any sales awards or other prizes. 1) We do not receive compensation other than the soft dollar benefits described in Item 12 of this Firm Brochure. B. If our firm or a related person directly or indirectly compensates any person who is not our employee for client referrals, we are required to describe the arrangement and the compensation. 1) We do not pay referral fees (non-commission based) to independent solicitors (non- registered representatives) for the referral of their clients to our firm. Item 15. Custody A. If we have custody of client funds or securities and a qualified custodian as defined in state rules (for example, a broker-dealer or bank) and do not send account statements with respect to those funds or securities directly to our clients, we must disclose that we have custody and explain the risks that you will face because of this. 1) Custody is disclosed in Form ADV because we have authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). The firm endeavors to comply with the SEC no-action letter to the Investment Adviser Association dated February 21, 2017, in this regard. 2) Other than SLOAs, our Firm does not maintain custody of client funds or securities. Custody is maintained with a qualified custodian. All our clients receive at least quarterly account statements directly from their custodians. Upon opening an account with a qualified custodian on a client's behalf, we promptly notify the client in writing of the qualified custodian's contact information. B. If we have custody of client funds or securities and a qualified custodian sends quarterly, or more 23  frequent, account statements directly to our clients, we are required to explain that you will receive account statements from the broker-dealer, bank, or other qualified custodian and that you should carefully review those statements. 1) Our Firm does not maintain custody of client funds or securities. We encourage our clients to raise any questions with us about the custody, safety or security of their assets. The custodians we do business with will send you independent account statements listing your account balance(s), transaction history and any fee debits or other fees taken out of your account. Item 16. Investment Discretion A. If we accept discretionary authority to manage securities accounts on behalf of clients, we are required to disclose this fact and describe any limitations our clients may place on our authority. The following procedures are followed before we assume this authority: 1) We usually receive discretionary authority in writing from the client at the outset of an advisory relationship to select the identity and amount of securities to be bought or sold. When recommending third-party investment managers and acting in a discretionary capacity, we have the ability to evaluate managers and switch money managers or reallocate assets among managers without consulting the client. When acting in a non-discretionary capacity, we will make recommendations, but only the client has the authority to hire or switch managers or reallocate assets. In all cases, discretion is exercised in a manner consistent with the stated investment objectives for the particular client account. Clients must authorize such discretion in the advisory agreement. When selecting securities and determining amounts, we observe the investment policies, limitations, and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to us in writing. Item 17. Voting Client Securities A. If we have, or will accept, proxy authority to vote client securities, we are required to briefly describe our voting policies and procedures. 1) We do not and will not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write, or email us to discuss questions they may have about particular proxy votes or other solicitations. Third party money managers may vote proxies for clients. Therefore, except in the event a third-party money manager votes proxies, clients maintain exclusive responsibility for: (1) directing the manner in which proxies solicited by issuers of securities beneficially owned by the client shall be voted, and (2) making all elections relative to any mergers, acquisitions, tender offers, bankruptcy proceedings or other type events pertaining to the client’s investment assets. Therefore (except for proxies that may be voted by a third-party money manager), our firm and/or you shall instruct your qualified custodian to forward to you copies of all proxies and 24  shareholder communications relating to your investment assets. Item 18. Financial Information A. If we require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, we are required to include a balance sheet for your most recent fiscal year. 1) We are not required to provide financial information to our clients because: • We do not require the prepayment of more than $1200 in fees when services cannot be rendered within 6 (six) months. • We do not take custody of client funds or securities. • We do not have a financial condition or commitment that impairs its ability to meet contractual and fiduciary obligations to clients. B. If we have discretionary authority or custody of client funds or securities, or we require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance, we are required to disclose any financial condition that is reasonably likely to impair your ability to meet contractual commitments to clients. • We have never been the subject of a bankruptcy proceeding. 25  TEVIS INVESTMENT MANAGEMENT, LLC PRIVACY NOTICE REQUIRED BY REGULATION S-P & REGULATION S-AM Maintaining the trust and confidence of our clients is a high priority. That is why we want you to understand how we protect your privacy when we collect and use information about you, and the steps that we take to safeguard that information. Information We Collect: In connection with providing investment products, financial advice, or other services, we obtain non-public personal information about you, including: • Information we receive from you on account applications, such as your address, date of birth, Social Security Number, occupation, financial goals, assets and income; Information about your transactions with us, our affiliates, or others; and • • Information received from credit or service bureaus or other third parties, such as your credit history or employment status. Information We Disclose: We may only disclose information that we collect in accordance with this policy. Tevis Investment Management, LLC does not sell customer lists and will not sell your name to telemarketers. To Whom We Disclose: We will not disclose information regarding you or your account with us, except under the following circumstances: • To entities that perform services for us or function on our behalf, including financial service providers, such as a clearing broker-dealer, investment company, or insurance company; • To third parties who perform services or marketing on our behalf; • To your attorney, trustee or anyone else who represents you in a fiduciary capacity; • To our attorneys, accountants or auditors; and • To government entities or other third parties in response to subpoenas or other legal process as required by law or to comply with regulatory inquiries. How We Use Information: Information may be used among companies that perform support services for us, such as data processors, technical systems consultants and programmers, or companies that help us market products and services to you for a number of purposes, such as: • To protect your accounts from unauthorized access or identity theft; • To process your requests such as securities purchases and sales; • To establish or maintain an account with an unaffiliated third party, such as a clearing broker- dealer providing services to you and/or Tevis Investment Management, LLC: • To service your accounts, such as by issuing checks and account statements; • To comply with Federal, State, and Self-Regulatory Organization requirements; • To keep you informed about financial services of interest to you. Regulation S-AM: Under Regulation S-AM, a registered investment adviser is prohibited from using eligibility information that it receives from an affiliate to make a marketing solicitation unless: (1) the potential marketing use of that information has been clearly, conspicuously and concisely disclosed to the consumer; (2) the 26  consumer has been provided a reasonable opportunity and a simple method to opt out of receiving the marketing solicitations; and (3) the consumer has not opted out. Tevis Investment Management, LLC does not receive information regarding marketing eligibility from affiliates to make solicitations. Our Security Policy: We restrict access to nonpublic personal information about you to those individuals who need to know that information to provide products or services to you and perform their respective duties. We maintain physical, electronic, and procedural security measures to safeguard confidential client information. Closed or Inactive Accounts: If you decide to close your account(s) or become an inactive customer, our Privacy Policy will continue to apply to you. Complaint Notification: Please direct complaints to: Ryan Tevis at Tevis Investment Management, LLC, 5700 W. Plano Pkwy. Suite 3200 Plano, TX 75093. (972) 971-2169 Changes to This Privacy Policy: If we make any substantial changes in the way we use or disseminate confidential information, we will notify you. If you have any questions concerning this Privacy Policy, please contact us at: Tevis Investment Management, LLC., 5700 W. Plano Pkwy. Suite 3200 Plano, TX 75093 (972) 971-2169 27