Overview
- Headquarters
- Miami, FL
- Total Firm Assets
- $1.6 billion
- Average High-Net-Worth Client Portfolio Size
- $1.5 million
- Minimum Account Size
- $100,000
Fee Structure
Primary Fee Schedule (FORM ADV 2A BROCHURE 02-06-2026)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | $750,000 | 2.50% |
| $750,001 | $1,000,000 | 2.25% |
| $1,000,001 | and above | 2.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $24,375 | 2.44% |
| $5 million | $104,375 | 2.09% |
| $10 million | $204,375 | 2.04% |
| $50 million | $1,004,375 | 2.01% |
| $100 million | $2,004,375 | 2.00% |
Clients
- High-Net-Worth Share of Firm Assets
- 40.25%
- Number of High-Net-Worth Clients
- 448
- Total Client Accounts
- 1,730
- Discretionary Accounts
- 1,459
- Non-Discretionary Accounts
- 271
Services Offered
Services: Portfolio Management for Individuals
Regulatory Filings
- SEC CRD Number
- 147129
Additional Brochure: FORM ADV 2A BROCHURE 06-026-2026- ADV PART 2A (2026-06-25)
View Document Text
VECTORGLOBAL IAG, INC.
1001 Brickell Bay Drive, Suite 1900
Miami, Florida 33131
Phone: 305.350.3350
Fax: 877.350.7494
06/25/2026
FORM ADV PART 2A
BROCHURE
This Brochure provides information about the qualifications and business practices of
VectorGlobal IAG, Inc. If you have any questions about the contents of this brochure, please
contact us at 305.350.3350. 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 VectorGlobal IAG, Inc. is also available on the SEC's website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for VectorGlobal IAG, Inc. is
147129.
VectorGlobal IAG, Inc. is a Registered Investment Adviser. Registration with the United States
Securities and Exchange Commission or any state securities authority does not imply a certain
level of skill or training.
VectorGlobal IAG, Inc.
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TABLE OF CONTENTS:
VectorGlobal IAG, Inc. ............................................................................................................. 1
FORM ADV PART 2A ................................................................................................................ 2
ITEM 1 DEFINITION Of Terms ................................................................................................... 4
ITEM 2 PORTFOLIO Management Services ............................................................................... 4
ITEM 3 ADVISORY Business - Minimum Investment & Annual Fees .......................................... 4
ITEM 4 ASSETS under Management ......................................................................................... 5
ITEM 5 FEES And Compensation ............................................................................................... 5
ITEM 6: Performance-Based Fees And Side-By-Side Management ........................................... 6
ITEM 7: Types of Clients ........................................................................................................... 7
ITEM 8: Methods Of Analysis, Investment Strategies And Risk Of Loss ..................................... 7
ITEM 9: Disciplinary Information ........................................................................................... 10
Item 12: Brokerage Practices ................................................................................................. 12
Item 13: Review of Accounts .................................................................................................. 12
Item 14: Client Referrals and Other Compensation ................................................................ 12
Item 15: Custody .................................................................................................................... 12
Item 16: Investment Discretion .............................................................................................. 13
Item 17: Voting Client Securities ....................................................................................... 13
Item 18: Financial Information .......................................................................................... 13
Item 19: Additional Information ....................................................................................... 13
VectorGlobal IAG, Inc.
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VectorGlobal, IAG, Inc. is a registered investment adviser based in Miami, Florida. We are organized as a corporation
under the laws of the State of Delaware. We have been providing investment advisory services since 2008. Our firm
is owned by Vectormex International, Inc., .
ITEM 1 DEFINITION OF TERMS
The following paragraphs describe our services and fees. Please refer to the description of each investment advisory
service listed below for information on how we tailor our advisory services to your individual needs. As used in this
brochure, the words "we", "our" and "us" refer to VectorGlobal, IAG, Inc. and the words "you", "your" and "client"
refer to you as either a client or prospective client of our firm. Also, you may see the term Associated Person
throughout this brochure. As used in this brochure, our Associated Persons are our firm's officers, employees, and
all individuals providing investment advice on behalf of our firm.
ITEM 2 PORTFOLIO MANAGEMENT SERVICES
We offer discretionary and non-discretionary portfolio management services. Our investment advice is tailored to
meet our clients' needs and investment objectives. If you retain our firm for portfolio management services, we will
meet with you to determine your investment objectives, risk tolerance, and other relevant information (the
"suitability information") at the beginning of our advisory relationship. We will use the suitability information we
gather to develop a strategy that enables our firm to give ongoing and focused investment advice and/or to make
investments on your behalf. Once we construct an investment portfolio for you, we will monitor your portfolio's
performance on an ongoing basis and will rebalance the portfolio as required by changes in market conditions and
in your financial circumstances.
If you participate in our discretionary portfolio management services, we require you to grant our firm discretionary
authority to manage your account. Discretionary authorization will allow our firm to determine the specific securities,
and the number of securities, to be purchased or sold for your account without your approval prior to each
transaction. Discretionary authority is typically granted by the investment advisory agreement you sign with our firm,
a power of attorney, or trading authorization forms. You may limit our discretionary authority (for example, limiting
the types of securities that can be purchased for your account) by providing our firm with your restrictions and
guidelines in writing. If you enter non-discretionary arrangements with our firm, we must obtain your approval prior
to executing any transactions on behalf of your account.
ITEM 3 ADVISORY BUSINESS - MINIMUM INVESTMENT & ANNUAL FEES
NOT APPLICABLE
The minimum initial investment in the Individual Portfolios, Separately Managed Accounts or the Mutual Funds and
ETF Model Portfolios may be waived at the sole discretion of VectorGlobal IAG.
Our fee for portfolio management services is based on a percentage of your total assets we manage, as follows:
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Annual Fees:
The above describes the maximum annual fees that we may charge an account, depending on its size and
model portfolio. Our annual portfolio management fee is billed and payable quarterly in advance based
on the value of your account on the last day of the previous quarter, including market value plus accrued
income. Accrued income amounts included in the calculated advisory and/or performance fees are not
necessarily obtained from data reported by our custodian, but a third-party service provider contracted
by the Adviser’s portfolio reporting and billing system.
If the portfolio management agreement is executed at any time other than the first day of a billing
quarter, our fees will apply on a pro rata basis, which means that the advisory fee is payable in proportion
to the number of days in the quarter for which you are a client. Our advisory fee is negotiable, depending
on individual client circumstances. The external accounts reporting fees are based on unmanaged assets
on external accounts, or accounts with other custodians.
Fees are directly deducted from your account through the qualified custodian holding your funds and
securities. We will deduct our advisory fee only when you have given our firm written authorization
permitting the fees to be paid directly from your account. By signing the Investment Advisory Agreement,
you give us such authorization. Further, the qualified custodian will deliver an account statement to you
at least quarterly. These account statements will show all disbursements from your account. You should
review all statements for accuracy. We will also receive a duplicate copy of your account statements.
If you did not receive the disclosure brochure within 48 hours prior to entering into the portfolio
management agreement, you may terminate the agreement within five business days of the date of
acceptance without penalty. If you received the disclosure documents 48 hours in advance or if the five-
day grace period has expired, you may terminate the portfolio management agreement upon written
notice to our firm. You will incur a pro rata charge for services rendered prior to the termination of the
portfolio management agreement, which means you will incur advisory fees only in proportion to the
number of days in the month for which you are a client. If you have pre-paid advisory fees that we have
not yet earned, you will receive a prorated refund of those fees.
You may request that we refrain from investing in securities or certain types of securities or issuers. You
must provide these restrictions with our firm in writing.
ITEM 4 ASSETS UNDER MANAGEMENT
As of 6/1/2026, we manage NO client assets.
ITEM 5 FEES AND COMPENSATION
Please refer to the "Advisory Business – Minimum Investment & Annual Fees" section in this brochure
for information on our advisory fees, fee deduction arrangements, and refund policy according to each
service we offer.
Additional Fees and Expenses
As part of our investment advisory services to you, we may invest, or recommend that you invest, in
mutual funds and exchange traded funds. The fees that you pay to our firm for investment advisory
services are separate and distinct from the fees and expenses charged by mutual funds or exchange
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traded funds (described in each fund's prospectus) to their shareholders. These fees will generally include
a management fee and other fund expenses. You will also incur transaction charges when purchasing or
selling securities typically imposed by the custodian through whom your account transactions are
executed. You may also incur brokerage fees when purchasing or selling securities through a broker
dealer not related to our firm. To fully understand the total costs you will incur, you should review all fees
charged by mutual funds, exchange traded funds, our firm, and our custodians, as well of other firms in
which the trade might be executed.
NOTE: An advisory fee above 2% is higher than that charged in the industry and other advisers can provide
the same or similar services at a lower rate.
ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT
Some of our accounts may be subject to performance-based fees, as agreed on the Investment Advisory
Agreement. The fee arrangement may create an incentive for the investment adviser to make
investments that are risker or more speculative that would be the case in the absence of a performance
fee; however, our investment adviser will only recommend and/or make investments that are
commensurate with the investment guidelines. Where relevant, the firm may receive increased
compensation with regards to unrealized appreciation as well as realized gains in the client account.
Compensation is based in part on the unrealized appreciation of securities for which market quotations
are not readily available within the meaning of Rule 2a-4(a) (1) under the Investment Company Act of
1940, 17 C.F.R.270.2a- 4(a) (1), the securities will be valued as follows: The Firm will contact the issuer in
case a price for the security is not available.
Note: Performance fees will only be charged to clients who have a net worth greater than $2,200,000 or
the advisor is managing more than $1,100,000 of the client’s assets and if a performance fee percentage
has been agreed between the advisor and the client in the Investment Advisory Agreement.
Performance fees are calculated based on the portfolio’s value at the end of the quarter, before
deducting Advisory Fees for the following quarter. Performance Fees are generally a percentage between
15% and 25% of the excess between the portfolio’s return and the benchmark’s return. They are charged
only if quarterly return is positive, and the portfolio’s value is historically high. Even if the portfolio’s
return exceeds the corresponding benchmark, if it is negative, no performance fee is collected. The
benchmarks used are the following:
Bloomberg Barclays Global Aggregate Bond Index: For Investment Grade fixed income investments. This
index is a flagship measure of global investment grade debt from twenty-four different local currency
markets. This multi-currency benchmark includes fixed-rate treasury, government-related, corporate,
and securitized bonds from both developed and emerging markets issuers. The Global Aggregate Index
is largely comprised of three regional aggregate components: The US Aggregate, the Pan-European
Aggregate, and the Asian-Pacific Aggregate Index. (Source: Bloomberg, ticker: LEGATRUH)
Bloomberg Barclays High Yield Total Return Index Value Unhedged: For High Yield investments. This index
is a multi-currency flagship measure of the global high yield debt market. The index represents the union
of the US High Yield, the Pan-European High Yield, and Emerging Markets (EM) Hard Currency High Yield
Indices. The high yield and emerging markets sub-components are mutually exclusive. (Source:
Bloomberg, ticker: LG30TRUU)
S&P 500 Net Total Return Index: For equity investments. Net total return reflects the return to an
investor, by reinvesting dividends after the deduction of withholding tax. Withholding tax is a tax on
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dividends that is paid by investors. While the withholding tax rates applied to each shareholder vary
based on their Country of domicile, Standard and Poor’s applies the maximum possible tax rate. (Source:
Bloomberg,ticker: SPTR500N).
For a multi-asset portfolio, the benchmark used is a weighted average of the above benchmarks according.
to the portfolio’s distribution by asset class (fixed income versus equity).
ITEM 7: Types of Clients
We offer investment advisory services to individuals, banks and thrift institutions, investment companies, pension
and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities.
In general, we require a minimum of $100,000 to open and maintain an advisory account.
Our Method of Analysis and Investment Strategies
ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS
We may use one or more of the following methods of analysis or investment strategies when providing investment
advice to you:
Fundamental Analysis - involves analyzing individual companies and their industry groups, such as a company's
financial statements, details regarding the company's product line, the experience and expertise of the company's
management, and the outlook for the company's industry. The resulting data is used to measure the true value of
the company's stock compared to the current market value, or its financial solvency in case of fixed income
investments.
Long Term Purchases - securities purchased with the expectation that the value of those securities will grow over a
relatively long period of time, generally greater than one year.
Short Term Purchases - securities purchased with the expectation that they will be sold within a relatively short
period of time, generally less than one year, to take advantage of the securities' short-term price fluctuations.
Margin Transactions - a securities transaction in which an investor borrows money to purchase a security, in which
case the security serves as collateral on the loan.
Option Writing - a securities transaction that involves selling an option - An option is the right, but not the obligation,
to buy or sell a particular security at a specified price before the expiration date of the option. When an investor
sells an option, he or she must deliver to the buyer a specified number of shares in case of calls or buy a specified
number of shares from seller in case of puts, if the buyer exercises the option. The seller pays the buyer a premium
(the market price of the option at a time) in exchange for writing the option.
Our investment strategies and advice may vary depending upon each client's specific financial situation. As such, we
determine investments and allocations based upon your predefined objectives, risk tolerance, time horizon, financial
horizon, financial information, liquidity needs, and other various suitability factors. Your restrictions and guidelines
may affect the composition of your portfolio.
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The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an
accurate estimate of earnings, which may be the basis for a stock's value, or liquidity, basis for evaluating fixed
income investments. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not
result in favorable performance.
Short-term trading generally involves a greater degree of risk than long term trading due to market volatility over a
short period of time. Long-term purchases may also be affected by unforeseen long-term changes in the company
in which you are invested or in the overall market.
Short selling is very risky. Unlike a straightforward investment in stocks where you buy shares with the expectation
that their price will increase so you can sell at a profit, in a "short sale" you borrow stocks from your brokerage firm
and sell them immediately, hoping to buy them later at a lower price. Thus, a short seller hopes that the price of a
stock will go down in the near future. A short seller thus uses declines in the market to his advantage. He makes
money when the stock prices fall and loses when prices go up.
The SEC has strict regulations in place regarding short selling. There is no ceiling on how much a short seller can lose
in a trade. The share price may keep going up and the short seller will have to pay whatever the prevailing stock
price is to buy back the shares. However, his gains have a ceiling level because the stock price cannot fall below zero.
A short seller must undertake to pay the earnings on the borrowed securities if he chooses to keep his short position
open. If the company declares dividends or issues bonus shares, the short seller will have to pay that amount to the
lender. Any such occurrence can skew the entire short investment and make it unprofitable. The broker can use the
funds in the short seller's margin account to buy back his loaned shares or issue a 'call away' to get the short seller
to return the borrowed securities. If the broker makes this call when the stock price is much higher than the price at
the time of the short sale, then the investor can end up making huge losses.
“Buying on margin” means borrowing money from a broker to purchase stock. Margin trading allows you to buy
more securities than you would be able to normally. An initial investment of at least $2,000 is required for a margin
account, though some brokerages require more. This deposit is known as the minimum margin. Once the account is
opened and operational, you can borrow the maximum amount allowed for that security as determined by the house
and fed requirements, whichever one is the most conservative. This portion of the purchase price that you deposit
is known as the initial margin. Some brokerages require you to deposit more than 50% of the purchase price. Not all
securities qualify to be bought on margin. When you sell the security in a margin account, the proceeds go to your
broker against the repayment of the loan until it is fully paid. There is also a restriction called the maintenance
margin, which is the minimum account balance you must maintain before your broker will force you to deposit more.
funds or sell securities to pay down your loan. When this happens, it is known as a margin call. If for any reason you
do not meet a margin call, the brokerage has the right to sell your securities to increase your account equity until
you are above the maintenance margin. Additionally, your broker may not be required to consult you before selling.
Under most margin agreements, a firm can sell your securities without waiting for you to meet the margin call and
you cannot control which stock is sold to cover the margin call. You also must pay the interest on your loan. The
interest charges are applied to your account unless you decide to make payments. Over time, your debt level
increases as interest charges accrue against you. As debt increases, the interest charges increase, and so on.
Therefore, buying on the margin is mainly used for short-term investments. The longer you hold an investment, the
greater the return that is needed to break even. In volatile markets, prices can fall very quickly. You can lose more
money than you have invested.
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Options are complex securities that involve risks and are not suitable for everyone. Option trading can be speculative
in nature and carry substantial risk of loss. It is generally recommended that you only invest in options with risk
capital. An option is a contract that gives the buyer the right, but not the obligation, to buy or sell an underlying
asset at a specific price on or before a certain date (the "expiration date"). The two types of options are calls and
puts:
A call gives the holder the right to buy an asset at a certain price within a specific period. Calls are like having a long
position on a stock. Buyers of calls hope that the stock will increase substantially before the option expires.
A put gives the holder the right to sell an asset at a certain price within a specific period. Puts are very similar to
having a short position on a stock. Buyers of puts hope that the price of the stock will fall before the option expires.
The main option trading risk pertaining to options buyers is the risk of losing your entire investment in a relatively
short period of time. The risk of losing your entire investment increases if, as expiration nears, the stock is below the
strike price of the call (for a call option) or if the stock is higher than the strike price of the put (for a put option).
European style options which do not have secondary markets on which to sell the options prior to expiration can
only realize its value upon expiration. Specific exercise provisions of a specific option contract may create additional
risks. Regulatory agencies may impose exercise restrictions, which stop you from realizing value.
Selling options is more complicated and can be even riskier. The option trading risks pertaining to options sellers
are:
Options sold may be exercised at any time before expiration.
•
•
Covered Call traders forgo the right to profit when the underlying stock rises above the strike price of the call
options sold and continue to risk a loss due to a decline in the underlying stock.
• Writers of Naked Calls risk unlimited losses if the underlying stock rises.
• Writers of Naked Puts risk unlimited losses if the underlying stock drops.
• Writers of naked positions run margin risks if the position goes into significant losses. Such risks may include
liquidation by the broker.
• Writers of call options can lose more money than a short seller of that stock on the same rise on that underlying
stock. This is an example of how the leverage in options can work against the option trader.
• Writers of Naked Calls are obligated to deliver shares of the underlying stock if those call options are exercised.
•
Call options can be exercised outside of market hours such that effective remedy actions cannot be performed
by the writer of those options.
• Writers of stock options are obligated under the options that they sold even if a trading market is not available
or that they are unable to perform a closing transaction.
The value of the underlying stock may surge or ditch unexpectedly, leading to automatic exercises.
•
Other option trading risks are:
The complexity of some option strategies is a significant risk on its own.
•
Option trading exchanges or markets and option contracts themselves are always open to changes.
•
•
Options markets have the right to halt the trading of any options, thus preventing investors from realizing
value.
Risk of erroneous reporting of exercise value.
•
If an options brokerage firm goes insolvent, investors trading through that firm may be affected.
•
Internationally traded options have special risks due to timing across borders.
•
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Risks that are not specific to options trading include: market risk, sector risk and individual stock risk. Option trading
risks are closely related to stock risks as stock options are a derivative of stocks.
We may use investment strategies that involve buying and selling securities frequently to capture significant market
gains and avoid significant losses during a volatile market. However, frequent trading can negatively affect
investment performance, particularly through increased brokerage and other transactional costs and taxes.
Our strategies and investments may have unique and significant tax implications. However, unless we specifically
agree otherwise, and in writing, tax efficiency is not our primary consideration in the management of your assets.
Regardless of your account size or any other factors, we strongly recommend that you continuously consult with a
tax professional prior to and throughout the investing of your assets.
Moreover, as a result of revised IRS regulations, custodians and broker-dealers will begin reporting the cost basis of
equities acquired in client accounts on or after January 1, 2011. Your custodian will default to the FIFO (First-In First-
Out) accounting method for calculating the cost basis of your investments. You are responsible for contacting your
tax advisor to determine if this accounting method is the right choice for you. If your tax advisor believes another
accounting method is more advantageous, please provide written notice to our firm immediately and we will alert
your account custodian of your individually selected accounting method. Please note that decisions about cost basis
accounting methods will need to be made before trades settle, as the cost basis method cannot be changed after
settlement.
Risk of Loss
Investing in securities involves risk of loss that you should be prepared to bear. We do not represent or
guarantee that our services or methods of analysis can or will predict future results, successfully identify
market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot
offer any guarantees or promises that your financial goals and objectives will be met. Past performance
is in no way an indication of future performance.
Recommendation of Particular Types of Securities
As disclosed under the "Advisory Business" section in this Brochure, we recommend several types of
securities, and we do not necessarily recommend one particular type of security over another since each
client has different needs and different tolerance for risk. Each type of security has its own unique set of
risks associated with it and it would not be possible to list here all the specific risks of every type of
investment. Even within the same type of investment, risks can vary widely. However, in very general terms,
the higher the anticipated return of an investment, the higher the risk of loss associated with it.
ITEM 9: Disciplinary Information
Neither our firm nor any of our Associated Persons has any reportable disciplinary information.
ITEM 10: Other Financial Industry Activities and Affiliations
Registrations with Broker-Dealer
Persons providing investment advice on behalf of our firm are registered representatives with VectorGlobal WMG,
Inc., a securities broker/dealer with which we are affiliated through common control and ownership. You are
under no obligation, contractually or otherwise, to purchase securities through any affiliated firm.
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Arrangements with Affiliated Entities
We are affiliated with VectorGlobal WMG, Inc., a securities broker/dealer and member of the Financial Industry
Regulatory Authority, through common control and ownership. Persons providing investment advice on behalf of
our firm are also registered representatives with VectorGlobal WMG, Inc. This practice could present a conflict of
interest if representatives providing investment advice to you had an incentive to execute securities transactions
for the purpose of generating commissions rather than solely based on your needs. To mitigate this risk, we have
implemented a wrap fee system for our investment advisory accounts. In this system, the investment advisor
charges an annual advisory fee for managing the client account. However, you will incur transaction costs and
might be subject to other fees per transaction. Your advisory account will be handled separately from any other
accounts held with our affiliated broker-dealer.
Commented [MW1]: Juan Manuel Please review
The Adviser also receives sub-advisory services from Claudia M.P. Batlle, CFP® LLC (CMPB), operating under the
name Seaview Investment Managers. Seaview is not an affiliate of the Adviser, but Carlos Gadala-Maria, a principal
of the Adviser, holds a 50% passive ownership interest in Seaview. This ownership may present a conflict of
interest, as it could create an incentive to allocate resources or business opportunities in a manner that benefits
Seaview. In certain instances, the Adviser may report assets managed in coordination with Seaview as part of its
regulatory filings, consistent with applicable guidance. These arrangements may create a conflict for you, as they
could divert time and resources away from your account. However, financial advisers at VectorGlobal IAG, Inc. are
not financially incentivized to select Seaview Investment Managers over any other manager available on our
platform. The Adviser has controls in place to mitigate these conflicts, including performing periodic portfolio
reviews to ensure that client portfolios are in line with their investment objectives and risk tolerance.
ITEM 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading
Description of Our Code of Ethics
We strive to comply with applicable laws and regulations governing our practices. Therefore, our Code of Ethics
includes guidelines for professional standards of conduct for our Associated Persons. Our goal is to always protect
your interests and to demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing
with you. All our Associated Persons are expected to adhere strictly to these guidelines. Persons associated with
our firm are also required to report any violations of our Code of Ethics. Additionally, we maintain and enforce
written policies reasonably designed to prevent the misuse or dissemination of material, non-public information
about you or your account holdings by persons associated with our firm. Clients or prospective clients may obtain a
copy of our Code of Ethics by contacting us at the telephone number on the cover page of this brochure.
Participation or Interest in Client Transactions
Neither our firm nor any of our Associated Persons has any material financial interest in client transactions beyond
the provision of investment advisory services as disclosed in this brochure. However, as disclosed in Item 10, Carlos
Gadala-Maria holds a passive ownership interest in Seaview Investment Managers, which provides sub-advisory
services to the Adviser. While this interest does not directly involve client transactions, it may present an indirect
conflict of interest. Importantly, financial advisers at VectorGlobal IAG, Inc. are not financially incentivized to select
Seaview Investment Managers over any other manager available on our platform. The Adviser has implemented
policies and procedures to monitor and mitigate such risks.
Personal Trading Practices
Our firm or persons associated with our firm may buy or sell the same securities that we recommend to you or
securities in which you are already invested. A conflict of interest exists in such cases because we have the ability
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to trade ahead of you and potentially receive more favorable prices than you will receive. To eliminate this conflict
of interest, it is our policy that neither our Associated Persons nor we shall have priority over your account in the
purchase or sale of securities.
ITEM 12: BROKERAGE PRACTICES
We recommend the brokerage of VectorGlobal WMG, Inc., among others. We believe that VectorGlobal WMG, Inc.
provides quality execution services for you, including the value of a research team, the firm's reputation, execution
capabilities, and responsiveness to our clients. You are under no obligation to purchase securities through this
affiliated firm. However, you may incur in additional costs if you decide to use another broker-dealer. All trades for
Pershing accounts are processed through the Block Trading/Rebalancing function even if it is for one or multiple
accounts.
Third party vendor generates a spreadsheet that is then uploaded to Pershing in the Block Trading/Rebalancing tool
where the trade is executed and allocated according to the spreadsheet.
Even though we seek to consolidate a single block trade for all the accounts there are times where it is not possible.
Please see the Fees and Compensation section in this brochure for more information.
use or refer to testimonials (which include any statement of a client's experience or endorsement);
Pursuant to SEC Rule 206(4)-1, VectorGlobal IAG is prohibited from using any advertisement that contains any untrue
statement of material fact or that is otherwise misleading. In addition, an advertisement may not:
•
•
refer to past, specific recommendations made by the adviser that were profitable, unless the advertisement
sets out a list of all recommendations made by the adviser within the preceding period of not less than one
year, and complies with other, specified conditions.
•
represent that any graph, chart, formula, or other device can, in and of itself, be used to determine which
securities to buy or sell, or when to buy or sell such securities, or can assist persons in making those decisions,
unless the advertisement prominently discloses the limitations thereof and the difficulties regarding its use;
and
•
represent that any report, analysis, or other service will be provided without charge unless the report, analysis,
or other service will be provided without any obligation whatsoever. Regarding the new Marketing Rule, the
firm conducts a review (by the CCO or delegate) of all performance, including 1, 5 and 10-year return periods.
VectorGlobal IAG uses performance results net of advisory fees (no gross performance).
ITEM 13: REVIEW OF ACCOUNTS
N/A
ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION
Persons providing investment advice on behalf of VectorGlobal IAG can also be dually registered
representatives with VectorGlobal WMG, Inc. a securities broker/dealer with which we are affiliated
through common control and ownership. Please refer to the Other Financial Industry Activities section
for information on how we mitigate potential conflicts of interest.
ITEM 15: CUSTODY
As paying agent for our firm, your independent custodian will directly debit your account(s) for the
payment of our advisory fees and performance fees, if applicable. This ability to deduct our advisory fees
from your accounts causes our firm to exercise limited custody over your funds or securities. We do not
have physical custody of any of your funds and/or securities. Your funds and securities will be held with
a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements
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from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The
account statements from your custodian(s) will indicate the amount of our advisory fees deducted from
your account(s) each billing period. You should carefully review account statements for accuracy.
You should compare Tamarac’s Advisor View Billing Statements with the statements from your account
custodian(s)to reconcile the information reflected on each statement. If you have a question regarding
your account statement or if you did not receive a statement from your custodian, please contact us
directly at the telephone number on the cover page of this brochure.
ITEM 16: INVESTMENT DISCRETION
Before we can buy or sell securities on your behalf, you must first sign our discretionary management
agreement, a power of attorney, and/or trading authorization forms.
You may grant our firm discretion over the selection and number of securities to be purchased or sold for
your account(s) without obtaining your consent or approval prior to each transaction. You may specify
investment objectives, guidelines, and/or impose certain conditions or investment parameters for your
account(s). For example, you may specify that the investment in any stock or industry should not exceed
specified percentages of the value of the portfolio and/or restrictions or prohibitions of transactions in
the securities of a specific industry or security. Please refer to the "Advisory Business" section in this
brochure for more information on our discretionary management services.
If you enter non-discretionary arrangements with our firm, we will obtain your approval prior to the
execution of any transactions for your account(s). You have an unrestricted right to decline to implement
any advice provided by our firm on a non-discretionary basis.
ITEM 17: VOTING CLIENT SECURITIES
The advisor will not be responsible for Proxy Voting for the client. All related communications shall be
directed from Custodian to client, and client shall notify Adviser of his/her proxy decision.
ITEM 18: FINANCIAL INFORMATION
Take custody of client funds or securities, or
• We are not required to provide financial information to our clients because we do not:
• Require the prepayment of more than $500 in fees and six or more months in advance, or
•
• Have a financial condition that is reasonably likely to impair our ability to meet our commitment
to you.
ITEM 19: ADDITIONAL INFORMATION
Your Privacy
We view protecting your private information as a top priority. Pursuant to applicable privacy
requirements, we have instituted policies and procedures to ensure that we keep your personal
information private and secure.
We do not disclose any nonpublic personal information about you to any nonaffiliated third parties,
except as permitted by law. While servicing your account, we may share some information with our service
providers, such as transfer agents, custodians, broker-dealers, accountants, consultants, and attorneys.
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We restrict internal access to nonpublic personal information about you to employees who need that
information in order to provide products or services to you. We maintain physical and procedural
safeguards that comply with regulatory standards to guard your nonpublic personal information and to
ensure our integrity and confidentiality.
We will not sell information about you or your accounts to anyone. We do not share your information
unless it is required to process a transaction, at your request, or required by law.
You will receive a copy of our privacy notice prior to or at the time you sign an Investment Advisory Agreement
with our firm. Thereafter, we will deliver a copy of the current privacy policy notice to you on an annual
basis. Please contact our main office at the telephone number on the cover page of this brochure if you
have any questions regarding this policy.
Trade errors
In the event a trading error occurs in your account, our policy is to restore your account to the position it
should have been in had the trading error not occurred. Depending on the circumstances, corrective
actions may include canceling the trade, adjusting an allocation, and/or reimbursing the account. If a trade
error results in a profit, the trade error will be corrected in the trade error account of the executing
broker-dealer, and you will not keep the profit.
Class Action Lawsuits
We do not determine if securities held by you are the subject of a class action lawsuit or whether you are
eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation
to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers
of securities held by you.
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FORM ADV PART 2B
SUPERVISED PERSON
BROCHURE
SUPPLEMENT
As of June 1 2026 no
individuals are
supervised.
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