Water Valley Investment Advisors, Inc.

Water Valley Investment Advisors, Inc. Firm Brochure - ADV Part 2A This brochure provides information about the qualifications and business practices of Water Valley Investment Advisors, Inc. If you have any questions about the contents of this brochure, please contact us at 712-395-0764 or by email at: info@wviainc.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 Water Valley Investment Advisors, Inc. is also available on the SEC's website at www.adviserinfo.sec.gov. Water Valley Investment Advisors, Inc.'s CRD number is: 116936. 952 N. Main Ave. Sioux Center, IA 51250 712-395-0764 101 Colorado St., Apt. 1201 Austin, TX 78701 info@wviainc.com https://www.wviainc.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: July 2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Water Valley Investment Advisors, Inc. on March 10, 2026, are described below. Material changes relate to Water Valley Investment Advisors, Inc.'s policies, practices, or conflicts of interests. Item 4 - Water Valley Investment Advisors only provides financial planning services to clients who are currently receiving asset management services from the firm for an asset management fee. WVIA does not offer separate financial planning services. Item 4 - Water Valley Investment Advisors provides periodic newsletter to its clients free of charge. Item 4 and 5 – Water Valley Investment Advisors provides Retirement Plan Services to retirement plans. This advisory service and fees have been further defined in Item 4 and 5. Item 12 – Water Valley Investment Advisors may elect to purchase or sell the same securities for several clients at approximately the same time, referred to as “block trading” when the firm believes such action may prove advantageous to clients. Item 13 - Managed accounts are reviewed at least quarterly and conducted by the CCO and the investment adviser representative of record. 2  Item 3: Table of Contents Item 2: Material Changes ....................................................................................................................................................... 2 Item 3: Table of Contents ....................................................................................................................................................... 3 Item 4: Advisory Business ...................................................................................................................................................... 4 Item 5: Fees and Compensation .............................................................................................................................................. 8 Item 6: Performance-Based Fees and Side-By-Side Management ..................................................................................... 10 Item 7: Types of Clients ........................................................................................................................................................ 10 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ................................................................................. 10 Item 9: Disciplinary Information ......................................................................................................................................... 13 Item 10: Other Financial Industry Activities and Affiliations............................................................................................. 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................... 14 Item 12: Brokerage Practices ............................................................................................................................................... 14 Item 13: Review of Accounts ............................................................................................................................................. 16 Item 14: Client Referrals and Other Compensation ........................................................................................................... 17 Item 15: Custody ................................................................................................................................................................... 17 Item 16: Investment Discretion ............................................................................................................................................ 18 Item 17: Voting Client Securities (Proxy Voting) ............................................................................................................... 18 Item 18: Financial Information .............................................................................................................................................. 18 3  Item 4: Advisory Business A. Description of the Advisory Firm Water Valley Investment Advisors, Inc. (hereinafter ‘WVIA") is a corporation organized in the State of Iowa. The firm was formed in February 1998, and the principal owner and Chief Compliance Officer is Kevin J. Gesink. B. Types of Advisory Services Portfolio Management Services WVIA offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. WVIA creates an Investment Policy Statement for each client, which outlines the client's current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: Personal investment policy Asset selection Regular portfolio monitoring Investment strategy Asset allocation Risk tolerance • • • • • • WVIA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. WVIA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. WVIA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of WVIA's economic, investment or other financial interests. To meet its fiduciary obligations, WVIA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, WVIA's policy is to seek fair and equitable allocation of investment opportunities/ transactions among its clients to avoid favoring one client over another over time. It is WVIA's policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. WVIA offers financial planning services, which involve preparing a written financial plan covering specific or multiple topics. When providing financial planning services, the role of your investment adviser representative is to find ways to help you understand your overall financial situation and help you set financial objectives. WVIA only provides financial planning services to clients who are currently receiving asset management services from WVIA for an asset management fee. WVIA does not offer separate financial planning 4  services. Retirement Plan Services Fiduciary Management Services WVIA provides clients with the following Fiduciary Retirement Plan Management Services: • Discretionary Management Services. WVIA will provide you with continuous and ongoing supervision over the designated retirement plan assets. WVIA will actively monitor the designated retirement plan assets and provide advice regarding buying, selling, reinvesting or holding securities, cash or other investments of the Plan. We have discretionary authority to make all decisions to buy, sell or hold securities, cash or other investments for the designated retirement plan assets in our sole discretion without first consulting with you. We also have the power and authority to carry out these decisions by giving instructions, on your behalf, to brokers and dealers and the qualified custodian(s) of the Plan for our management of the designated retirement plan assets. • Discretionary Investment Selection Services. WVIA will monitor the investment options of the Plan and add or remove investment options for the Plan. WVIA will have discretionary authority to make all decisions regarding the investment options that will be made available to Plan participants. • Default Investment Alternative Management. WVIA will develop and actively manage qualified default investment alternative(s) (“QDIA”), as defined in DOL Reg. Section 2550.404c-5(e)(4)(i), for participants who are automatically enrolled in the Plan or who otherwise fail to make an investment election. If you elect to utilize any of WVIA’s Fiduciary Management Services, then WVIA will be acting as an Investment Manager to the Plan, as defined by ERISA section 3(38), with respect to our Fiduciary Management Services, and WVIA hereby acknowledges that it is a fiduciary with respect to its Fiduciary Management Services. We strive to render our best judgment for clients. Still, WVIA cannot assure that investments will be profitable or assure that no losses will occur in their portfolios. Past performance is an important consideration with respect to any investment or investment advisor, but it is not necessarily an accurate predictor of future performance. WVIA will disclose, to the extent required by ERISA Regulation Section 2550.408b-2(c), to you any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). In accordance with ERISA Regulation Section 2550.408b-2(c)(vi)(A), we will disclose within thirty (30) days following receipt of a written request from the responsible plan 5  fiduciary or Plan Administrator (unless such disclose is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclosed as soon as practicable) all information related to the Qualified Retirement Plan Agreement and any compensation or fees received in connection with the Agreement that is required for the Plan to comply with the reporting and disclosure requirements of Title 1 of ERISA and the regulations, forms and schedules issued thereunder. If we make an unintentional error or omission in disclosing the information required under ERISA Regulation Section 2550.408b-2(c)(1)(iv) or (vi), we will disclose to you the correct information as soon as practicable, but no later than thirty (30) days from the date on which we learns of such error or omission. Retirement Plan Rollover Recommendations When WVIA provides investment advice about your retirement plan account or individual retirement account (“IRA”) including whether to maintain investments and/or proceeds in the retirement plan account, roll over such investment/proceeds from the retirement plan account to a IRA or make a distribution from the retirement plan account, we acknowledge that WVIA is a “fiduciary” within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”) as applicable, which are laws governing retirement accounts. The way WVIA makes money creates conflicts with your interests so WVIA operates under a special rule that requires WVIA to act in your best interest and not put our interest ahead of you. Under this special rule’s provisions, WVIA must act as a fiduciary to a retirement plan account or IRA under ERISA/IRC: • • • • • • Meet a professional standard of care when making investment recommendations (give prudent advice); Never put the financial interests of WVIA ahead of you when making recommendations (give loyal advice); Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that WVIA gives advice that is in your best interest; Charge no more than is reasonable for the services of WVIA; and Give Client basic information about conflicts of interest. To the extent we recommend you roll over your account from a current retirement plan account to an individual retirement account managed by WVIA, please know that WVIA and our investment adviser representatives have a conflict of interest. 6  We can earn increased investment advisory fees by recommending that you roll over your account at the retirement plan to a IRA managed by WVIA. We will earn fewer investment advisory fees if you do not roll over the funds in the retirement plan to an IRA managed by WVIA. Thus, our investment adviser representatives have an economic incentive to recommend a rollover of funds from a retirement plan to an IRA which is a conflict of interest because our recommendation that you open an IRA account to be managed by our firm can be based on our economic incentive and not based exclusively on whether or not moving the IRA to our management program is in your overall best interest. We have taken steps to manage this conflict of interest. We have adopted an impartial conduct standard whereby our investment adviser representatives will (i) provide investment advice to a retirement plan participant regarding a rollover of funds from the retirement plan in accordance with the fiduciary status described below, (ii) not recommend investments which result in WVIA receiving unreasonable compensation related to the rollover of funds from the retirement plan to an IRA, and (iii) fully disclose compensation received by WVIA and our supervised persons and any material conflicts of interest related to recommending the rollover of funds from the retirement plan to an IRA and refrain from making any materially misleading statements regarding such rollover. When providing advice to a retirement plan account or IRA, our investment advisor representatives will act with the care, skill, prudence, and diligence under the circumstances then prevailing that a prudent person acting in a like capacity and familiar with such matters would use in the conduct of an enterprise of a like character and with like aims, based on the investment objectives, risk, tolerance, financial circumstances, and a client’s needs, without regard to the financial or other interests of WVIA or our affiliated personnel. Newsletters WVIA occasionally prepares general, educational and informational newsletters. Newsletters are always offered on an impersonal basis and do not focus on the needs of a specific individual. Newsletters are provided free of charge. Services Limited to Specific Types of Investments WVIA generally limits its investment advice to mutual funds, fixed income securities, equities and ETFs, although WVIA primarily recommends mutual funds. WVIA may use other securities as well to help diversify a portfolio when applicable. 7  C. Client Tailored Services and Client Imposed Restrictions WVIA will tailor a program for each individual client. This will include an interview session to get to know the client's specific needs and requirements as well as a plan that will be executed by WVIA on behalf of the client. WVIA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent WVIA from properly servicing the client account, or if the restrictions would require WVIA to deviate from its standard suite of services, WVIA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs. WVIA does not participate in wrap fee programs. E. Assets Under Management WVIA has the following assets under management: Non-discretionary Amounts: I Date Calculated: Discretionary Amounts: I December 2025 $ 157,226,348 $0 II Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $1,000,000 1.00% $1,000,001 - $2,000,000 0.75% $2,000,001 - AND UP 0.50% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. 8  These fees are generally negotiable and the final fee schedule will be memorialized in the client's advisory agreement. The fee is negotiable based on the type of client, the complexity of the client’s situation, the composition of the client’s account, the potential for additional account deposits, the relationship of the client with the investment adviser representative, family-related accounts, accounts related to education, charities or ministries and the total amount of assets under management for the client. A client’s negotiated fee may range between 0.25% to 1%. Clients may terminate the agreement without penalty for a full refund of WVIA's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 30 days' written notice. Retirement Plan Fees WVIA will charge an annual fee that is calculated as a percentage of the value of plan assets. This fee is negotiable and ranges between 0.25% and 0.5%. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis. Fees are paid in advance. Payment of Retirement Plan Fees Plans can elect to have the fee deducted from their account or billed directly and due upon receipt of the billing notice. If Plans elect to have the fee automatically deducted from an existing account, they are required to provide the custodian with written authorization to deduct the fees from the account and pay the fees to WVIA. We will provide the custodian with a fee notification statement. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by WVIA. Please see Item 12 of this brochure regarding broker-dealer/ custodian. D. Prepayment of Fees WVIA collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check, or return deposit back into the client's account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of 9  the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) E. Outside Compensation For the Sale of Securities to Clients Neither WVIA nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management WVIA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients WVIA generally provides advisory services to the following types of clients: ❖ ❖ ❖ ❖ Individuals High-Net-Worth Individuals Charitable Organizations Retirement Plans WVIA requires a minimum of $250,000 in order to open an account. To reach this account minimum, clients can aggregate all household accounts. Exceptions may be granted to this minimum at the firm’s discretion. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis WVIA's methods of analysis include Fundamental analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/ or the analysis of management or competitive advantages. Investment Strategies WVIA uses long term trading. 10  Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company's value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/ regulatory risk. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond "fixed income" nature (lower risk) or stock "equity'' nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/ or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds 11  may be the best-known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/ inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially "time the market" is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF's shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 12  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither WVIA nor its representatives are registered as, or have pending applications to become, a broker/ dealer or a representative of a broker/ dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither WVIA nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither WVIA nor its representatives have any material relationships to this advisory business that would present a possible conflict of interest. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections WVIA does not utilize nor select third-party investment advisers. 13  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics WVIA has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. WVIA1s Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests WVIA and its associated persons may have material financial interests in issuers of securities_-that WVIA may recommend for purchase or sale by clients However, at this time we have no such interest in any issuers of such securities. This presents a conflict of interest in that WVIA or its related persons may receive more compensation from investment in a security in which WVIA or a related person has a material financial interest than from other investments. Client approval will be sought for client investment in such recommendations and, if granted, such approval will be binding. WVIA always acts in the best interest of the client consistent with its fiduciary duties and clients are not required invest in such investments if they do not wish to do so. C. Investing Personal Money in the Same Securities as Clients WVIA will recommend to client securities in which the firm or its representatives also invest. D. Trading Securities At/Around the Same Time as Clients' Securities Please see Item 11.C above. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on WVIA's duty to seek "best 14  execution," which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and WVIA may also consider the market expertise and research access provided by the broker- dealer/ custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in WVIA's research efforts. WVIA will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/ custodian. WVIA recommends Schwab Institutional, a division of Charles Schwab & Co., Inc. 1. Research and Other Soft-Dollar Benefits WVIA receives access to Schwab's institutional trading and custody services, which are typically not available to Schwab retail investors. Schwab's services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors. For WVIA client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to WVIA other products and services that benefit WVIA but may not benefit its clients' accounts. These benefits may include national, regional or WVIA specific educational events organized and/ or sponsored by Schwab Advisor Services, which WVIA would pay for. Other of these products and services assist WVIA in managing and administering clients' accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of WVIA's fees from its clients' accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of WVIA's accounts. WVIA is independently owned and operated and not affiliated with Schwab. 2. Brokerage for Client Referrals WVIA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 15  3. Clients Directing Which Broker/Dealer/Custodian to Use WVIA may permit clients to direct it to execute transactions through a specified broker-dealer. If a client directs brokerage, then the client will be required to acknowledge in writing that the client's direction with respect to the use of brokers supersedes any authority granted to WVIA to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts We may elect to purchase or sell the same securities for several clients at approximately the same time. This process is referred to as aggregating orders, batch trading or block trading and is used by our firm when WVIA believes such action may prove advantageous to clients. If and when we aggregate client orders, allocating securities among client accounts is done on a fair and equitable basis. Typically, the process of aggregating client orders is done in order to achieve better execution, to negotiate more favorable commission rates or to allocate orders among clients on a more equitable basis in order to avoid differences in prices and transaction fees or other transaction costs that might be obtained when orders are placed independently. WVIA uses the average price allocation method for transaction allocation. Under this procedure WVIA will calculate the average price and transaction charges for each transaction included in a block order and assign the average price and transaction charge to each allocated transaction executed for the client’s account. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Managed accounts are reviewed at least quarterly. Account reviews will include investment strategy and objectives review and making a change if strategy and objectives have changed. Reviews are conducted by Kevin Gesink and the investment adviser representative of record, with reviews performed in accordance with your investment goals and objectives.” All client accounts for WVIA's advisory services provided on an ongoing basis are reviewed at least annually with clients by Kevin J. Gesink, with regard to clients' respective investment policies and risk tolerance levels. All accounts at WVIA are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes 16  in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of WVIA's advisory services provided on an ongoing basis will receive a monthly report detailing the client's account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. WVIA will also provide at least quarterly a separate written statement to the client. Item 14: Client Referrals and Other Compensation Benefits Provided by Third Parties for Advice A. Economic Rendered to Clients (Includes Sales Awards or Other Prizes) WVIA does not receive any economic benefit, directly or indirectly from any third party for advice rendered to WVIA's clients. B. Compensation to Non - Advisory Personnel for Client Referrals II WVIA does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, WVIA will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. For accounts in which WVIA is deemed to have custody, we have established procedures to ensure all client funds and securities are held at a qualified custodian in a separate account for each client under that client’s name. Clients or an independent representative of the client will direct, in writing, the establishment of all accounts and therefore are aware of the qualified custodian’s name, address and the manner in which the funds or securities are maintained. Finally, account statements are delivered directly from the qualified custodian to each client, or the client’s independent representative, at least quarterly. Clients should carefully review those statements and are urged to compare the statements against reports received from WVIA. When clients have questions about their account statements, they should contact WVIA or the qualified custodian preparing the statement. 17  Item 16: Investment Discretion WVIA provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, WVIA generally manages the client's account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/ sold, what securities to buy or sell, or the price per share. In some instances, WVIA's discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to WVIA. Item 17: Voting Client Securities (Proxy Voting) WVIA will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet WVIA neither requires nor solicits prepayment of more than $1200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither WVIA nor its management has any financial condition that is likely to reasonably impair WVIA's ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years WVIA has not been the subject of a bankruptcy petition in the last ten years. 18