Overview

Assets Under Management: $56.3 billion
Headquarters: SANTA BARBARA, CA
High-Net-Worth Clients: 1,769
Average Client Assets: $2 million

Frequently Asked Questions

WORLD INVESTMENT ADVISORS, LLC charges 3.00% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #208512), WORLD INVESTMENT ADVISORS, LLC is subject to fiduciary duty under federal law.

WORLD INVESTMENT ADVISORS, LLC is headquartered in SANTA BARBARA, CA.

WORLD INVESTMENT ADVISORS, LLC serves 1,769 high-net-worth clients according to their SEC filing dated December 03, 2025. View client details ↓

According to their SEC Form ADV, WORLD INVESTMENT ADVISORS, LLC offers financial planning, portfolio management for individuals, portfolio management for pooled investment vehicles, portfolio management for institutional clients, pension consulting services, selection of other advisors, and educational seminars and workshops. View all service details ↓

WORLD INVESTMENT ADVISORS, LLC manages $56.3 billion in client assets according to their SEC filing dated December 03, 2025.

According to their SEC Form ADV, WORLD INVESTMENT ADVISORS, LLC serves high-net-worth individuals, pooled investment vehicles, institutional clients, and pension and profit-sharing plans. View client details ↓

Services Offered

Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Pooled Investment Vehicles, Portfolio Management for Institutional Clients, Pension Consulting, Investment Advisor Selection, Educational Seminars

Fee Structure

Primary Fee Schedule (PART 2A - WEALTH)

MinMaxMarginal Fee Rate
$0 and above 3.00%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $30,000 3.00%
$5 million $150,000 3.00%
$10 million $300,000 3.00%
$50 million $1,500,000 3.00%
$100 million $3,000,000 3.00%

Clients

Number of High-Net-Worth Clients: 1,769
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 6.64
Average High-Net-Worth Client Assets: $2 million
Total Client Accounts: 25,897
Discretionary Accounts: 23,348
Non-Discretionary Accounts: 2,549

Regulatory Filings

CRD Number: 208512
Filing ID: 2031787
Last Filing Date: 2025-12-03 15:41:50
Website: 73

Form ADV Documents

Additional Brochure: PART 2A - WEALTH (2025-11-26)

View Document Text
Item 1 – Cover Page World Investment Advisors, LLC 24 East Cota Street Santa Barbara, CA 93101 Phone: (888) 201-5488 http://www.worldadvisors.com November 26, 2025 This Brochure provides information about the qualifications and business practices of World Investment Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us at (888) 201-5488 or email compliance@worldadvisors.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. World Investment Advisors, LLC, is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. This Brochure is intended, in part, to provide information which can be used to make a determination to hire or retain an Adviser. Additional information about World Investment Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. (Please see page 16 for WIA’s Privacy Policy) i Item 2 – Material Changes The Firm has no material changes to report since the last annual brochure dated March 31, 2025. The Firm has made the following clarification within the Brochure: • • Item 4 – added disclosure regarding Insurance and Annuity Exchange Item 5 – additional detail regarding procedures applicable to account termination Each year, we will provide each client with (i) a free updated Brochure that either includes a summary of material changes or is accompanied by a summary of material changes, or (ii) a summary of material changes that includes an offer to provide a copy of the updated Brochure and information on how clients may obtain the Brochure. Our Brochure may be requested by contacting us toll-free at (888) 201-5488 or by sending an email to compliance@worldadvisors.com. Additional information about World Investment Advisors, LLC is also available via the SEC’s website at www.adviserinfo.sec.gov. The SEC’s website provides information about any persons affiliated with World Investment Advisors, LLC who are registered, or are required to be registered, as investment adviser representatives of World Investment Advisors, LLC. ii Item 3 - Table of Contents Table of Contents Item 1 – Cover Page ....................................................................................................................................... i Item 2 – Material Changes ............................................................................................................................ ii Item 3 - Table of Contents ............................................................................................................................ iii Item 4 – Advisory Business ........................................................................................................................... 1 Item 5 – Fees and Compensation ................................................................................................................. 5 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................ 10 Item 7 – Types of Clients ............................................................................................................................. 10 Item8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 10 Item 9 – Disciplinary Information ............................................................................................................... 11 Item 10 – Other Financial Industry Activities and Affiliations .................................................................... 11 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 12 Item 12 – Brokerage Practices .................................................................................................................... 13 Item 13 – Review of Accounts .................................................................................................................... 14 Item 14– Client Referrals and Other Compensation ................................................................................... 15 Item 15 – Custody ....................................................................................................................................... 15 Item 16 – Investment Discretion ................................................................................................................. 15 Item 17 – Voting Client Securities ............................................................................................................... 16 Item 18 – Financial Information .................................................................................................................. 16 Privacy Policy .............................................................................................................................................. 16 iii Item 4 – Advisory Business World Investment Advisors, LLC (“WIA” or “Adviser”) was established in March 2015. WIA is a wholly owned subsidiary of WIA Holdings, LLC. WIA is an Investment Adviser registered with the U.S. Securities and Exchange Commission under the Investment Advisers Act of 1940. In addition to the Programs described in this Brochure, WIA also offers wrap fee programs, which are disclosed in separate Wrap Fee Brochures. Our wrap fee programs include portfolio management services including mutual funds and exchange traded funds (“ETFs”), along with high quality individual fixed income and equity securities. In a wrap fee program, clients are charged an all-inclusive wrap fee on Program Assets that covers advisory, execution, custodial and reporting services on Eligible Assets. A portion of these fees will be paid to WIA for advisory services. In a non-wrap fee program, WIA’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, technology platforms, third party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund 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 the fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to WIA’s fee, WIA shall not receive any portion of these commissions, fees, and costs. As of December 31, 2024, the Firm had $24,345,157,752 in discretionary assets under management and $31,939,237,892 in non-discretionary assets under management. WIA Wealth WIA provides advisory services through its Wealth Program, giving continuous advice based on the client’s individual needs. Through personal discussions with our clients regarding their goals and objectives the firm will typically develop a personal investment policy based upon which a Client Profile is created and we manage the portfolio according to the criteria in the profile. Through its advisor as portfolio manager program, WIA advisors can deliver customized portfolio solutions through their access to online tools that streamline the process of managing client accounts, including rebalancing and liquidity tools, client-level security restrictions, trading tools, alerts, and integrated reporting functions. Third-Party Money Management WIA has access to a wide range of non-affiliated investment advisors (“third-party money managers”) via the Envestnet ENV2 platform to offer asset allocation and asset management services to WIA advisory clients. Each IAR shall assist their client in formulating a strategic investment portfolio based on the client's investment objectives. Once formulated, if appropriate for the client, a suitable third-party money manager is selected to implement and continually manage the portfolio. In preparing the portfolio, each IAR may set restrictions or limitations on the management of the account and will explain to the client the continual account activity transacted by the third-party money manager. Also, WIA will periodically review the current and historical performance record of each third-party money manager. WIA has also entered into additional agreements with various non-affiliated investment advisors (“third- party money managers”) not available on the Envestnet platform to offer asset allocation and asset management services to WIA advisory clients. In the same way as mentioned above, each IAR shall assist their client in formulating a strategic investment portfolio based on the client's investment objectives. 1 Once formulated, a suitable third-party money manager is selected to implement and continually manage the portfolio. In preparing the portfolio, each IAR may set restrictions or limitations on the management of the account and will explain to the client the continual account activity transacted by the third-party money manager. Also, WIA will periodically review the current and historical performance record of each third-party money manager. The relationship of WIA with any third-party money manager will be clearly communicated to all clients in the third-party money manager’s Client Services Agreement and/or other similar documentation. Each third-party money manager is required to provide WIA and the IAR with a disclosure document statement, typically a copy of their Form ADV 2A. The third-party money manager’s Form ADV 2A will be provided to the client by the IAR. Additionally, WIA advisors may recommend the use of WealthPath models to Clients. These models are managed by WealthPath Advisors, LLC. WealthPath advisors are registered as investment advisor representatives of WIA. When offered to their own clients, there are no additional fees; however, when offered to the clients of other advisors (including other WIA investment advisor representatives), a portion of the total advisory fee charged is paid to WealthPath in exchange for their investment management services. Although the fee paid by the Client is not impacted, WIA receives additional remuneration when WealthPath is selected as the manager of the Clients’ assets because WealthPath is not an outsourced third-party money manager. WIA’s fiduciary responsibility is to always choose the manager or portfolio that is in the best interest of the client. Additionally, WIA does not promote the exclusive use of WealthPath as a third-party money manager alternative. Reasonable Restrictions Each client has the ability to impose reasonable restrictions, in writing, on the management of his/her account, including the designation of particular securities or types of securities that should not be purchased for the account, or that should not be sold if held in the account. If a client’s instructions are unreasonable or an investment advisor representative believes that the instructions are inappropriate for the client, WIA will notify the client that, unless the instructions are modified, it may cancel the instructions in the client’s account. A client will not be able to provide instructions that prohibit or restrict the investment adviser of an open-end or closed-end mutual fund or ETF with respect to the purchase or sale of specific securities or types of securities within the fund. Financial Planning & Analysis As an extension of its wealth advisory services, WIA may provide advice in the form of a Financial Plan. Clients may receive a written plan, providing the client with a detailed financial plan designed to achieve their stated financial goals and objectives. In general, the plan will address any or all of the following: • Personal: Family records, budgeting, personal liability, estate information and financial goals. • Tax and Cash Flow: Income tax, spending analysis and planning for past and future years. • Death and Disability: Cash needs at death, income needs of surviving dependents, estate planning. • Retirement: Strategies and investment plans to help client achieve their retirement goals. • Investments: Analysis of investment alternatives and their effect on a client’s portfolio. Information on clients will be gathered through in-depth personal interviews and review of personal financial information. Gathering data concerning current financial status, future requirements, risk appetite and goals is essential. In some instances, this information may be incorporated into eMoney or 2 another technology solution offering a goals-based approach to financial planning and analysis. The financial management process begins with an in-depth evaluation of the client’s current financial goals and objectives. Once overall objectives have been established, the Advisor will focus on the client’s specific goals. WIA may work with other professionals such as attorneys, certified public accountants, trust officers, mortgage analysts, etc., to offer financial and estate planning advice. WIA specializes in the areas of investment, finance, estate, risk management, retirement, and business continuation planning. eMoney In addition to the aforementioned services, WIA offers investment data storage and periodic comprehensive reporting services which can incorporate all of the client’s investment assets, including those investment assets that are not part of the assets managed by WIA (the “Excluded Assets”). Should the client utilize these reporting services, the client acknowledges and understands that with respect to the Excluded Assets, WIA’s service is limited to reporting and data storage services only and does not include investment management, review, or monitoring services, no investment recommendations or advice. As such, WIA will not be responsible for the investment performance of the Excluded Assets. If the client requests WIA to provide investment management services with respect to the Excluded Assets, the client may engage WIA to do so for a separate and additional fee. Insurance and Annuity Exchange (FIDx) The Insurance and Annuity Exchange, powered by Envestnet, provides end-to-end management of annuity solutions from pre- to post-issuance. Advisors can plan, research, generate proposals, open policies, manage in-force transactions, and create client reports within the Envestnet platform. Insurance and Annuity Exchange is a way to offer long-term protection solutions to clients through a single, unified platform. WorldMAP Program Overview World Managed Account Platform (WorldMAP) is an asset management platform offered by WIA to its clients. WorldMAP provides clients with access to professionally managed portfolios that are designed to achieve certain investment objectives and/or to comply with specific risk limitations and other constraints. The investment manager typically makes investment decisions based on a strategy the manager has developed to meet those objectives and constraints. Typically, the manager creates and maintains a “model portfolio,” that is, a portfolio consisting of certain securities in specific allocations that can be implemented widely in the separate accounts of those clients who subscribe to that manager’s strategy. In some cases, the client’s advisor will create and manage a customized portfolio, rather than a model. Whether managing a model portfolio or a customized portfolio, the manager maintains the portfolio by making decisions to buy and sell securities and to adjust the allocation among the securities held in the portfolio on an ongoing basis. Investment management services under the WorldMAP program are implemented through a portal, or “platform,” to which WIA has been provided access under agreements with Vestmark Advisory Solutions, Inc. and its affiliates (VAS). WorldMAP offers WIA clients access to: (a) model or customized portfolios managed by the client’s advisor (Advisor-Managed Portfolios or “AMP”); (b) model portfolios managed by Cota Street Investment Management, WIA’s investment management team (Cota Street Models); and (c) model portfolios made available to WIA pursuant to a sub-advisory agreement between WIA and VAS that are managed by third- party managers (Third-Party Manager Models). Clients participating in the WorldMAP program will 3 typically hold investments based on one or more of these types of model or customized portfolios. Additionally, through participation in WorldMAP, a client may choose to receive certain tax strategy services and direct indexing services for accounts for which those services are appropriate. Additionally, VAS publishes its own Form ADV, Part 2A, commonly called a “brochure,” which is similar to this document. It describes the VAS platform and services in more detail. The current brochure for VAS will be delivered to clients who participate in the WorldMAP program, and we encourage our clients to review that brochure. The decision to liquidate security issues or mutual funds may result in tax consequences that should be discussed with the client’s tax advisor. Factors that may affect the orderly and efficient manner would be size and types of issues, liquidity of the markets, and market makers’ abilities. Should the necessary securities’ markets be unavailable, and trading suspended, efforts to trade will be done as soon as possible following their reopening, due to the administrative processing time needed to terminate client’s investment advisory services and communicate. WorldMAP Advisor Managed Portfolios (AMP) Accounts participating in AMP are managed and traded by the client’s advisor. Model portfolios created by advisors will vary from one advisor to the next in terms of investment objectives, risk, trading restraints and other factors. Advisors may also offer customized portfolios under the AMP program. AMP offers clients and their advisor the flexibility to structure portfolios in any manner deemed suitable for each client. Whether in a model or customized portfolio, allowable investments include, but are not limited to, equities, fixed income securities, mutual funds, partnership interests, certain unit investment trusts (“UITs”), managed futures funds, ETFs, options or any combination thereof. Portfolios are constructed based on the investment goals established by the client. Prior to opening an account, the client and the advisor will discuss the client’s investment objectives and risk tolerance. From that information, the advisor will either recommend a model portfolio or will construct a portfolio that best matches the client’s individual needs which will be managed by the advisor. The client may impose reasonable restrictions on investing in certain securities or types of securities. After the client’s initial investment, the advisor performs ongoing monitoring and due diligence to ensure the portfolio continues to meet the relevant investment objectives for which the portfolio was originally designed, making changes as needed. AMP accounts can include many combinations of securities and strategies. As such, it is important for each client to discuss with his or her advisor the specific risks associated with the account holdings and/or strategy to ensure the client understands each asset and/or technique used to manage the account. WorldMAP Cota Street Models For the Cota Street Models, the WIA Investment Team analyzes securities and then selects and allocates those securities that the team believes to be the best choices to achieve each model’s objectives within its constraints. These models are made available to the entire network of WIA advisors, but there is no obligation for any advisor to use the models. The models are monitored and reviewed regularly by the team to ensure they continue to meet the investment standards, objectives and constraints for which they were originally selected and allocated. The team will make changes to the models as necessary. 4 WorldMAP Third-Party Manager Models The WIA Investment Team also analyzes Third-Party Manager Models available on the VAS platform and selects certain of those models to be made available to WIA clients. These are made available to the entire network of WIA advisors, but there is no obligation for any advisor to use the models. These models are available for all WIA advisors and WIA clients, subject to client suitability and investment objectives. After the initial approval of the models, the Investment Team performs ongoing monitoring and due diligence of these models to ensure they continue to meet their investment standards and adhere to the investment philosophy and process for which they were originally selected. If a particular Third-Party Manager Model materially deviates from its stated objectives and/or constraints, and/or performance or risk is materially different from the WIA Investment Team’s expectations for the model, the Investment Team may decide to remove the model from the WorldMAP Model Program. Additionally, the Investment Team may remove a Third-Party Manager Model for any reason at any time without advance notice. The Investment Team will provide recommendation(s) for replacement of those models the WIA Investment Team removes from the WorldMAP Model Program. It is possible that a client’s account will be adversely affected if this should happen, as WIA would no longer follow the trading activity of the portfolio manager. In those instances, clients have the option to have their account invested in a new model, or clients may elect to hold one or more securities that were dictated by the discontinued model while not continuing to follow the model in its entirety. In these scenarios, clients should discuss all alternatives with their advisor. WorldMAP Tax-Managed Overlay (TMO) WorldMAP Tax-Managed Overlay (TMO) is available via the VAS platform for clients seeking potential benefits from active tax management of their non-qualified accounts. TMO is a service by which the client’s portfolio is actively managed to generate capital losses to help offset capital gains generated in the subscribing account throughout the tax year. TMO also includes tax transition services for assets being transferred into the account. The tax transition service helps to move client assets from another model or strategy into the WorldMAP model in a tax-efficient manner based on each client's individual tax situation. TMO is optional to clients and available for an additional fee (TMO Fee), over and above the Program Fee. WorldMAP (Cota Street Direct Indexing) WorldMAP Cota Street Direct Indexing (CSDI) is available to clients seeking potential benefits from active tax management and/or personalization of their non-tax-qualified accounts. CSDI is an investment service in which the investment manager buys and sells securities to replicate the performance and risk characteristics of a specified equity index, while simultaneously harvesting securities to create capital losses to help offset capital gains generated in the client account. To participate in the CSDI program, TMO is also required for the entire subscribing client account. CSDI is optional to clients and is available for a fee (CSDI Fee) that is in addition to the Program Fee and TMO Fee, both of which are described below. Item 5 – Fees and Compensation WIA Wealth The specific manner in which fees are charged by the Firm is established in a client’s written agreement (“Agreement”). Fees, for accounts custodied at Schwab, are generally based on a percentage of assets under management as of the last day in the previous month, calculated at an annual rate and billed monthly in advance based on the number of days in that particular month. If the account is custodied at Fidelity the fees are generally based on a percentage of assets under management as of the last day in the previous month, calculated at an annual rate, divided by 12 and billed monthly in advance. In some 5 instances, other methodologies for calculations of fees (i.e., fees payable in arrears or on a quarterly basis) may be employed and will be specifically outlined in the client’s Agreement. WIA IARs may also use a custodian other than Schwab or Fidelity, which will be made clear to the client prior to any accounts being opened. Fees are based on the assets in the account, will never exceed 3.00% and in some instances, may be negotiated. WIA may be under a flat-fee or tiered structure as described in more detail in the client Agreement. The firm, in its sole discretion, may waive or charge a lesser investment advisory fee based upon certain criteria (e.g., historical relationship, type of assets, anticipated future earning capacity, anticipated future additional assets, dollar amounts of assets to be managed, related accounts, account composition, negotiations with clients, etc.). If a client’s Agreement becomes effective as of a day other than the first day of a billing period or if a termination of a client’s Agreement is effective on a day other than the last day of a billing period, the Fees for that billing period shall be prorated (calculated on a per diem basis) and the applicable amount promptly paid by Client to WIA or refunded by WIA to Client, as the case may be. Fees will be deducted from the account directly unless the Client requests to be billed separately. Generally, no further proration is done for additions or withdrawals made during the fee period. Fees may be reduced or waived for WIA employees. Financial Planning WIA may charge a fixed agreed upon rate or an hourly rate for any agreed upon financial planning work. This rate may vary depending on the requested task; however, the client will be provided with an estimate in advance. In some instances, clients may elect to engage in ongoing financial planning for which an ongoing fee will be charged. In these instances, the client will be notified in advance of the cost of the ongoing financial planning, and details about the recurring fee will be specifically outlined in the client’s Agreement. Financial planning fees will be charged at an agreed upon fixed fee, generally ranging from $1,000 to $5,000, or on an hourly basis, generally ranging from $100 to $275 per hour, depending on the nature and complexity of each client's circumstances. In certain instances, financial planning fees may exceed these rates, typically in cases of highly complex circumstances. The firm may also, in its sole discretion, waive or charge a lesser financial planning fee based upon certain criteria (e.g., historical relationship, anticipated future earning capacity, anticipated future additional assets, related accounts, negotiations with clients, etc.). When charging an hourly financial planning fee, an estimate for the total hours will be determined at the start of the advisory relationship. Up to 50% of the estimated fee may be due upon signing the Agreement, with the balance (based on actual hours) due upon presentation of the plan to the client. Typically, the financial plan will be presented to the client within 90 days of the contract date, provided that all of the relevant information needed to prepare the financial plan has been promptly provided by the client. The client may terminate its arrangement at any time, in writing, and will be refunded a portion of the fee based upon a pro-rated calculation related to the time and expense expended by the firm. WorldMAP-Related Fees and Conflicts of Interest Program Fee. WIA charges a Program Fee on all accounts managed in the WorldMAP program (“Program Fee”). From the Program Fee, WIA pays a variety of types of fees to VAS, such as asset-based fees for access to technology, model trading services, back-office services such as account setup and maintenance, and fees for other services provided under WIA’s agreements with Vestmark and VAS. However, the fees 6 payable to Vestmark and VAS will be less than the Program Fee, meaning that a portion of the Program Fee will be retained by WIA. This creates an incentive for WIA to recommend participation in the WorldMAP program, which presents a conflict of interest. This conflict of interest is mitigated through disclosure to clients and by assuring that all client recommendations are made in the client’s best interest, considering all relevant factors, including fees. The way in which WIA compensates our advisors represents an additional conflict of interest with respect to possible recommendations to participate in the WorldMAP program. Specifically, our advisors typically receive a portion of the investment advisory fees WIA receives for management of our clients’ accounts. But an amount equal to the Program Fee will be deducted from the advisory fee prior to calculating the portion of the fee that the advisor would otherwise receive. That means that an advisor has a disincentive to recommend participation in the WorldMAP Program because he or she will receive less compensation for participating accounts. Additionally, if the advisor does recommend the WorldMAP program to a client, he or she has an incentive to raise the client’s investment advisory fee for that client by the amount of the Program Fee, so that the net compensation to the advisor is equal or approximately equal to that which the adviser receives for both WorldMAP and non-WorldMAP clients. In other words, some advisors will pass on to their client the cost of participating in the program. In some cases, advisors will incur administrative or other expenses for clients participating in the WorldMAP programs. These expenses will sometimes be passed on to the client in the form of increased investment advisory fees. This will vary from one advisor to the next. The conflicts of interest discussed above are mitigated through disclosure to clients and by assuring that all client recommendations are made in the client’s best interest, considering all relevant factors, including fees. WIA anticipates that many advisors will, in fact, charge a higher advisory fee for WorldMAP- participating clients than for non-WorldMAP participating clients. Clients should discuss with their advisor the amount of fees incurred in connection with participating in WorldMAP, whether the costs of participating in the program are being passed on to clients, and whether the client’s advisory fee is reasonable in relation to the benefits provided by participating in a WorldMAP model. Strategy Fee. Clients will pay an additional Strategy Fee for some but not all model portfolios or strategies. Unlike the Program Fee, which is paid out of the advisory fee the client is charged, the Strategy Fees are charged in addition to the client’s advisory fee. The Strategy Fee is paid to Vestmark who, in turn, pays the fee to the relevant strategist or third-party manager. The amount of the Strategy Fee varies depending on the strategy. Strategy fees for approved managers will be published as “Guide to Fees” on a regular basis to https://worldadvisors.com/important-disclosures. In the case of Cota Street Model Portfolios, the Strategy Fee is paid to Cota Street. This creates a conflict of interest in the form of an economic incentive for WIA and its advisors to recommend Cota Street strategies or models. This conflict of interest is mitigated through disclosure to clients and by assuring that all client recommendations are made in the client’s best interest, considering all relevant factors, including fees. In the case of advisor created model portfolios, the Strategy Fee is paid to the advisor. This creates a conflict of interest in the form of an economic incentive for WIA advisors to recommend their own strategies or models. This conflict of interest is mitigated through disclosure to clients and by assuring that all client recommendations are made in the client’s best interest, considering all relevant factors, including fees. 7 Tax Management Fee (TMO). The TMO Fee is charged to the subscribing client account by WIA. Unlike the Program Fee, which is paid out of the advisory fee the client is charged, the TMO Fee is charged in addition to the client’s advisory fee. WIA pays a variety of types of fees to VAS in connection with accounts that subscribe to TMO, but WIA retains a portion of the TMO Fee. This creates a conflict of interest because it incentivizes WIA and its advisors to recommend the TMO service to clients for their eligible accounts. WIA mitigates this conflict of interest through disclosure and by assuring that all investment recommendations are made in the client’s best interest. The Tax Management fee will be published within the “Guide to Fees” on a regular basis to https://worldadvisors.com/important-disclosures. Direct Indexing Fee (CSDI Fee). The CSDI Fee is charged to the subscribing client account by WIA. Unlike the Program Fee, which is paid out of the advisory fee the client is charged, the CSDI Fee is charged in addition to the client’s advisory fee. WIA pays a variety of types of fees to VAS in connection with accounts that subscribe to CSDI, but WIA retains a portion of the CSDI Fee. This creates a conflict of interest because it incentivizes WIA and its advisors to recommend the CSDI service to clients for their eligible accounts. WIA mitigates this conflict of interest through disclosure and by assuring that all investment recommendations are made in the client’s best interest. The Direct Indexing fee will be published within the “Guide to Fees” on a regular basis to https://worldadvisors.com/important-disclosures. General Fee Information The advisory fees and transaction charges do not cover charges imposed by third parties for investments held in the account, such as contingent deferred sales charges or 12(b)-1 trails on mutual funds. In addition, each mutual fund or third-party money manager charges asset management fees, which are in addition to the advisory fees charged by our firm. The fees charged by such funds or managers are disclosed in each fund’s prospectus or Manager’s ADV Part 2A. Accounts may require a minimum advisory fee or quarterly maintenance fee that will be detailed in the applicable advisory agreement. The Management Fee also does not cover custodial or platform fees and charges in connection with debit balances; margin interest; odd-lot differentials; IRA fees; transfer taxes; exchange fees; wire transfers; extensions; non-sufficient funds; mailgrams; legal transfers; bank wires; postage; costs associated with exchanging foreign currencies; and SEC fees or other fees or taxes required by law. Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as 12b-1 fees. 12b-1 fees come from fund assets, therefore, indirectly from client assets. Some mutual funds within this program pay 12(b)-1 service fees (typically 0.25% per year) to the Custodian. For certain ERISA accounts, 12b-1 fees in whole or in part are credited back to the account to offset fees charged. 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. Typically, WIA does not recommend mutual funds that charge 12(b)-1 fees when other share classes are available. However, there are instances in which WIA 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 WIA due to investment minimums, or the chosen custodian may make available certain funds which do not carry a transaction fee. WIA does not receive any part of the fees charged by Mutual Funds, and as a fiduciary to your account, will select the most appropriate fund share class. In addition to the fees outlined above, a separate fee of up to 0.05% (5 basis points) may be levied by Envestnet or Tamarac, the firm's technology platforms used for billing and reporting (“platform fee”). This fee may be levied in addition to the advisory fee assessed for investment management services and is not billed as a separate line item. The annual Envestnet/Tamarac platform fee will not exceed 0.05% or a 8 $100.00 minimum annual fee, prorated monthly, whichever is greater. Accordingly, a client might pay an effective rate greater than the rate specified in the fee schedule on their Advisory Agreement. The $100.00 fee is reset annually based on the month the account was originally opened. In the event a third-party money manager is implemented in a client portfolio, the annual Envestnet/Tamarac platform fee will not exceed 0.15% or a $150.00 minimum annual fee, prorated monthly, whichever is greater. This fee may be reduced based on the amount of investable assets and is in addition to the advisory fee assessed by WIA and the third-party asset manager for investment management services. Although WIA believes its fees are reasonable considering the services provided, clients should be aware that such fees may be more or less than the fees and commissions associated with investment advisory and brokerage services purchased separately. The comparison is dependent upon several factors, including the frequency of brokerage activity in the client’s account, the size of the account under management, and any negotiated fee arrangements with respect to the account. An investor should consider these factors prior to opening an Advisory Account with WIA. Transaction fees charged may be higher than those otherwise available if the services were provided separately for a discrete fee or if an Investment Advisor were to select brokerage and negotiate commissions in the absence of the extra consulting service provided. Clients should consider the value of the additional consulting services when making such comparisons. The combination of custodial, consulting, and brokerage services may not be available separately or may require multiple accounts, documentation, and fees. All fees described herein may be subject to negotiation depending on a range of factors including, but not limited to, account size and overall range of services requested. Clients have the option to purchase investment products that WIA and its IARs recommend through other brokers or agents that are not affiliated with WIA. Account Termination Upon notification of the death of a client, WIA will cease advisory services. No additional trading or liquidations will occur, and the account will be frozen until the necessary documents are provided to transfer the account to the individual’s estate, joint owner, or beneficiary, as applicable based on the account type and instructions set up by the client. In addition, all POAs will be canceled. Any prepaid, asset-based fees will be prorated to the date the Firm was notified and rebated to the client. The firm may initiate termination of the contract, with or without cause, upon not less than 30 days’ prior written notice provided to the Client. The contract termination will be effective on the date specified in the notice, provided it is at least 30 days after the client’s receipt of such. WIA does not charge a fee for terminating the contract, but the custodian may charge a termination fee. Upon written receipt of notice from the client to terminate its client Agreement, and unless specific transfer instructions are received, WIA and its representative(s) will cease advisory services. Should the client provide specific instructions to liquidate, WIA will proceed with liquidation of the client’s account in an orderly and efficient manner. There will not be a charge by WIA for such redemption; however, the client should be aware that certain securities impose redemption fees as stated in each company’s prospectus. Additionally, custodians may assess additional redemption fees for short-term liquidations. Clients must keep in mind that the decision to liquidate security issues or mutual funds may result in tax consequences that should be discussed with the client’s tax advisor. Factors that may affect the orderly and efficient manner would be size and types of issues, liquidity of the markets, and market makers’ abilities. Should the necessary securities’ markets be unavailable, and trading suspended, efforts to trade will be done as soon as possible following their reopening. Due to the administrative processing time 9 needed to terminate client’s investment advisory services and communicate the instructions to client’s Investment Advisor, termination orders received from clients are not market orders; it may take several business days under normal market conditions to process the client’s request. During this time, the client’s account is subject to market risk. WIA and its representative(s) are not responsible for market fluctuations in the client’s account from time of written notice until complete liquidation. All efforts will be made to process the termination in an efficient and timely manner. Item 6 – Performance-Based Fees and Side-By-Side Management WIA does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients WIA provides advisory services to Individuals and Retirement Plans including, 401(k) Plans, 403(b) Plans, pensions and profit-sharing plans, non-qualified plans, foundations, endowments, corporations, or other businesses not listed above. For Wealth Clients, Adviser generally does not require a minimum account size but may impose a minimum annual consulting fee. Certain third-party money managers may require a higher minimum account size as disclosed in the individual manager’s Firm Brochure. Under certain circumstances, the minimum may be waived, including related accounts that may be combined to meet the minimum if the services involved may otherwise be provided. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss WIA’s investment strategy begins with an understanding of a client’s financial goals. Advisors use demographic and financial information provided by the client to assess the client’s risk profile and investment objectives in determining an appropriate plan for the client’s assets. Investment strategies ordinarily include long- or short-term purchases of stock portfolios, mutual funds, fixed income securities and third-party money managers, if appropriate. Should the client’s risk profile and/or objectives change during the advisory relationship, the client must notify the advisor accordingly. Investment recommendations are based on an analysis of the client’s individual needs and are drawn from research and analysis. Security analysis methods may include the following: • • Fundamental analysis: WIA attempts to measure the intrinsic value of a security by looking at economic and financial factors to determine if the company is underpriced or overpriced. 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 and charting: WIA attempts to determine the trend of a security by studying past market data, including price and volume. This presents a potential risk, as the price of a security can change direction at any time and past performance is not a guarantee of future performance. • Cyclical analysis: WIA attempts to identify the industry cycle of a company to determine whether the company is in a market introduction phase, growth phase or maturity phase. Generally projected revenues, growth potential and business risk may fluctuate based on the company’s cycle stage. 10 Information for this analysis may be drawn from financial newspapers, websites, and magazines, research materials prepared by others, annual reports, corporate filings, prospectuses, company press releases, and/or corporate ratings services. It is important to note that investing in securities involves a risk that clients should be prepared to bear. For any risks associated with Investment Company products, please refer to the prospectuses for additional details about these risks. WIA’s investment approach constantly keeps the risk of loss in mind. These risks include, but are not limited to: • Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline. • • Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic, and social conditions may trigger market events. Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation. • Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e., interest rate). This primarily relates to fixed income securities. • • • Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like. Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not. Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Item 9 – Disciplinary Information Registered investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to an evaluation of WIA or the integrity of WIA’s management. WIA has no disclosable information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations WIA is a wholly owned subsidiary of WIA Holdings, LLC. Under the common control of WIA Holdings, LLC, WIA is affiliated with Goldman Sachs & Co., LLC, a FINRA broker-dealer (Member SIPC) and SEC Registered Investment Adviser, and World Investments, LLC, a FINRA broker dealer (Members SIPC), WIA is also affiliated with World Insurance Associates, LLC, Scotts American, LLC, Keating, LLC, ESA Associates, LLC, FastComp, LLC, Hamond Safety Management, LLC, Pacific Coast NCA Premium Finance, LLC, and World Insurance Programs, LLC, all insurance agencies engaging in Life, Health, Long Term Care, Variable, and various other Insurance business. 11 Recommendations for Goldman Sachs investment products are limited to a small subset of products approved by WIA. No incentives are provided to WIA or WIA Investment Advisor Representatives to recommend Goldman Sachs products over other investment products. WIA is also affiliated with other financial services companies, but does not have any shared business dealings, operations, referral programs, clients, representatives, or premises with these other companies, and has no reason to believe the firm’s relationship with them otherwise creates a conflict of interest with WIA clients. A full list of WIA’s affiliates will be provided upon request. Investment Adviser Representatives (“IARs”) of WIA may effect securities transactions for Clients as registered representatives of World Investments, LLC. (“WI”) or St. Bernard Securities, LLC (“St. Bernard”), both FINRA broker-dealers. WIA is affiliated with WI through the common control and ownership by WIA Holdings, LLC. WIA has no affiliation with St. Bernard. Advisors that are registered representatives of these firms may recommend either of the two firms with whom they are registered for broker-dealers services. Factors for such a recommendation may be when transaction compensation is seen as a benefit to the client. For broker-dealer services, WI or St. Bernard, or their associated persons, may receive compensation, which is separate and distinct from compensation related to investment advisory services. Commissions paid to advisors for broker-dealer services may be higher or lower than those paid by other brokers. All FINRA, SEC, and other regulatory agencies disclosure requirements and policies are observed for all transactions. If a trade error were to occur, it may result in profit or loss to the firm. The firm has controls in place to limit such trade errors. Investment Advisers will not participate in any profits resulting from such errors. Some IARs of WIA may also be registered as IARs of Acrisure Investment Advisory Solutions, LLC (“Acrisure”). However, these IARs do not effect any transactions through Acrisure. One WIA Advisor is also registered as an Advisor with Nexus338, an advisory firm providing technology-based retirement plan managed account services to non-WIA clients. WIA is not affiliated with Acrisure or Nexus338. Individuals may also write Insurance business through Pensionmark Partners Insurance Services, LLC (“PPIS”) as independent insurance agents. PPIS is affiliated with WIA through common control and ownership. PPIS is an insurance producer group engaging in Life, Health, Long Term Care and Variable Insurance business. Variable insurance products will be offered exclusively through PSC, while fixed products will be offered directly with an insurance carrier through the producer group contracts. Compensation will be paid directly by these entities. Individuals licensed as Registered Representatives or Insurance Agents may spend as much as 50% of their time on these non-advisory activities. When a client’s Advisor is acting in their capacity as registered representatives or independent insurance agents, clients will be charged separately from their advisory services. Clients have the option to purchase investment products that we recommend through other brokers or agents that are not affiliated with WIA. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading WIA has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business 12 entertainment items, and personal securities trading procedures, among other things. All supervised persons at WIA must acknowledge the terms of the Code of Ethics annually, or as amended. Advisors of WIA may buy or sell securities that are recommended to clients. WIA’s employees and persons associated with WIA are required to follow the Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of WIA and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for WIA’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of WIA will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of WIA’s clients. In addition, the Code requires pre-approval of many transactions and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between WIA and its clients. Advisors may recommend and trade in the same securities with clients and/or related accounts at or about the same time. Generally, this would pose a conflict if the Advisor or related account were given a better price than the client. To mitigate this conflict, it is procedure to not trade an Advisors account or related persons account on the same day as a client unless the client gets the better price. Trades may be done on an aggregated basis when consistent with WIA's obligation of best execution. In such circumstances, the Advisor (or related account) and client accounts will share commission costs equally and receive securities at a total average price. WIA will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the order confirmation. WIA’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting WIA at (888) 201-5488 or by sending an email to compliance@worldadvisors.com. Item 12 – Brokerage Practices WIA generally recommends that clients establish brokerage accounts with Charles Schwab & Co., Fidelity Institutional Wealth Services, Pershing LLC or Pershing Advisory Services (“Schwab”, “Fidelity”, “Pershing”, or collectively, “the Custodian(s)”), SEC registered broker-dealers, members FINRA /SIPC, to maintain custody of clients’ assets and to effect trades for their accounts. In some instances, WIA may recommend clients establish brokerage accounts with other custodians. We recommend the services of the Custodian based on several factors including financial strength, reputation, execution, pricing, responsiveness, fees, research, and other services. Although WIA may recommend that clients establish accounts at the Custodian, it is the client’s decision to custody assets with the Custodian. WIA does not direct brokerage to a particular venue for execution but rather relies on the Custodian (with the exception of bond trades that may be directed to a third-party available to WIA through the Custodians’ Platform). Fees and commissions charged by the Custodian may be higher or lower than obtainable elsewhere. Circumstances occasionally arise when the Custodian must impose a separate or special handling or custodial charge for acting as custodian for an exempt security or private placement 13 that was recommended by WIA to a WIA Advisory Client. On a case-by-case basis, WIA may cover the cost of this type of fee on a “value-added” basis by having the fee directly billed to WIA rather than the Client or by reimbursing the Client. WIA is independently owned and operated and not affiliated with any Custodian. Custodians may make products and services available to WIA that benefit WIA but may not directly benefit its clients’ accounts. Many of these products and services are used to service all or a substantial number of WIA accounts. Some of these products and services provided include software and other technology that provides access to client account data (such as trade confirmations and account statements); provides research, pricing, and other market data; facilitates payment of fees from clients’ accounts; and assists with back-office functions, recordkeeping, and client reporting. WIA clients can benefit when trades are aggregated to obtain volume discounts on execution costs. Trade aggregation refers to the practice of combining orders for execution. When consistent with WIA’s duty to obtain best execution, multiple client transactions will be aggregated into a single order to obtain the best price for clients. In such circumstances, the accounts will share commission costs equally and receive securities at a total average price. WIA will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro-rata basis. Any exceptions will be explained on the order. Trade aggregation will typically be done at the branch level. For third-party money managers WIA recommends, WIA does not direct brokerage in these accounts. Brokerage practices of separately managed accounts are disclosed separately in their Brochure(s). Item 13 – Review of Accounts Accounts are assigned to IARs who are responsible for performing periodic reviews and consulting with the respective client. Accounts are reviewed no less than annually by the Advisor. Factors that are considered during such reviews include, but are not limited to, the following: investment objectives, targeted allocation, current allocation, suitability, performance, monthly distributions, concentrated positions, diversification, and outside holdings. Examples of situations that may impact Client’s account would be the following: performance that is not in line with the client’s “downside risk tolerance,” change in investment objective, the client making a significant addition or withdrawal of capital from the account, rebalancing of the portfolio if current allocation and targeted allocation are not consistent, concentrated position(s) that could lead to volatility, etc. Accounts may also be subject to a secondary review by a designated supervisor. Such supervisory reviews will be done on a periodic basis. The supervisor will oversee the selected accounts for the same triggering factors as mentioned above. Advisor has the ability to provide performance reports for assets under advisement through data aggregation and portfolio reporting tools (e.g., Envestnet and Tamarac). For data aggregation purposes, these reports may include information on assets managed by the Adviser for both commissionable and fee-based accounts. The client agrees to inform the firm in writing of any material changes to the information included in the Client Profile or any other change in the client’s financial circumstances that might affect the manner in which the client’s assets should be invested. Clients may contact the firm during normal business hours to consult with the firm concerning the management of the client’s account(s). 14 Item 14– Client Referrals and Other Compensation WIA, in some instances, may compensate third-party promoters for Client referrals. For a promoter to be compensated by WIA for referring a Client to WIA, the promoter must be engaged by WIA under a Promoter or Referral Agreement (“Agreement”) in compliance with Section 206(4)-1 of the Investment Advisers Act of 1940. In general, a promoter is compensated by a percentage of the advisory fee collected for a limited period specified in the Agreement. The Client pays no additional fee for the referral over and above WIA’s quoted advisory fee; on the contrary, the fee the Adviser earns is reduced by the amount of the compensation to the promoter. A Client who is referred by a promoter will receive the promoter’s separate Disclosure Statement describing the nature of the arrangement in detail. Clients may request details regarding a particular Agreement by contacting us toll-free at (888) 679-6067 or by emailing compliance@worldadvisors.com. Certain mutual fund companies, recordkeepers, or other third parties (“Third Parties”) will periodically sponsor educational seminars for participating financial advisors designed to facilitate and promote professional development and product knowledge. To encourage participation, Third Parties will cover travel-related expenses for certain advisors to attend these meetings. Such expense reimbursements are only permissible by WIA when pre-approved, and after review of the agenda and estimated costs. WIA will not approve expense reimbursements by the Third Parties for travel unless the travel expenses appear reasonable and customary; lavish expenses will not be approved. WIA Advisors do not base recommendations on the expectation of such conference and travel. In addition, WIA or its Advisors may host events where Third Parties “sponsor” a specific portion of the event, e.g., the cost of a dinner. WIA Advisors do not base recommendations on the expectation of such event sponsorship. Item 15 – Custody WIA is deemed to have custody of client funds because investment advisory fees are directly debited from some Client accounts. Debiting fees is done pursuant to authorization provided by the Client. Clients should receive statements at least quarterly from the selected qualified Custodian that holds and maintains client’s investment assets. WIA urges clients to carefully review such statements and compare the official custodial records to the account statements that WIA may provide. WIA’s statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. WIA is also deemed to have custody of client assets as a result of certain Clients’ authorization for WIA and/or its IARs to distribute assets from their account(s) to a specific named recipient on demand in accordance with a standing letter of instruction. WIA intends to comply with the SEC No-Action Letter dated 2/21/2017 (Investment Adviser Association) allowing firms complying with the provisions of the No Action Letter to forego an annual surprise custody examination with respect to those assets. Item 16 – Investment Discretion WIA typically acts in a discretionary capacity for its Wealth Clients but may act in a non-discretionary capacity. Discretionary authority provides the WIA Advisor with the authority to determine, without obtaining specific Client consent, both the securities to be bought and sold in their accounts as well as the dollar amount/quantity of securities to be bought and sold. 15 If discretionary authority is granted to select the identity and amount of securities to be bought or sold, clients must authorize such discretion in writing in the advisory agreement. In all cases, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining amounts, WIA observes the investment policies, limitations, and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to WIA in writing. WIA may recommend third-party money managers. When acting in a discretionary capacity, the firm can evaluate managers and may switch money managers or reallocate assets among managers without consulting the client. When acting in a non-discretionary capacity, the Advisor will make recommendations, but only the client has the authority to hire or switch money managers or reallocate assets between programs. In all cases, the Advisor will monitor the performance of the third-party money manager and will make recommendations consistent with the client’s investment objectives and risk tolerance. Item 17 – Voting Client Securities As a matter of firm policy and practice, WIA does not vote proxies on behalf of WIA Wealth advisory clients. Clients retain the responsibility for receiving and voting proxies for all securities maintained in client portfolios. Clients should contact their financial advisor if they have any questions and/or to obtain this information. Clients will receive their proxies directly from their custodian or transfer agent. Clients can authorize third-party investment managers to vote proxy requests on their behalf in their client agreements. Please refer to the respective investment manager's Form ADV for a full disclosure of its proxy voting policies and procedures. Item 18 – Financial Information Registered Investment Advisers are required to provide certain financial information or disclosures about their financial condition. WIA has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients and has not been the subject of any bankruptcy proceedings. Privacy Policy World Investment Advisors, LLC (“WIA”) recognizes that its Clients have an expectation that WIA and its affiliates will maintain the confidentiality of Clients’ nonpublic personal information. Consequently, WIA has adopted this Privacy Policy concerning information obtained during the servicing of Client’s account(s). Nonpublic Information: Nonpublic information obtained by WIA for purposes of providing services hereunder will not be furnished to third parties for any other purpose other than in furtherance of the services to be provided hereunder. Notwithstanding the foregoing, WIA may disclose nonpublic information (i) to the extent such disclosure is required by court order or by a valid order of a governmental body governmental or quasi-governmental agency (such as FINRA) (ii) after the time of disclosure such information becomes part of the public knowledge or literature, not as a result of any inaction or action of WIA, (iii) reasonably necessary for WIA to enforce its legal rights in any dispute with that Client; or (iv) is approved by Client, in writing, for release. WIA does not disclose nonpublic personal information about its Clients to any party except as permitted by law. 16 Sources of Personal Information: WIA collects Personal Information about its Clients from meetings with Clients and on applications or other forms Clients have submitted to WIA, as well as information about Clients’ investments or transactions with WIA or others (such as third-party service providers or fund companies) from other sources. How WIA Protects the Confidentiality of Clients’ Nonpublic Personal Information: WIA does not sell or trade Clients’ information with nonaffiliated companies. When information is provided to third party service providers, safeguards are in place to assure that information is used only for the purpose it is provided. WIA maintains its records on secured computers. Prospective employees are screened for criminal convictions. Once hired, employees are made aware of WIA’s Privacy Policy and of the confidential nature of the information they handle. Employees are limited to accessing only that customer information that is necessary to perform their job functions. To Whom This Policy Applies: This Notice applies to all WIA Clients who enter into an Advisory Services Agreement or Customer Agreement with WIA. For Former Clients: WIA’s Privacy Policy continues to apply even to Clients that have terminated services with the firm. Internet Cookies: An internet “cookie” is a small amount of data that is placed on to your electronic device by a website and stored in your internet browser. Cookies allow websites to store things like preferences, so that it can recognize users when returning to the site and respond appropriately. When individuals access the worldadvisors.com website, WIA makes use of cookies to improve the load times and functionality of the website, and in some cases registration pages. WIA may from time to time also utilize data tracking software to assist in spotting trends and areas of improvement on the website. By accessing the worldadvisors.com site and embedded web pages, users are providing their express approval allowing WIA to utilize these technologies to improve services provided. WIA may also use various third-party cookies to report usage statistics of the service, or to authenticate users and prevent fraudulent access of user accounts. Access to and Correction of Information: Upon the written request of Clients, WIA will make available for review any file that may be maintained for their personal Information; provided, however, that any Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available. If Clients notify WIA that any information is incorrect, the information will be reviewed. If WIA agrees the information is incorrect, records will be corrected. If WIA disagrees, Clients may submit a short statement of dispute, which will be included in any future disclosure of the disputed Information. Additional California Privacy Disclosures: Please consult the supplemental WIA Privacy Notice for California Residents for additional disclosures pertinent to California residents. Further Information: WIA reserves the right to change this Privacy Policy at any time. The examples contained within this Privacy Policy are illustrations and are not intended to be exclusive. This Policy attempts to comply with federal and state regulations regarding privacy. Clients may have additional rights under other foreign or domestic laws that may apply to them. If the financial advisor servicing a client account leaves WIA to join another firm, the advisor is permitted to retain copies of client information so that he/she can assist with the transfer of the client account and continue to serve the client at their new firm. 17 “Opting Out” of Third-Party Disclosures: If a client does not want a financial advisor to retain copies of client sensitive information when he/she leaves WIA to join another firm, the client may contact the WIA Compliance Department by phone at (888) 201-5488 or by email at compliance@worldadvisors.com to request further information regarding this policy. 18

Additional Brochure: WRAP FEE BROCHURE - WORLD ADVISORS WRAP (2025-11-26)

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Item 1 Cover Page World Investment Advisors, LLC 24 East Cota Street Santa Barbara, CA 93101 Phone: (888) 201-5488 http://www.worldadvisors.com November 26, 2025 This wrap fee brochure provides information about the qualifications and business practices of World Investment Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us at (888) 201-5488 or email compliance@worldadvisors.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. World Investment Advisors, LLC is a Registered Investment Adviser. Registration of an Investment Adviser does not imply any level of skill or training. This Brochure is intended, in part, to provide information which can be used to make a determination to hire or retain an Adviser. Additional information about World Investment Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov Item 2 Material Changes As this is the firm’s initial Brochure, there are no material changes to report. 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 World Investment Advisors, LLC is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s website provides information about any persons affiliated with World Investment Advisors, LLC who are registered, or are required to be registered, as investment adviser representatives of World Investment Advisors, LLC. Item 3 Table of Contents Item 1 Cover Page ...................................................................................................................................................................i Item 2 Material Changes ....................................................................................................................................................... ii Item 3 Table of Contents ..................................................................................................................................................... iii Item 4 Services, Wrap Fees, and Compensation ................................................................................................................... 4 Item 5 Account Requirements and Types of Clients ........................................................................................................... 19 Item 6 - Portfolio Manager Selection and Evaluation .......................................................................................................... 20 Item 7 - Client Information Provided to Portfolio Managers ............................................................................................... 20 Item 8 - Client Contact with Portfolio Managers ............................................................................................................... 23 Item 9 - Additional Information ............................................................................................................................................ 23 Privacy Policy ......................................................................................................................................................................... 29 iii Item 4 Services, Wrap Fees, and Compensation World Investment Advisors, LLC (“WIA” or “Adviser”) was established in March 2015. WIA is a wholly owned subsidiary of WIA Holdings, LLC. WIA sponsors this wrap fee program (“World Advisors Wrap”) that is custodied with Pershing, LLC, a non-affiliated clearing broker dealer for custodial and transaction services for client accounts. WIA provides advisory services, giving continuous advice based on the client’s individual needs. Through personal discussions in which goals and objectives based upon the client’s personal objectives are established, the firm will develop a personal investment policy based upon the WIA Client Profile and manage the portfolio according to the criteria. We provide a wide array of advisory services to our clients in which both proprietary and non- proprietary investment options are made available. We may manage these advisory accounts on a discretionary and/or non-discretionary basis. We offer these services to individuals, pension and profit-sharing plans, trusts, estates and/or charitable organizations and also corporations and/or other business entities. The Registrant participates in advisory programs as portfolio manager, advisor, co-advisor or solicitor depending on the program and depending on the needs or direction of its clients. Clients should discuss with their advisor what roles are appropriate, and what programs are appropriate for their investment objectives and risk tolerances. The Registrant also may select other investment advisors for its clients, in particular by advising clients regarding Independent Managers or Third-Party Asset Management Programs ("TAMPs") or by referral arrangements. To the extent the Registrant utilizes an Independent Manager or a Third-Party Money Manager, the Registrant shall provide the Independent Manager or Third-Party Money Manager with each client's particular investment objective and risk tolerance. Any changes in the client's financial situation or investment objectives reported by the client to the Registrant shall be communicated to the Independent Manager or Third-Party Money Manager within a reasonable period of time. Of the funds managed by and/or through the services provided by WIA, the majority are considered "Investment Supervisory Services", meaning we provide continuing advice as to the investment of funds on the basis of the individual needs of each client. These services will generally include the following types of asset management services: • Individual Portfolio Management - we provide asset management of client funds based on the individual needs of the client. The Investment Advisor Representative initially determines the client's financial objectives, time horizons, restrictions, etc; develops the client's personal investment plan; then creates and manages a customized portfolio based on that plan. • Model Portfolio Management - we provide portfolio management services to clients using model asset allocation portfolios. Each model portfolio is designed to meet a particular investment goal. The Investment Advisor Representative initially determines the client's financial objectives, time horizons, restrictions, etc; and determines if the model portfolio is suitable for the client. Once a suitable model is determined, the portfolio is managed based on the portfolio's goals, rather than on each client's individual needs. 4 • Third-Party Money Managers - WIA does not directly manage these client assets. Each Investment Advisor Representative may outsource the management of client funds to an outside money manager who may utilize an investment strategy, which after discussions with the client, may be deemed the closest in line with the client's investment goals and objectives. • Financial Planning and Consulting Services - financial planning is a comprehensive evaluation of a client's current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. Through the financial planning process, all questions, information and analysis are considered as they impact and are impacted by the entire financial and life situation of the client. We also provide on a limited basis, advisory services that differentiate the level of services being provided to the client, reflecting that our management of client portfolios is not continuous and therefore is not "Investment Supervisory Services." These services typically are consultative in nature and are defined by the terms of the underlying contracts as such. Consultative advisory services typically have certain terms associated with the compensation for such services. These associated terms may generally include the following: • Hourly Fees • • Flat - Fee for Service Retainer Fees Outside of the specific mention in the contract, these types of compensation tend to indicate that the advisory services provided are temporary in nature or based upon time spent with the client and not indicative of continuous and regular supervisory or management services. WIA offers these types of services, but they represent a very small part of our advisory business. Third-Party Asset Management Programs ("TAMPS") The Registrant participates in advisory programs as portfolio manager, advisor, co-advisor or solicitor depending on the program and depending on the needs or direction of its clients. Clients should discuss with their advisor what roles are appropriate, and what programs are appropriate for their investment objectives and risk tolerances. The Registrant also may select other investment advisors for its clients, in particular by advising clients regarding Independent Managers or Third-Party Asset Management Programs ("TAMPs") or by choosing from available managers on the Envestnet Asset Management, Inc. ("Envestnet") platform. To the extent the Registrant utilizes an Independent Manager or a Third-Party Money Manager, the Registrant shall provide the Independent Manager or Third-Party Money Manager with each client's particular investment objective and risk tolerance. Any changes in the client's financial situation or investment objectives reported by the client to the Registrant shall be communicated to the Independent Manager or Third-Party Money Manager within a reasonable period of time. The following provides in more detail, the full depth & breadth of the advisory services WIA offers to our clients. 5 INVESTMENT SUPERVISORY SERVICES ("ISS") Individual Portfolio Management Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy and create and manage a portfolio based on that policy. During our data- gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. As appropriate, we also review and discuss a client's prior investment history, as well as family composition and background. We manage these advisory accounts on a discretionary and/or non-discretionary basis and offer both proprietary and non-proprietary alternatives to the client. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. We offer Advisor as Portfolio Manager (APM) Accounts, an asset -based fee account with no commissions or transaction fees to the client. The client, or the investment advisor representative, depending on the agreement signed, may conduct transactions in a wide variety of securities and periodically adjust portfolio holdings as circumstances dictate - for a single asset- based fee. Clients from time to time may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. The firm may not be able to accommodate all requests. Our investment recommendations are limited to specific products or services offered by a broker- dealer or insurance company and will generally include advice regarding the following securities: Exchange-listed securities Securities traded over-the-counter Corporate debt securities (other than commercial paper) Certificates of deposit Interests in partnerships investing in real estate Exchanged Traded Funds Separately Managed Accounts • • • Variable life insurance • Variable annuities • Mutual fund shares • • • Municipal securities • US Government securities • • • • Other Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. 6 Proprietary Model Portfolio Management Our firm provides portfolio management services to clients using model asset allocation portfolios. Our clients have access to these models through our proprietary program branded as "Buy/Hold Plus". Each model portfolio is comprised of mutual funds and/or Exchanged Traded Funds and is designed to meet a specified range of risk tolerance and/or time horizon in connection with a client's broad-based investment goals. Investments in our Traditional Buy/Hold Plus program are based on one of five models and combine traditional asset allocation with our proprietary manager selection process to determine the best performing fund within each asset class. Investments in our Buffered Buy/Hold Plus program utilize buffered or defined outcome ETFs to build portfolios that can prove upside potential to an index-based cap, while still maintaining a degree of downside protection. Managers are screened quarterly and portfolios are conditionally re-balanced according to predetermined allocations. The models and their respective allocations are as follows: • Traditional Models: o Conservative – 30% stock funds, 68% bond funds, 2% cash o Moderately Conservative – 45% stock funds, 53% bond funds, 2% cash o Moderate – 65% stock funds, 33% bond funds, 2% cash o Moderately Aggressive – 75% stock funds, 23% bond funds, 2% cash o Aggressive - 86% stock funds, 12% bond funds, 2% cash • Buffered Models: o Buffered 100 - 98% buffered ETFs, 2% cash o Buffered 60 - 40% equity ETFs, 58% buffered ETFs, 2% cash These advisory accounts are managed on a discretionary basis. Through personal discussions with the client and the use of an investment policy statement questionnaire in which the client's goals and objectives are established, we determine if the model portfolio is suitable to the client's circumstances. Once we determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients do not have the opportunity to place reasonable restrictions on these types of investments held in their account. Clients retain individual ownership of all securities. Our investment recommendations are limited to the specific products or services offered by a broker dealer or insurance company and will generally include advice regarding the following securities: • Exchange-listed securities • Securities traded over-the-counter • Mutual Funds • Exchanged Traded Funds • Variable Annuities Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. 7 To ensure that our initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: • Periodically contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives; • Be reasonably available to consult with the client; • Encourage clients to contact us immediately should there be a change of their financial situation; and • Maintain client suitability information in each client's file. In addition, each introducing investment advisor representative remains in close contact with their respective clients to update various financial information and determine continued suitability. Non-Proprietary Model Portfolio Management Our individual advisory representatives may provide portfolio management services to clients using model asset allocation portfolios. These models may be managed to a specific portfolio goal. The individual advisory representatives manage these advisory accounts on a discretionary or non-discretionary basis. Account supervision is guided by the client's stated objectives (i.e., maximum capital appreciation, growth, income, or growth and income), as well as tax considerations. Through personal discussions with the client in which the client's goals and objectives are established, the individual advisor representative determines if the model portfolio is suitable to the client's circumstances. Once they determine the suitability of the portfolio, the portfolio is managed based on the portfolio's goal, rather than on each client's individual needs. Clients, nevertheless, typically have the opportunity to place reasonable restrictions on the types of investments to be held in their account. Clients retain individual ownership of all securities. These investment recommendations are limited to the specific product or service offered by a broker dealer or insurance company and will generally include advice regarding the following securities: • Exchange-listed securities • Securities traded over-the-counter • Mutual fund shares • Exchanged Traded Funds • Variable Annuities Because some types of investments involve certain additional degrees of risk, they will only be implemented/recommended when consistent with the client's stated investment objectives, tolerance for risk, liquidity and suitability. In some cases, investment advisory representatives may incorporate alternative strategies designed to limit risk but also capture upside potential in both up and down markets. There is no 8 assurance that these strategies will be successful or that any attempted performance goals will be achieved. These strategies may include the use of exchange traded funds that offer leverage or that are designed to perform Inversely to the index or benchmark they track-or both. Our investment advisory representatives are sure to ascertain a client's suitability prior to the use of such instruments or trading strategies, based on a full understanding of the terms and features of the product or strategy recommended. Typically, such products are utilized in sophisticated trading strategies and are highly complex in nature and are disclosed to the clients of WIA as such. In addition, due to the effects of compounding, their performance over longer periods of time can differ significantly from their stated daily objective. Therefore, inverse and/or leveraged ETFs that are reset daily may not be suitable for retail investors who plan to hold them for longer than one trading session. To ensure that initial determination of an appropriate portfolio remains suitable and that the account continues to be managed in a manner consistent with the client's financial circumstances, we will: • Periodically send written reminders to each Model Portfolio Management Services client requesting any updated information regarding changes in the client's financial situation and investment objectives; • Periodically contact each participating client to determine whether there have been any changes in the client's financial situation or investment objectives, and whether the client wishes to impose investment restrictions or modify existing restrictions; • Be reasonably available to consult with the client • Encourage clients to contact us immediately should there be a change of their financial situation; and • Maintain client suitability information in each client's file. Third-Party Manager Programs We also offer advisory management services to our clients through Third-Party Manager Programs (hereinafter, "Programs"). Our firm may provide the client with an asset allocation strategy developed through personal discussions in which goals and objectives based on the client's particular circumstances are established. This asset allocation strategy is drafted into the client's Personal Investment Policy Statement ("PIPS"). Based on the client's individual circumstances and needs (as exhibited in the client's PIPS) we will then perform management searches of various unaffiliated registered investment advisors/ Third-Party managers to identify which registered investment advisor's portfolio management style is appropriate for that client. Factors considered in making this determination include account size, risk tolerance, the opinion of each client and the investment philosophy of the selected registered investment advisor. Clients should refer to the selected registered investment advisor's Firm Brochure or other disclosure document for a full description of the 9 services offered. We are available to meet with clients on a regular basis, or as determined by the client, to review the account. Once we determine the most suitable investment advisor(s) for the client, we may re-affirm the client's investment profile by completing the selected managers PIPS (if applicable). The Third- Party adviser(s) then creates and manages the client's portfolio based on the client's individual needs as exhibited in the PIPS. investment advisor(s) We monitor the performance of the selected registered investment advisor(s). If we determine that a particular selected registered is not providing sufficient management services to the client, or is not managing the client's portfolio in a manner consistent with the client's PIPS, we may suggest that the client contract with a different registered investment advisor and/or program sponsor. Under this scenario, our firm assists the client in selecting a new registered investment advisor and/or program. However, any move to a new registered investment advisor and/or program is solely at the discretion of the client. Third-Party Asset Management Programs ("TAMPS") It is the Third-Party Third-Party Asset Management Programs ("TAMPS") The Registrant may recommend or select other investment advisors for its clients generally through Third-Party Asset Management Programs ("TAMPs"). Envestnet Asset Management, Inc. ("Envestnet") makes available advisory services and programs of Third-Party investment advisors. Through these TAMPs, the Registrant's representatives provide ongoing investment advice to clients that is tailored to the individual needs of the client. As part of these TAMP services, the representative typically obtains the necessary financial data from the client, assists the client in determining the suitability of the program, assists the client in setting an appropriate investment objective and risk tolerance and assists the client in opening an account with the TAMP. In addition, depending on the type of program, the representative may assist the client to select a model portfolio of securities designed by the TAMP or select a portfolio management firm to provide discretionary asset investment advisor (and not Registrant's management services. representative) that has client authority to purchase and sell securities on a discretionary or non- discretionary basis pursuant to investment objective chosen by the client. This authorization will be set out in the TAMP client agreement. The Brochure for the particular TAMP will explain whether clients may impose restrictions on investing in certain securities or types of securities. In particular, the Registrant currently offers advisory services through TAMPs sponsored by,a variety of well diversified asset managers. Clients should refer to the Brochure, client agreement and other account paperwork for each TAMP for more detailed information about the services available under the program. Fees and Compensation Investment Supervisory Services Individual Portfolio Management Fees Our annual fees for Investment Supervisory Services are based upon a percentage of assets under management and generally range from 0.3% to 3.00%. The annualized fee for Investment Supervisory Services will be charged as a percentage of assets under management based on the corresponding program selected by the client, according to the 10 following schedules: Fees shall be prorated and paid quarterly, in advance, based upon the total market value of the assets on the last day of the previous calendar quarter. Initial inception billing will include fees for the remainder of the current calendar quarter, calculated in advance, on a prorated basis from the day the initial deposit was added to the account. Advisor as Portfolio Manager Non-Discretionary Fee Schedule (SILVER) Assets Under Management Annual Fee Consultant Fee Program Fee $10,000 - $24,999 2.30% 1.80% 0.50% $25,000 - $49,999 2.30% 1.90% 0.40% $50,000 - $99,999 2.20% 1.90% 0.30% $100,000 - $249,999 2.25% 2.00% 0.25% $250,000 - $499,999 2.25% 2.05% 0.20% $500,000 - $999,999 2.25% 2.10% 0.15% $1,000,0000 - $1,999,999 2.25% 2.15% 0.10% $2,000,0000 - and above 2.25% 2.15% 0.10% Advisor as Portfolio Manager Discretionary Fee Schedule (SILVER) Assets Under Management Annual Fee Consultant Fee Program Fee $10,000 - $24,999 2.30% 1.80% 0.50% $25,000 - $49,999 2.30% 1.90% 0.40% $50,000 - $99,999 2.20% 1.90% 0.30% $100,000 - $249,999 2.25% 2.00% 0.25% $250,000 - $499,999 2.25% 2.05% 0.20% $500,000 - $999,999 2.30% 2.10% 0.20% $1,000,0000 - $1,999,999 2.30% 2.15% 0.15% $2,000,0000 - and above 2.25% 2.15% 0.10% *Minimum Individual Account $10,000 Minimum Combined Household $25,000 11 Advisor as Portfolio Manager Discretionary Fee Schedule (GOLD) Assets Under Management Annual Fee Consultant Fee Program Fee $50,000 - $99,999 2.50% 2.05% 0.45% $100,000 - $249,999 2.50% 2.10% 0.40% $250,000 - $499,999 2.50% 2.15% 0.35% $500,000 - $999,999 2.50% 2.20% 0.30% $1,000,000 - $1,999,999 2.50% 2.25% 0.25% $2,000,000 - $4,999,999 2.50% 2.30% 0.20% $5,000,000 - $9,999,999 2.50% 2.30% 0.20% $10,000,000 - above 2.50% 2.35% 0.15% A minimum of $50,000 of assets under management is required to participate in the Advisor as Portfolio Manager, Discretionary Asset Management Program (GOLD). This account size may be negotiable under certain circumstances. WIA may group certain related client accounts for the purposes of achieving the minimum household size and determining the annualized fee. Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the contract between the adviser and each client. Investment Advisory Fee Schedule, as outlined below, is a tiered or layered fee schedule, which applies distinct fee rates to different portions of the portfolio. Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons of our firm. Fund Strategist Account Models (FSM) Assets Under Management Annual Fee Consultant Fee Program Fee $50,000 - $99,999 2.50% 1.80% 0.70% $100,000 - $249,999 2.50% 1.85% 0.65% $250,000 - $499,999 2.50% 1.85% 0.65% 12 $500,000 - $999,999 2.50% 1.90% 0.60% $1,000,000 - $1,999,999 2.50% 2.00% 0.50% $2,000,000 - $4,999,999 2.50% 2.05% 0.45% $5,000,000 - $9,999,999 2.50% 2.10% 0.40% $10,000,000 - above 2.50% 2.20% 0.30% A minimum of $50,000 of assets under management is required to participate in the World Fund Strategist Account Models (FSM). This account size may be negotiable under certain circumstances. WIA may group certain related client accounts for the purposes of achieving the minimum household size and determining the annualized fee. Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the contract between the adviser and each client. Investment Advisory Fee Schedule, as outlined below, is a tiered or layered fee schedule, which applies distinct fee rates to different portions of the portfolio. Separately Managed Account Models (SMA) Assets Under Management Annual Fee Consultant Fee Program Fee $100,000 - $249,999 2.65% 1.85% 0.80% $250,000 - $499,999 2.65% 1.85% 0.80% $500,000 - $999,999 2.65% 1.90% 0.75% $1,000,000 - $1,999,999 2.60% 2.00% 0.60% $2,000,000 - $4,999,999 2.60% 2.05% 0.55% $5,000,000 - $9,999,999 2.60% 2.10% 0.40% $10,000,000 - above 2.65% 2.20% 0.45% A minimum of $100,000 of assets under management is required to participate in the World Separately Managed Account Models (SMA) . This account size may be negotiable under certain circumstances. WIA may group certain related client accounts for the purposes of achieving the minimum household size and determining the annualized fee. 13 Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the contract between the adviser and each client. Investment Advisory Fee Schedule, as outlined below, is a tiered or layered fee schedule, which applies distinct fee rates to different portions of the portfolio. Unified Managed Account Models (UMA) Assets Under Management Annual Fee Consultant Fee Program Fee $100,000 - $249,999 2.65% 1.85% 0.80% $250,000 - $499,999 2.65% 1.85% 0.80% $500,000 - $999,999 2.65% 1.90% 0.75% $1,000,000 - $1,999,999 2.60% 2.00% 0.60% $2,000,000 - $4,999,999 2.60% 2.05% 0.55% $5,000,000 - $9,999,999 2.60% 2.10% 0.50% 2.65% 2.20% 0.45% $10,000,000 - above A minimum of $100,000 of assets under management is required to participate in the Unified Managed Account Models (UMA). This account size may be negotiable under certain circumstances. WIA may group certain related client accounts for the purposes of achieving the minimum household size and determining the annualized fee. Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the contract between the adviser and each client. 14 Insurance and Annuity Exchange Variable Annuities Assets Under Management Annual Fee Consultant Fee Program Fee $0 - $99,999 2.20% 1.85% 0.35% $100,000 - $249,999 2.15% 1.85% 0.30% $250,000 - $499,999 2.16% 1.85% 0.31% $500,000 - $749,999 2.17% 1.90% 0.27% $750,000 - $999,999 2.17% 1.90% 0.27% $1,000,000 - $1,999,999 2.24% 2.00% 0.24% $2,000,000 - $4,999,999 2.27% 2.05% 0.22% $5,000,000 - $9,999,999 2.32% 2.10% 0.22% $10,000,000 - + 2.50% 2.30% 0.20% Fixed Annuities Assets Under Management Annual Fee Consultant Fee Program Fee $0 - $99,999 2.18% 1.85% 0.33% $100,000 - $249,999 2.13% 1.85% 0.28% $250,000 - $499,999 2.14% 1.85% 0.29% $500,000 - $749,999 2.15% 1.90% 0.25% $750,000 - $999,999 2.15% 1.90% 0.25% $1,000,000 - $1,999,999 2.22% 2.00% 0.22% $2,000,000 - $4,999,999 2.25% 2.05% 0.20% $5,000,000 - $9,999,999 2.30% 2.10% 0.20% $10,000,000 - + 2.48% 2.30% 0.18% A minimum of $10,000 of assets under management is required to participate in the Insurance and Annuity Exchange (FIDx). This account size may be negotiable under certain circumstances. 15 WIA may group certain related client accounts for the purposes of achieving the minimum household size and determining the annualized fee. Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the contract between the adviser and each client. Investment Advisory Fee Schedule, as outlined below, is a tiered or layered fee schedule, which applies distinct fee rates to different portions of the portfolio. Investment Supervisory Services Proprietary Model Portfolio Management Fees Our annual fees for Model Portfolio Management Services are based upon a percentage of assets under management and generally range from 0.25% to 3.00% for the Traditional Models and .37% to 3.00% for the Buffered Models. The annualized fee for Investment Supervisory Services will be charged as a percentage of assets under management based on the corresponding program selected by the client, according to the following schedules: Fees shall be prorated and paid quarterly, in advance, based upon the total market value of the assets on the last day of the previous calendar quarter. Initial inception billing will include fees for the remainder of the current calendar quarter, calculated in advance, on a prorated basis from the day the initial deposit was added to the account. Our Investment Advisory Fee Schedule, as outlined below, is a tiered or layered fee schedule which applies distinct fee rates to different portions of the portfolio. For the first break point multiply the first range amount, in this case $50,000, by the applicable rate for that range. Next, multiply the second range, in this case $50,000, by its applicable, lower rate, then multiply the third range amount, in this case $150,000, by its applicable lower rate on the schedule, and so on until the calculation is complete. All accounts within the same family (husband, wife, and minor children) are linked and treated as one household for purposes of fee calculations. Corporate accounts are considered separately and, thus, would not be included in the household for the purpose of reducing fees. The discounted fees are calculated based upon the cumulative account values at the end of the prior calendar quarter. Any advanced fees due to the account owner will be prorated and refunded in the event of a liquidation or transfer. Buy/Hold Plus Fee Schedule for Traditional Models Assets Under Management Annual Fee Consultant Fee Program Fee $25,000 - $49,999 2.50% 1.80% 0.70% $50,000 - $99,999 2.50% 1.90% 0.60% 16 $100,000- $249,999 2.50% 2.00% 0.50% $250,000 - $499,999 2.50% 2.05% 0.45% $500,000 - $999,999 2.45% 2.05% 0.40% $1,000,000 - $1,999,999 2.45% 2.10% 0.35% $2,000,000 - $4,999,999 2.45% 2.15% 0.30% $5,000,000- $9,999,999 2.45% 2.20% 0.25% $10,000,000 - and above 2.50% 2.25% 0.25% Buy/Hold Plus Fee Schedule for Buffered Models Assets Under Management Annual Fee Consultant Fee Program Fee $25,000 - $49,999 2.57% 1.80% 0.77% $50,000 - $99,999 2.62% 1.90% 0.72% $100,000- $249,999 2.67% 2.00% 0.67% $250,000 - $499,999 2.70% 2.05% 0.65% $500,000 - $999,999 2.67% 2.05% 0.62% $1,000,000 - $1,999,999 2.68% 2.10% 0.58% $2,000,000 - $4,999,999 2.72% 2.15% 0.57% $5,000,000- $9,999,999 2.76% 2.20% 0.56% $10,000,000 - and above 2.80% 2.25% 0.55% Minimum Account Size $25,000 Minimum Household Size $50,000 17 A minimum of $25,000 of assets under management is required for this service. This household size may be negotiable under certain circumstances. WIA may group certain related client accounts for the purposes of achieving the minimum account size and determining the annualized fee. Limited Negotiability of Advisory Fees: Although WIA has established the aforementioned fee schedule(s), we retain the discretion to negotiate alternative fees on a client-by-client basis. Alternate fee schedules may be utilized based on client facts, circumstances and needs, and will be considered in determining the fee schedule. These include the complexity of the client, assets to be placed under management, anticipated future additional assets; related accounts; portfolio style, account composition, reports, among other factors. The specific annual fee schedule will be identified in the contract between the adviser and each client. Discounts, not generally available to our advisory clients, may be offered to family members and friends of associated persons of our firm. General Information Termination of the Advisory Relationship: Clients may cancel advisory agreements without penalty for a period of five (5) days after the date signed. Agreement shall remain in full force and effect until such time as either party to the agreement receives written notification from the other party of his or her desire to cancel the agreement. Upon receipt by Advisor of written notice of cancellation, the Advisor shall complete the outstanding commitments and obligations made by it on behalf of the investor; however, the Advisor shall not make any new commitments or undertake additional obligations on behalf of the investor. As disclosed above, certain fees are paid in advance of services provided. Upon termination of any account, any prepaid, unearned fees will be promptly refunded. In calculating a client's reimbursement of fees, we will pro rate the reimbursement according to the number of days remaining in the billing period as applicable. Mutual Fund Fees: All fees paid to WIA for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and/or ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees will generally include a management fee, other fund expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge. A client could invest in a mutual fund directly, without our services. In that case, the client would not receive the services provided by our firm which are designed, among other things, to assist the client in determining which mutual fund or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and our fees to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Wrap Fee Programs and Separately Managed Account Fees: Clients participating in separately managed account programs may be charged various program fees in addition to the advisory fee charged by our firm. Such fees may include the investment advisory fees of the independent advisers, which may be charged as part of a wrap fee arrangement. In a wrap fee arrangement, clients pay a single fee for advisory, brokerage and custodial services. 18 Client's portfolio transactions may be executed without commission charge in a wrap fee arrangement. In evaluating such an arrangement, the client should also consider that, depending upon the level of the wrap fee charged by the broker-dealer, the amount of portfolio activity in the client's account, and other factors, the wrap fee may or may not exceed the aggregate cost of such services if they were to be provided separately. We will review with clients any separate program fees that may be charged to clients. Grandfathering of Minimum Account Requirements: Pre-existing advisory clients are subject to WIA minimum account requirements and advisory fees in effect at the time the client entered into the advisory relationship. Therefore, our firm's minimum account requirements will differ among clients. How are Advisory Fees Calculated and Earned: In Advance as a percentage of assets under management How Frequently Do We Collect Advisory Fees: Quarterly How Do We Collect Advisory Fees: • Direct Debit of Client Brokerage, Managed, Mutual Fund or Bank Account • Bill Client Directly • Credit Card Advisory Fees in General: Unless otherwise specified, all asset management fees are typically prorated and paid quarterly, in advance. Fees are billed approximately 15 days after the end of each calendar quarter and where appropriate, deducted directly from the Investor's account. Clients should note that similar advisory services may (or may not) be available from other registered (or unregistered) investment advisers for similar or lower fees. Limited Prepayment of Fees: Under no circumstances do we require or solicit payment of fees in excess of $1200 more than six months in advance of services rendered. Item 5 Account Requirements and Types of Clients WIA provides advisory services to the following types of clients: Individuals (other than high net worth individuals) • • High net worth individuals • Pension and profit-sharing plans(other than plan participants) • Charitable organizations • Corporations or other businesses not listed above. As previously disclosed in Item 5, our firm has established certain initial minimum account requirements, based on the nature of the service(s) being provided. For a more detailed understanding of those requirements, please review the disclosures provided in each applicable service. 19 Item 6 - Portfolio Manager Selection and Evaluation WIA serves as the portfolio manager in the wrap fee program. WIA may outsource its portfolio management by using outside portfolio managers for the referenced Program. WIA uses industry standards to measure the performance of its portfolio managers; however, the firm does not use a third-party auditor to review and verify the performance of its portfolio managers. Item 7 - Client Information Provided to Portfolio Managers WIA is usually both your registered investment adviser and your portfolio manager. WIA may outsource its portfolio management by using outside portfolio managers for the referenced Programs. In some cases, your portfolio manager has the same access to you r information as WIA. This information may include, among other things, income, net worth, risk tolerance, and investment objectives. Portfolio Managers use this information to determine an appropriate asset allocation and manage investments. When a client updates their information with WIA, portfolio managers will be provided with the same updated information. Performance-Based Fees and Side-By-Side Management WIA does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Methods of Analysis We use the following methods of analysis in formulating our investment advice and/or managing client assets: 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. Technical Analysis. We analyze past market movements and apply that analysis to the present in 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 under perform 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. Quantitative Analysis. We use mathematical models in an attempt to obtain more accurate measurements of a company's quantifiable data, such as the value of a share price or earnings per share, and predict changes to that data. A risk in using quantitative analysis is that the models used may be based on assumptions that prove to be incorrect. 20 Asset Allocation. Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income, and cash suitable to the client's investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash will change over time due to stock and market movements and, if not corrected, will no longer be appropriate for the client's goals. Mutual Fund and/or ETF Analysis. We look at the experience and track record of the manager of the mutual fund or ETF in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We may look at the underlying assets in a mutual fund or ETF in an attempt to determine if there is significant overlap in the underlying investments held in another fund(s) in the client's portfolio. We also monitor the funds or ETFs in an attempt to determine if they are continuing to follow their stated investment strategy. A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the holding(s) less suitable for the client's portfolio. Third-Party Money Manager Analysis. We examine the experience, expertise, investment philosophies, and past performance of independent third-party investment managers in an attempt to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We monitor the manager's underlying holdings, strategies, concentrations and leverage as part of our overall periodic risk assessment. Additionally, as part of our due-diligence process, we survey the manager's compliance and business enterprise risks Risks for all forms of analysis. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly-available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. Investment Strategies We use the following strategy(ies) in managing client accounts, provided that such strategy(ies) are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations: Long-term purchases. We purchase securities with the idea of holding them in the client's account for a year or longer. Typically, we employ this strategy when: 21 • we believe the securities to be currently undervalued, and/or • we want exposure to a particular asset class over time, regardless of the current projection for this class. • 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 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. A short-term purchase strategy poses risks should the anticipated price swing not materialize; we are then left with the option of having a long-term investment in a security that was designed to be a short-term purchase, or potentially taking a loss. In addition, this strategy involves more frequent trading than does a longer-term strategy, and will result in increased brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. 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. Utilizing a trading strategy creates the potential for sudden losses if the anticipated price swing does not materialize. Moreover, under those circumstances, we are left with few options: • • having a long-term investment in a security that was designed to be a short-term purchase, or the potential of having to taking a loss. In addition, because this strategy involves more frequent trading than does a longer-term strategy, there will be a resultant increase in brokerage and other transaction-related costs, as well as less favorable tax treatment of short-term capital gains. Risk of Loss. Securities investments are not guaranteed and you may lose money on your investments. We ask that you work with us to help us understand your tolerance for risk. Clients should understand that investing in any securities, including mutual funds, involves a risk of loss of both income and principal. Voting Client Securities As a matter of firm policy, we do not vote proxies on behalf of clients. Therefore, although our firm may provide investment advisory services relative to client investment assets, 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. Clients are responsible for instructing each custodian 22 of the assets, to forward to the client copies of all proxies and shareholder communications relating to the client's investment assets. We may provide clients with consulting assistance regarding proxy issues if they contact us with questions at our principal place of business. Item 8 - Client Contact with Portfolio Managers Clients may communicate with portfolio managers directly during normal business hours. Consultations beyond normal business practices may require additional negotiated fees. Item 9 - Additional Information Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to an evaluation of WIA or the integrity of WIA’s management. WIA has no information applicable to this Item. Other Financial Industry Activities and Affiliations WIA is a wholly owned subsidiary of WIA Holdings, LLC. Under the common control of WIA Holdings, LLC, WIA is affiliated with Goldman Sachs & Co., LLC, a FINRA broker-dealer (Member SIPC) and SEC Registered Investment Adviser, and World Investments, LLC, a FINRA broker dealer (Members SIPC), WIA is also affiliated with World Insurance Associates, LLC, Scotts American, LLC, Keating, LLC, ESA Associates, LLC, FastComp, LLC, Hamond Safety Management, LLC, Pacific Coast NCA Premium Finance, LLC, and World Insurance Programs, LLC, all insurance agencies engaging in Life, Health, Long Term Care, Variable, and various other Insurance business. Recommendations for Goldman Sachs investment products are limited to a small subset of products approved by WIA. No incentives are provided to WIA or WIA Investment Advisor Representatives to recommend Goldman Sachs products over other investment products. WIA is also affiliated with other financial services companies, but does not have any shared business dealings, operations, referral programs, clients, representatives, or premises with these other companies, and has no reason to believe the firm’s relationship with them otherwise creates a conflict of interest with WIA clients. A full list of WIA’s affiliates will be provided upon request. Investment Adviser Representatives (“IARs”) of WIA may effect securities transactions for Clients as registered representatives of World Investments, LLC. (“WI”) or St. Bernard Securities, LLC (“St. Bernard”), both FINRA broker-dealers. WIA is affiliated with WI through the common control and ownership by WIA Holdings, LLC. WIA has no affiliation with St. Bernard. Advisors that are registered representatives of these firms may recommend either of the two firms with whom they are registered for broker-dealers services. Factors for such a recommendation may be when transaction compensation is seen as a benefit to the client. For broker-dealer services, WI or St. Bernard, or their associated persons, may receive compensation, which is separate and distinct from compensation related to investment advisory services. Commissions paid to advisors for broker-dealer services may be higher or lower than those paid by other brokers. 23 All FINRA, SEC, and other regulatory agencies disclosure requirements and policies are observed for all transactions. If a trade error were to occur, it may result in profit or loss to the firm. The firm has controls in place to limit such trade errors. Investment Advisers will not participate in any profits resulting from such errors. One WIA Advisor is also registered as an Advisor with Icon Wealth Partners, LLC. (“IWP”). This Advisor utilizes IWP for their individual wealth clients and only utilizes WIA for their Retirement plan business. Some Investment Adviser Representatives (“IARs”) of WIA may also be registered as IARs of Acrisure Investment Advisory Solutions, LLC (“Acrisure”). However, these IARs do not effect any transactions through Acrisure. One WIA Advisor is also registered as an Advisor with Nexus338, an advisory firm providing technology-based retirement plan managed account services to non-WIA clients. WIA is not affiliated with IWP, Acrisure, or Nexus338. Individuals may also write Insurance business through Pensionmark Partners Insurance Services, LLC (“PPIS”) as independent insurance agents. PPIS is affiliated with WIA through common control and ownership. PPIS is an insurance producer group engaging in Life, Health, Long Term Care and Variable Insurance business. Variable insurance products will be offered exclusively through PSC, while non-variable products will be offered directly with an insurance carrier through the producer group contracts. Compensation will be paid directly by these entities. Individuals licensed as Registered Representatives or Insurance Agents may spend as much as 50% of their time on these non-advisory activities. When a client’s Advisor is acting in their capacity as registered representatives or independent insurance agents, clients will be charged separately from their advisory services. Clients have the option to purchase investment products that we recommend through other brokers or agents that are not affiliated with WIA. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading WIA has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at WIA must acknowledge the terms of the Code of Ethics annually, or as amended. Advisors of WIA may buy or sell securities that are recommended to clients. WIA’s employees and persons associated with WIA are required to follow the Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors, and employees of WIA and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for WIA’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of the employees of WIA will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of WIA’s clients. In addition, the Code requires pre- 24 approval of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client. Employee trading is continually monitored under the Code of Ethics to reasonably prevent conflicts of interest between WIA and its clients. Advisors may recommend and trade in the same securities with clients and/or related accounts at or about the same time. Generally, this would pose a conflict if the Advisor or related account were given a better price than the client. To mitigate this conflict, it is procedure to not trade an Advisors account or related persons’ account on the same day as a client unless the client gets the better price. Trades may be done on an aggregated basis when consistent with WIA's obligation of best execution. In such circumstances, the Advisor (or related account) and client accounts will share commission costs equally and receive securities at a total average price. WIA will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro-rata basis. Any exceptions will be explained on the order. WIA’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting WIA at (888) 201-5488 or by sending an email to compliance@worldadvisors.com. Brokerage Practices Advisory clients of WIA are required to use Pershing, LLC, a non-affiliated clearing broker dealer for custodial and transaction services for client accounts and in some cases for World Securities, Inc. Pershing LLC provides the clearing, asset allocation, custodial and transactional services that are required to operate WIA, as its affiliated broker dealer World Securities, Inc. may not provide one or more of these services. In addition, the use of Pershing LLC enables WIA to pay from the client's advisory fees, some of the transaction fees as described in the fee schedule. Each client of WIA provides written authority for the use of Pershing as the "clearing entity" for their transactions and the commission costs that will be charged for said transactions. Clients must include any limitations on this discretionary authority in the afore mentioned authority statement. Clients may change/amend these limitations as required. Such amendments must be provided to us in writing. Advisory clients of WIA in need of brokerage or custodial services other than the asset allocation services offered, WIA may recommend the use of World Securities, Inc. for those services where the investment advisor representative of WIA is properly licensed to do so and provided WIA can meet its fiduciary obligation of best execution. However, no client is under obligation to effect transactions through any recommended broker. WIA will block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple client 25 accounts, so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. Block trading may allow us to execute equity trades in a timelier, more equitable manner, at an average share price. WIA will typically aggregate trades among clients whose accounts can be traded at a given broker, and generally will rotate or vary the order of brokers through which it places trades for clients on any particular day. WIA block trading policy and procedures are as follows: • Transactions for any client account may not be aggregated for execution if the practice is prohibited by or inconsistent with the client's advisory agreement with WIA, or our firm's order allocation policy. • Trading personnel in concert with the portfolio manager determine that the purchase or sale of the particular security involved is appropriate for the client and consistent with the client's investment objectives and with any investment guidelines or restrictions applicable to the client's account. • The portfolio manager must reasonably believe that the order aggregation will benefit, and will enable WIA to seek best execution for each client participating in the aggregated order. This requires a good faith judgment at the time the order is placed for the execution. It does not mean that the determination made in advance of the transaction must always prove to have been correct in the light of a "20-20 hindsight" perspective. Best execution includes the duty to seek the best quality of execution, as well as the best net price. • Prior to entry of an aggregated order, an electronic order ticket is generated which identifies each client account participating in the order and the proposed allocation of the order, upon completion, to those clients. Trading personnel have the ability to print order tickets or generate a print screen of the entire allocation for any particular aggregated trading activity. • If the order cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated pro rata among the participating client accounts in accordance with the initial order ticket or other written statement of allocation. However, adjustments to this pro rata allocation may be made to participating client accounts in accordance with the initial order ticket or other written statement of allocation. Furthermore, adjustments to this pro rata allocation may be made to avoid having odd amounts of shares held in any client account, or to avoid excessive ticket charges in smaller accounts. • Generally, each client that participates in the aggregated order must do so at the average price for all separate transactions made to fill the order and must share in the commissions on a pro-rata basis in proportion to the client's participation. Under the client's agreement with the custodian/broker, transaction costs may be based on the number of shares traded for each client. 26 • If the order will be allocated in a manner other than that stated in the initial statement of allocation, a written explanation of the change must be provided to and approved by the Chief Compliance Officer no later than the morning following the execution of the aggregate trade. • WIA client account records separately reflect, for each account in which the aggregated transaction occurred, the securities which are held by, and bought and sold for, that account. • Funds and securities for aggregated orders are clearly identified on WIA records and to the broker-dealers or other intermediaries handling the transactions, by the appropriate account numbers for each participating client. • No client or account will be favored over another. Review of Accounts Investment Supervisory Services Individual Portfolio Management REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed regularly as the investment advisor representatives deem necessary. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. These accounts are typically reviewed by the corresponding investment advisor representative. REPORTS: In addition to the monthly statements and confirmations of transactions that clients receive from their custodian, Individual registered investment advisors may provide other reports summarizing account performance, balances and holdings. These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. Investment Supervisory Services Proprietary Model Portfolio Management REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed regularly as the managers deem necessary. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. In addition, the investment advisor representatives review their client accounts on a regular basis. These accounts are typically reviewed by the portfolio manager. REPORTS: In addition to the monthly/quarterly statements and confirmations of transactions that clients receive from the custodian, Individual registered investment advisors may provide other reports summarizing account performance, balances and holdings. These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment 27 objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. Platform Providers, FSP (Fund Strategist Portfolio), SMA(Separately Managed Account), UMA (Unified Managed Account) REVIEWS: While the underlying securities within Individual Portfolio Management Services accounts are continually monitored, these accounts are reviewed regularly as the managers deem necessary. Accounts are reviewed in the context of each client's stated investment objectives and guidelines. More frequent reviews may be triggered by material changes in variables such as the client's individual circumstances, or the market, political or economic environment. In addition, the investment advisor representatives review their client accounts on a regular basis. These accounts are typically reviewed by the portfolio manager. REPORTS: In addition to the monthly/quarterly statements and confirmations of transactions that clients receive from the custodian, Individual registered investment advisors may provide other reports summarizing account performance, balances and holdings. These reports will also remind the client to notify us if there have been changes in the client's financial situation or investment objectives and whether the client wishes to impose investment restrictions or modify existing restrictions. Mutual Fund Portfolio Management REVIEWS: WIA continually reviews and monitors the Mutual Fund's holdings in accordance with the investment objectives as detailed in the Fund Prospectus. REPORTS: Clients should refer to the Fund Prospectus for information regarding regular reports to the fund by WIA. Selection And Monitoring of Third-Party Money Managers REVIEWS: These client accounts should refer to the independent registered investment adviser's Firm Brochure (or other disclosure document used in lieu of the brochure) for information regarding the nature and frequency of reviews provided by that independent registered investment adviser. WIA will provide reviews as contracted at the inception of the advisory relationship. These accounts are typically reviewed by the corresponding investment advisor representative. REPORTS: These clients should refer to the independent registered investment adviser's Firm Brochure (or other disclosure document used in lieu of the brochure) for information regarding the nature and frequency of reports provided by that independent registered investment adviser. WIA will provide these client accounts with reports if and when as contracted for at the inception of the advisory relationship. Custody We previously disclosed in the "Fees and Compensation" section (Item 5) of this Brochure that our firm directly debits advisory fees from client accounts. 28 As part of this billing process, the client's custodian is advised of the amount of the fee to be deducted from that client's account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. Because the custodian does not calculate the amount of the fee to be deducted, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation, among other things. Clients should contact us directly if they believe that there may be an error in their statement. Our firm does not have actual or constructive custody of client accounts. Investment Discretion Clients may hire us to provide discretionary asset management services, in which case we place trades in a client's account without contacting the client prior to each trade to obtain the client's permission. Our discretionary authority includes the ability to do the following without contacting the client: Determine the security to buy or sell; and/or Determine the amount of the security to buy or sell. Clients give us discretionary authority when they sign a discretionary agreement with our firm and may limit this authority by giving us written instructions. Clients may also change/amend such limitations by once again providing us with written instructions. Financial Information Under no circumstances do we require or solicit payment of fees in excess of $1200 per client more than six months in advance of services rendered. Therefore, we are not required to include a financial statement. As an advisory firm, we are also required to disclose any financial condition that is reasonable likely to impair our ability to meet our contractual obligations. WIA has no additional financial circumstances to report. WIA has not been the subject of a bankruptcy petition at any time during the past ten years. Privacy Policy World Investment Advisors, LLC (“WIA”) recognizes that its Clients have an expectation that WIA and its affiliates will maintain the confidentiality of Clients’ nonpublic personal information. Consequently, WIA has adopted this Privacy Policy concerning information obtained during the servicing of Client’s account(s). Nonpublic Information: Nonpublic information obtained by WIA for purposes of providing services hereunder will not be furnished to third parties for any other purpose other than in furtherance of the services to be provided hereunder. Notwithstanding the foregoing, WIA may disclose nonpublic information (i) to the extent such disclosure is required by court order or by a valid order of a governmental body governmental or quasi-governmental agency (such as FINRA) (ii) after the time of disclosure such information becomes part of the public knowledge or literature, not as a result of any inaction or action of WIA, (iii) reasonably necessary for WIA to enforce its legal rights in any dispute with that Client; or (iv) is approved by Client, in writing, for 29 release. WIA does not disclose nonpublic personal information about its Clients to any party except as permitted by law. Sources of Personal Information: WIA collects Personal Information about its Clients from meetings with Clients and on applications or other forms Clients have submitted to WIA, as well as information about Clients’ investments or transactions with WIA or others (such as third-party service providers or fund companies) from other sources. How WIA Protects the Confidentiality of Clients’ Nonpublic Personal Information: WIA does not sell or trade Clients’ information with nonaffiliated companies. When information is provided to third party service providers, safeguards are in place to assure that information is used only for the purpose it is provided. WIA maintains its records on secured computers. Prospective employees are screened for criminal convictions. Once hired, employees are made aware of WIA’s Privacy Policy and of the confidential nature of the information they handle. Employees are limited to accessing only that customer information that is necessary to perform their job functions. To Whom This Policy Applies: This Notice applies to all WIA Clients who enter into an Advisory Services Agreement or Customer Agreement with WIA. For Former Clients: WIA’s Privacy Policy continues to apply even to Clients that have terminated services with the firm. Internet Cookies: An internet “cookie” is a small amount of data that is placed on to your electronic device by a website and stored in your internet browser. Cookies allow websites to store things like preferences, so that it can recognize users when returning to the site and respond appropriately. When individuals access the Worldadvisors.com website, WIA makes use of cookies to improve the load times and functionality of the website, and in some cases registration pages. WIA may from time to time also utilize data tracking software to assist in spotting trends and areas of improvement on the website. By accessing the Worldadvisors.com site and embedded web pages, users are providing their express approval allowing WIA to utilize these technologies to improve services provided. WIA may also use various third-party cookies to report usage statistics of the service, or to authenticate users and prevent fraudulent access of user accounts. Access to and Correction of Information: Upon the written request of Clients, WIA will make available for review any file that may be maintained for their personal Information; provided, however, that any Information collected in connection with, or in anticipation of, any claim or legal proceeding will not be made available. If Clients notify WIA that any Information is incorrect, the information will be reviewed. If WIA agrees the information is incorrect, records will be corrected. If WIA disagrees, Clients may submit a short statement of dispute, which will be included in any future disclosure of the disputed Information. Additional California Privacy Disclosures: Please consult the supplemental WIA Privacy Notice for California Residents for additional disclosures pertinent to California residents. Further Information: WIA reserves the right to change this Privacy Policy at any time. The examples contained within this Privacy Policy are illustrations and are not intended to be 30 exclusive. This Policy attempts to comply with federal and state regulations regarding privacy. Clients may have additional rights under other foreign or domestic laws that may apply to them. If the financial advisor servicing a client account leaves WIA to join another firm, the advisor is permitted to retain copies of client information so that he/she can assist with the transfer of the client account and continue to serve the client at their new firm. “Opting Out” of Third-Party Disclosures: If a client does not want a financial advisor to retain copies of client sensitive information when he/she leaves WIA to join another firm, the client may contact the WIA Compliance Department by calling (888) 201-5488 or by sending an email to compliance@worldadvisors.com to request further information regarding this policy. 31