X ADVISORS, LLC

Item 1: Cover Page Part 2A of Form ADV: Firm Brochure June 2025 X Advisors, LLC 2646 Santa Maria Way, Suite #104, Santa Maria, CA 93455 Firm Contact: Tad Bull Chief Compliance Officer This brochure provides information about the qualifications and business practices of X Advisors, LLC. If clients have any questions about the contents of this brochure, please contact us at 805-354- 7250. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any State Securities Authority. Additional information about our firm is also available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #315838. Please note that the use of the term “registered investment adviser” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise clients for more information on the qualifications of our firm and our employees.  Item 2: Material Changes X Advisors, LLC is required to notify clients of any information that has changed since the last annual update of the Firm Brochure (“Brochure”) that may be important to them. Clients can request a full copy of our Brochure or contact us with any questions that they may have about the changes. Since our firm’s last annual amendment filing on 03/13/2024 please see below for the following material changes: Our firm has opened a new branch office location in Encino, CA. Please reach out to X Advisors, LLC for additional information or questions. Additionally, our firm has opened a new branch office in Chevy Chase, MD. Please reach out to X Advisors, LLC for additional information or questions. Lastly, our firm now discloses that we may provide cash or non-cash compensation to unaffiliated persons for testimonials or endorsements (which include client referrals). Please see item 14 of our Form ADV Part 2A, item 14 of Advisor Associate Form ADV Part 2A, or reach out to X Advisors, LLC for additional information or questions. ADV Part 2A – Firm Brochure Page 2 X Advisors, LLC  Item 3: Table of Contents Item 1: Cover Page ..................................................................................................................................... 1 Item 2: Material Changes ......................................................................................................................... 2 Item 3: Table of Contents ......................................................................................................................... 3 Item 4: Advisory Business ........................................................................................................................ 4 Item 5: Fees & Compensation .................................................................................................................. 7 Item 6: Performance-Based Fees & Side-By-Side Management ...................................................... 10 Item 7: Types of Clients & Account Requirements ............................................................................ 10 Item 8: Methods of Analysis, Investment Strategies & Risk of Loss ............................................... 10 Item 9: Disciplinary Information .......................................................................................................... 12 Item 10: Other Financial Industry Activities & Affiliations ............................................................. 13 Item 11: Code of Ethics, Participation or Interest in......................................................................... 13 Item 12: Brokerage Practices ................................................................................................................ 14 Item 13: Review of Accounts or Financial Plans ................................................................................ 16 Item 14: Client Referrals & Other Compensation .............................................................................. 17 Item 15: Custody ...................................................................................................................................... 17 Item 16: Investment Discretion ............................................................................................................ 18 Item 17: Voting Client Securities .......................................................................................................... 19 Item 18: Financial Information ............................................................................................................. 19 ADV Part 2A – Firm Brochure Page 3 X Advisors, LLC  Item 4: Advisory Business Our firm is dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm is a limited liability company formed under the laws of the State of California in 2021 and has been in business as an investment adviser since that time. Our firm is owned by Ryan Gorski, (3.3%), Betsy Ginn (90%), Loren Grabau (3.4%), and Ben McCollum (3.3%). The purpose of this Brochure is to disclose the conflicts of interest associated with the investment transactions, compensation and any other matters related to investment decisions made by our firm or its representatives. As a fiduciary, it is our duty to always act in the client’s best interest. This is accomplished in part by knowing our client. Our firm has established a service-oriented advisory practice with open lines of communication for many different types of clients to help meet their financial goals while remaining sensitive to risk tolerance and time horizons. Working with clients to understand their investment objectives while educating them about our process, facilitates the kind of working relationship we value. Types of Advisory Services Offered Asset Management Services: As part of our Asset Management service, a portfolio is created, consisting of individual stocks, bonds, exchange traded funds (“ETFs”), options, mutual funds and other public and private securities or investments. The clients individual investment strategy is tailored to their specific needs and may include some or all of the previously mentioned securities. Portfolios will be designed to meet a particular investment goal, determined to be suitable to the client’s circumstances. Once the appropriate portfolio has been determined, portfolios are continuously and regularly monitored, and if necessary, rebalanced based upon the client’s individual needs, stated goals and objectives. Financial Planning Services: Our firm provides a variety of standalone financial planning services to clients for the management of financial resources based upon an analysis of current situation, goals, and objectives. The financial plan may include, but is not limited to, review and prioritization of a client’s goals and objectives, development of a net worth statement, cash flow summary and insurance analysis, review of investment holdings, and development of an investment management strategy. A financial plan may also include financial projections and analysis, in addition to education funding, tax, retirement and estate planning analyses. Plans are based on your financial situation at the time and are based on financial information disclosed by you to our firm. Clients are advised to consult with their tax professional and attorneys for all specific tax and legal matters. Clients are also advised to notify us immediately of changes to their financial status, goals, risk tolerance, or any other items of relevance that could impact the advice provided in their financial plan. ADV Part 2A – Firm Brochure Page 4 X Advisors, LLC  Written financial plans or financial consultations rendered to clients usually include general recommendations for a course of activity or specific actions to be taken by the clients. Implementation of the recommendations will be at the discretion of the client. Our firm provides clients with a summary of their financial situation, and observations for financial planning engagements. Financial consultations are not typically accompanied by a written summary of observations and recommendations, as the process is less formal than the planning service. Assuming that all the information and documents requested from the client are provided promptly, plans or consultations are typically completed within 6 months of the client signing a contract with our firm. Wealth Management Services: Based on a client’s individual needs, our firm provides the following additional services: Estate Planning – Coordinate estate planning documents. Assist others in implementation of recommendations that minimize tax consequences and create a more efficient diposition of assets. Our firm and its investment adviser representatives do not prepare estate planning documents or provide legal advice. Fees for this service are in addition to legal fees from third parties, all of which will be borne by the client. Insurance Counseling – Identify life insurance needs, evaluate and coordinate existing insurance coverage. All insurance selections are the responsibility of the client. Investment adviser representatives may be compensated in their separate capacity as insurance agents for any policies that are sold, in addition to the fee for this service. Any other incidental insurance costs or legal fees from third parties are the responsibility of the client. Tax Planning – Provide general information on tax consequences and strategies. Our firm and its investment adviser representatives do not prepare tax returns or provide tax advice. Client will need to refer to their tax professional for a specific advice and any incidental fees charged are in addition to the fees for this service. Clients are advised to consult with their tax professionals are attorneys for all specific tax and legal matters. Clients with fee-based assets under management of $1 million or more with our firm are eligible for the Signature Services Program. Limited are negotiable for clients with fee-based assets under management with our firm of $5 million or more. Upon an eligible client’s request, our firm will agree to pay a portion of the preparation fees for the following: • Preparation and/or amendment of U.S. person wills. (not to exceed $2,000 every 5 years) • Preparation of U.S. personal tax returns. (not to exceed $15000 per year) Defined Contribution Plan Services: For exiting clients with portfolios being managed by our firm, we offer defined contribution plan services to employer sponsored retirement plans. Depending on the type of plan and the specific arrangement with the plan sponsor, our firm may provide one or more of the following services: • Non-discretionary investment advisory services to defined contribution plans (the Plan) with respect to the included assets as defined in accordance with the Plan’s investment policies and objectives. • Assist in the selection and replacement of service providers. • Fee and cost review comparison of existing Plan compared to existing options. ADV Part 2A – Firm Brochure Page 5 X Advisors, LLC  • Ongoing monitoring of investment options and Plan performance without providing specific investment recommendations. • Participant education and enrollment support. • Participant consultation and advice. Consultation Services: Our firm can provide consultation services on a stand-alone basis (outside of and in addition to other services) to companies and foreign clients for a negotiated fee. These consultation services could include, among other things, asset allocation services or financial advice regarding specific personal and business situations. Clients will review and sign a Financial Consulting Services Agreement prior to the onset of service which provides details of the type of consultation being provided, the fee for this service, and other terms and conditions of the contract. This document should be read carefully by the client. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor (“DOL”) Field Assistance Bulletin 2018-02 ceases to be in effect), for purposes of complying with the DOL’s Prohibited Transaction Exemption 2020-02 (“PTE 2020-02”) where applicable, we are providing the following acknowledgement to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. CCR Section 260.235.2 requires that Our firm discloses that a conflict of interest exists between Our firm and our clients. Client is under no obligation to act upon the recommendations provided by Our firm. If Client elects to act on Our firm’s recommendations, client is under no obligation to effect the transaction through Our firm. Tailoring of Advisory Services Our firm offers individualized investment advice to our Asset Management clients. General investment advice will be offered to our Financial Planning clients. ADV Part 2A – Firm Brochure Page 6 X Advisors, LLC  Each one of our firm’s clients has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. This fee includes financial planning services. Participation in Wrap Fee Programs Our firm does not offer or sponsor a wrap fee program. Regulatory Assets Under Management Our firm has $189,928,226 in assets under management as of December 2024. Item 5: Fees & Compensation Compensation for Our Advisory Services Asset Management Services: The maximum annual fee charged for this service will not exceed 2.50%. Fees to be assessed will be outlined in the advisory agreement to be signed by the Client and are based on the scope and complexity of each Client’s circumstance(s). Our firm bills on cash unless indicated otherwise in writing. Annualized fees are billed on a pro-rata basis monthly in advance based on the value of the account(s) on the last business day of the previous month. Fees are negotiable and will be deducted from client account(s). Our firm does not offer direct invoicing. As part of this process, Clients understand the following: a) The client’s independent custodian sends statements at least quarterly showing the market values for each security included in the Assets and all account disbursements; including the amount of the advisory fees paid to our firm; b) Clients will provide authorization permitting our firm to be directly paid by these terms. Our firm will send an invoice directly to the custodian; and c) If our firm sends a copy of our invoice to the client, a legend urging the comparison of information provided in our statement with those from the qualified custodian will be included. Financial Planning Services Our firm charges on a flat fee basis for financial planning services. The total estimated fee, as well as the ultimate fee charged, is based on the scope and complexity of our engagement with the client. Flat fees will not exceed $10,000. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the signed agreement. Our firm will not require a retainer exceeding $1,200 when services cannot be rendered within 6 months. ADV Part 2A – Firm Brochure Page 7 X Advisors, LLC  Defined Contribution Plan Services Our firm is compensated through an annualized asset-based fee, which will be paid monthly in advance. Fees are negotiable and are not based on a share of capital gains upon or capital appreciation of the funds or any portion of the funds. Our firm doing business will quote the Plan a fee based on the fee range below. The fee will be determined based on several factors including size and complexity of the plan, complexity of services, and number of educational seminars per year. Fees range from .40% to .50% of plan assets annually. The management fee is a percentage of the market value of the assets in the account and is agreed upon with the client in the advisory contract prior to the onset of service. No fee adjustments will be made for additional deposits to the Plan or partial withdrawals from the Plan or for account appreciation or depreciation during a calendar month. The account management fee will be payable monthly in advance and will be calculated as a percentage of the market value of all assets in the account on the last business day of each calendar quarter. Payment to our firm must be made payable to our firm within 30 days of receipt of the invoice. In addition to our firm’s advisory fee above, the Plan and/or Plan participants may pay third party administrator fees, custodial fees, account maintenance fees and other fees associated with maintain the Plan Account. Such fees are not charged by our firm and are charged by the product, broker/dealer or account custodian. Our firm does not share in any portion of such fees. Additionally, the Plan and/or Plan participants may pay a proportionate share of the fund’s management and administrative fees and sales charges as well as the mutual fund adviser’s fee of any mutual fund purchased. Such advisory fees are not shared with our firm and are compensated to the fund- manager. Our firm will not receive trail compensation for any other additional compensation on Plan assets other than its advisory fee invoiced. Our firm, its advisors, or the client may terminate this fee-based relationship at any time by providing written notification to the other. In such a circumstance, the monthly fee will be pro-rated based on the number of days the account was open during the current month and the client will be refunded any pre-paid, unearned fees. Consultation Services Consultation fees are negotiable but are typically based on an hourly rate ranging from $400-$500 per hour or a flat rate to be determined on a case-by-case basis. Regardless if the fee is assessed at an hourly rate or as a flat fee, the rate will be defined in the consultation agreement that will be validated by both parties. Otherwise, the client will be billed upon completion of the project. Our firm, its investment adviser representatives, or the client may terminate this consultative relationship at any time by providing written notification to the other. Client will be responsible for any time spent by our firm in providing the consultative services, but any unearned prepaid fees (in the case of a retainer) will be refunded to the client. ADV Part 2A – Firm Brochure Page 8 X Advisors, LLC  Other Types of Fees & Expenses Clients will incur transaction fees for trades executed by the required custodian, via individual transaction charges. These transaction fees are separate from our firm’s advisory fees and will be disclosed by the required custodian, Charles Schwab & Co., Inc. (“Schwab”) which does not charge transaction fees for U.S. listed equities and exchange traded funds. Clients may also pay holdings charges imposed by the required custodian for certain inherited investments, charges imposed directly by a mutual fund, index fund, or exchange traded fund, which shall be disclosed in the fund’s prospectus (e.g., fund management fees and other internal fund expenses), distribution fees, surrender charges, variable annuity fees, IRA and qualified retirement plan fees, mark-ups and mark-downs, spreads paid to market makers, fees for trades executed away from custodian, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. Our firm does not receive a portion of these fees. Termination & Refunds Either party may terminate the advisory agreement signed with our firm for Asset Management services in writing at any time. Clients may terminate the agreement within five days of signing without fee or penalty. Thereafter, upon notice of termination our firm will process a pro-rata refund of the unearned portion of the advisory fees charged in advance. Financial Planning clients may terminate their agreement at any time before the delivery of a financial plan by providing written notice. For purposes of calculating refunds, all work performed by us up to the point of termination shall be calculated per the hourly rate set in the signed agreement. Clients will receive a pro-rata refund of unearned fees based on the time and effort expended by our firm. Commissionable Securities Sales Representatives of our firm are registered representatives of Independent Financial Group, Inc., member FINRA/SIPC. As such they are able to accept compensation for the sale of securities or other investment products, including distribution or service (“trail”) fees. Clients should be aware that the practice of accepting commissions for the sale of securities presents a conflict of interest and gives our firm and/or our representatives an incentive to recommend investment products based on the compensation received. This incentive creates a conflict of interest. Our firm generally addresses commissionable sales conflicts that arise when explaining to clients these sales create an incentive to recommend based on the compensation to be earned and/or when recommending commissionable mutual funds, explaining that “no-load” funds are also available. Such a recommendation will only be made when they are in the client’s best interest. Clients always have the right to decide whether to act on such recommendations by the firm. If they do decide to act on such recommendation, they always have the right to do so through the professional of their choosing. Ryan Gorski is also insurance licensed. Please see item 10 for more information regarding his insurance license and the conflict of interest it creates. ADV Part 2A – Firm Brochure Page 9 X Advisors, LLC  Item 6: Performance-Based Fees & Side-By-Side Management Our firm does not charge performance-based fees and therefore does not engage in side-by-side management. Item 7: Types of Clients & Account Requirements Our firm has the following types of clients: • Individuals and High Net Worth Individuals; • Trusts, Estates or Charitable Organizations; • Corporations, Limited Liability Companies and/or Other Business Types • Pensions and profit-sharing plans Our firm does not impose requirements for opening and maintaining accounts or otherwise engaging us. Item 8: Methods of Analysis, Investment Strategies & Risk of Loss The following methods of analysis and investment strategies may be utilized in formulating our investment advice and/or managing client assets, provided that such methods and/or strategies are appropriate to the needs of the client and consistent with the client's investment objectives, risk tolerance, and time horizons, among other considerations. General Risks of Owning Securities The prices of securities held in client accounts and the income they generate may decline in response to certain events taking place around the world. These include events directly involving the issuers of securities held as underlying assets in a client’s account, conditions affecting the general economy, and overall market changes. Other contributing factors include local, regional, or global political, social, or economic instability and governmental or governmental agency responses to economic conditions. Currency, interest rate, and commodity price fluctuations may also affect security prices and income. The prices of, and the income generated by, most debt securities held by a client’s account may be affected by changing interest rates and by changes in the effective maturities and credit ratings of these securities. For example, the prices of debt securities in the client’s account generally will decline when interest rates rise and increase when interest rates fall. In addition, falling interest rates may cause an issuer to redeem, “call” or refinance a security before its stated maturity, which may result in our firm having to reinvest the proceeds in lower yielding securities. Longer maturity debt securities generally have higher rates of interest and may be subject to greater price fluctuations than shorter maturity debt securities. Debt securities are also subject to credit risk, which is the possibility ADV Part 2A – Firm Brochure Page 10 X Advisors, LLC  that the credit strength of an issuer will weaken and/or an issuer of a debt security will fail to make timely payments of principal or interest and the security will go into default. The guarantee of a security backed by the U.S. Treasury, or the full faith and credit of the U.S. government only covers the timely payment of interest and principal when held to maturity. This means that the current market values for these securities will fluctuate with changes in prevailing interest rates. Investments in securities issued by entities based outside the United States may be subject to increased levels of the risks described above. Currency fluctuations and controls, different accounting, auditing, financial reporting, disclosure, regulatory and legal standards and practices could also affect investments in securities of foreign issuers. Additional factors may include expropriation, changes in tax policy, greater market volatility, different securities market structures, and higher transaction costs. Various administrative difficulties, such as delays in clearing and settling portfolio transactions, or in receiving payment of dividends can increase risk. Finally, investments in securities issued by entities domiciled in the United States may also be subject to many of these risks. Methods of Analysis We use the following methods of analysis in formulating our investment advice and/or managing client assets: • Charting • Cyclical Analysis • Fundamental Analysis • Mutual Fund and/or Exchange Traded Fund (“ETF”) Analysis • Technical Analysis • Quantitative Analysis • Qualitative Analysis • Sector Analysis Investment Strategies We Use We use the following strategies in managing client accounts, provided that such strategies are appropriate to the needs of the client and consistent with the client’s investment objectives, risk tolerance, and time horizons, among other considerations: • Asset Allocation • Long-Term Purchases • Short-Term Purchases • Growth Vs. Value • Growth and Income Models • Models we will customize for the client’s unique investment profile Alternative Investments: Hedge funds, commodity pools, Real Estate Investment Trusts (“REITs”), Business Development Companies (“BDCs”), and other alternative investments involve a high degree of risk and can be illiquid due to restrictions on transfer and lack of a secondary trading market. They can be highly leveraged, speculative and volatile, and an investor could lose all or a substantial amount of an investment. Alternative investments may lack transparency as to share price, valuation and portfolio holdings. Complex tax structures often result in delayed tax reporting. Compared to ADV Part 2A – Firm Brochure Page 11 X Advisors, LLC  mutual funds, hedge funds and commodity pools are subject to less regulation and often charge higher fees and may require “capital calls” which would require additional investment. Alternative investment managers typically exercise broad investment discretion and may apply similar strategies across multiple investment vehicles, resulting in less diversification. Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. While the stock market may increase and the account(s) could enjoy a gain, it is also possible that the stock market may decrease, and the account(s) could suffer a loss. It is important that clients understand the risks associated with investing in the stock market, and that their assets are appropriately diversified in investments. Clients are encouraged to ask our firm any questions regarding their risk tolerance. • Capital Risk • Mutual Fund Risk • Economic Risk • Market Risk • Market Timing Risk • Strategy Risk • Security Specific Risk • Dividend Risk • Care Satellite • Tactical • Dynamic • Strategic Description of Material, Significant or Unusual Risks Our firm generally invests client cash balances in money market funds, FDIC Insured Certificates of Deposit, high-grade commercial paper, mutual funds, ETF’s and/or government backed debt instruments. Our firm may use and look at strategies such as active vs. passive or growth vs. value. Our firm may use Index Funds as a hub, along with a few equities. Saying this, our firm may use the Hub and Spoke model. Ultimately, our firm tries to achieve the highest return on client cash balances through relatively low-risk conservative investments. In most cases, at least a partial cash balance will be maintained in a money market account so that our firm may debit advisory fees for our services related to our Asset Management services, as applicable. Our firm’s research is done independently through third party companies that our firm subscribes to. Item 9: Disciplinary Information There are no legal or disciplinary events that are material to the evaluation of our advisory business or the integrity of our management. ADV Part 2A – Firm Brochure Page 12 X Advisors, LLC  Item 10: Other Financial Industry Activities & Affiliations Our firm is not registered, nor does it have an application pending to register, as a broker-dealer, investment company or pooled investment vehicle, futures commission merchant, commodity pool operator, commodity trading advisor, banking or thrift institution, accountant or accounting firm, lawyer or law firm, insurance company or agency, pension consultant, real estate broker or dealer or a sponsor or syndicator of limited partnership, or an associated person of the foregoing entities. In addition, our firm does not select other advisor representatives for clients. Representatives of our firm are registered representatives of Independent Financial Group, Inc., member FINRA/SIPC. Clients always have the right to decide whether to act on such recommendations by the firm and if they do decide to act on such recommendation, they always have the right to do so through the professional of their choosing. As a result of these transactions, they receive normal and customary commissions. A conflict of interest exists as these commissionable securities sales create an incentive to recommend products based on the compensation earned. To mitigate this conflict, our firm will act in the client’s best interest. Insurance Agents have an incentive to recommend insurance products in order to receive commissions on those products. This incentive creates a conflict of interest. Such a recommendation will only be made when they are in the client’s best interest. Clients always have the right to decide whether to act on such insurance recommendations by the firm and if they do decide to act on such insurance recommendations, they always have the right to do so through the insurance agent of their choosing. Representatives of our firm are investment advisor representatives of Independent Financial Group, Inc. dba Crosby Investment Group an independently owned and unaffiliated registered investment advisor. They receive compensation for managing client accounts at Independent Financial Group, Inc. To mitigate the conflict of interest, representatives of our firm will act in the client’s best interest. Existing clients at IFG will remain/transition to our firm. All new Advisory clients will be clients of X Advisors. Item 11: Code of Ethics, Participation or Interest in Client Transactions & Personal Trading As a fiduciary, it is an investment adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. Our fiduciary duty is the underlying principle for our firm’s Code of Ethics, which includes procedures for personal securities transaction and insider trading. Our firm requires all representatives to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment with our firm, and at least annually thereafter, all representatives of our firm will acknowledge receipt, understanding and compliance with our firm’s Code of Ethics. Our firm and representatives must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure ADV Part 2A – Firm Brochure Page 13 X Advisors, LLC  is provided to give all clients a summary of our Code of Ethics. If a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Our firm recognizes that the personal investment transactions of our representatives demands the application of a Code of Ethics with high standards and requires that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, our firm also believes that if investment goals are similar for clients and for our representatives, it is logical, and even desirable, that there be common ownership of some securities. In order to prevent conflicts of interest, our firm has established procedures for transactions effected by our representatives for their personal accounts1. In order to monitor compliance with our personal trading policy, our firm has pre-clearance requirements and a quarterly securities transaction reporting system for all of our representatives. Neither our firm nor a related person recommends, buys or sells for client accounts, securities in which our firm or a related person has a material financial interest without prior disclosure to the client. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to mitigate this conflict of interest, our related persons will act in the clients best interest and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Likewise, related persons of our firm buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to mitigate this conflict of interest, our related persons will act in the client’s best interest and adhere to our firm’s Code of Ethics, a copy of which is available upon request. Further, our related persons will refrain from buying or selling securities that will be bought or sold in client accounts unless done so after the client execution or concurrently as a part of a block trade. Item 12: Brokerage Practices Selecting a Brokerage Firm While our firm does not maintain physical custody of client assets, we are deemed to have custody of certain client assets if given the authority to withdraw our firm’s management fees from client accounts (see Item 15 Custody, below). Client assets must be maintained by a qualified custodian. Our firm seeks to recommend a custodian who will hold client assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. The factors considered, among others, are these: • Timeliness of execution • Timeliness and accuracy of trade confirmations • Research services provided 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. ADV Part 2A – Firm Brochure Page 14 X Advisors, LLC  • Ability to provide investment ideas • Execution facilitation services provided • Record keeping services provided • Custody services provided • Frequency and correction of trading errors • Ability to access a variety of market venues • Expertise as it relates to specific securities • Financial condition • Business reputation • Quality of services With this in consideration, our firm has an arrangement with Charles Schwab & Co. Inc. (“Schwab”), a qualified custodian from whom our firm is independently owned and operated. Schwab offers services to independent investment advisers which includes custody of securities, trade execution, clearance, and settlement of transactions. Schwab enables us to obtain many no-load mutual funds without transaction charges and other no-load funds at nominal transaction charges. Schwab does not charge client accounts separately for custodial services. Client accounts will be charged transaction fees, commissions or other fees on trades that are executed or settled into the client’s custodial account. These fees are negotiated with Schwab and are generally lower than other custodian customary retail commission rates. This benefits clients because the overall fee paid is often lower than would be otherwise. Schwab may make certain research and brokerage services available at no additional cost to our firm. Research products and services provided by Schwab may include: research reports on recommendations or other information about particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Schwab to our firm in the performance of our investment decision-making responsibilities. The research and brokerage services qualify for the safe harbor exemption defined in Section 28(e) of the Securities Exchange Act of 1934. The research and brokerage services are used by our firm to manage our client accounts. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. As part of our fiduciary duty to our clients, our firm will always endeavor to put the interests of our clients first. Clients should be aware, however, that the receipt of economic benefits by our firm or our related persons creates a conflict of interest and may indirectly influence our firm’s choice of Schwab as a custodial recommendation. Our firm examined this conflict of interest when our firm chose to recommend Schwab and have determined that the recommendation is in the best interest of our firm’s clients and satisfies our fiduciary obligations, including our duty to seek best execution. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Although our firm will seek competitive rates, to the benefit of all clients, our firm may not necessarily obtain the lowest possible commission rates for specific client account transactions. ADV Part 2A – Firm Brochure Page 15 X Advisors, LLC  Soft Dollars Our firm does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities Exchange Act of 1934. The safe harbor research products and services obtained by our firm will generally be used to service all of our clients but not necessarily all at any one particular time. Aggregation of Purchase or Sale Our firm provides investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of a block trade to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more accounts, they are affected only when our firm believes that to do so will be in the best interest of the effected accounts. When such block trades occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, our firm attempts to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, current asset allocation and availability of funds using price averaging, proration, and consistently non-arbitrary methods of allocation (average price). Item 13: Review of Accounts or Financial Plans Our Managing Members review accounts on at least a quarterly basis for our advisory clients. The nature of these reviews is to learn whether client accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Our firm does not provide written reports to clients, unless asked to do so. Verbal reports to clients take place on at least an annual basis when we review the client’s account and client’s profile for any significant changes to the client’s financial profile. Financial Planning clients do not receive reviews of their written plans unless they take action to schedule a financial consultation with us. Our firm does not provide ongoing services to financial planning clients, but are willing to meet with such clients upon their request to discuss updates to their plans, changes in their circumstances, etc. Financial Planning clients do not receive written or verbal updated reports regarding their financial plans unless they separately engage our firm for a post-financial plan meeting or update to their initial written financial plan. Our firm may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. ADV Part 2A – Firm Brochure Page 16 X Advisors, LLC  Item 14: Client Referrals & Other Compensation Schwab Our firm receives economic benefit from Schwab in the form of the support products and services made available to our firm and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit our firm, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability of Schwab’s products and services is not based on our firm giving particular investment advice, such as buying particular securities for our clients. Referral Fees In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Such compensation arrangements will not result in higher costs to the referred client. In this regard, our firm maintains a written agreement with each unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following information will be disclosed clearly and prominently to referred prospective clients at the time of each testimonial or endorsement: • Whether or not the unaffiliated person is a current client of our firm, • A description of the cash or non-cash compensation provided directly or indirectly by our firm to the unaffiliated person in exchange for the referral, if applicable, and • A brief statement of any material conflicts of interest on the part of the unaffiliated person giving the referral resulting from our firm’s relationship with such unaffiliated person. In cases where state law requires licensure of solicitors, our firm ensures that no solicitation fees are paid unless the solicitor is registered as an investment adviser representative of our firm. If our firm is paying solicitation fees to another registered investment adviser, the licensure of individuals is the other firm’s responsibility. Compensation Received from Referrals Other than the soft dollar benefits listed in Item 12 above, our firm does not receive compensation from any third party for the advisory services that we provide to clients. Item 15: Custody Deduction of Advisory Fees: While our firm does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), we are deemed to have custody of certain client assets if ADV Part 2A – Firm Brochure Page 17 X Advisors, LLC  given the authority to withdraw assets from client accounts, as further described below under “Third Party Money Movement.” All of our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. Additionally, if our firm decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those received from our firm. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Third Party Money Movement: On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4)-2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of authorization (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodian: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Item 16: Investment Discretion The firm requires the client to grant discretion for portfolio management services, pursuant to an executed investment advisory client agreement. By granting investment discretion, our firm is authorized to execute securities transactions, determine which securities are bought and sold, and the total amount to be bought and sold. Limitations may be imposed by the client in the form of specific constraints on any of these areas of discretion with our firm’s written acknowledgement. ADV Part 2A – Firm Brochure Page 18 X Advisors, LLC  Item 17: Voting Client Securities Our firm does not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, our firm will forward them to the appropriate client and ask the party who sent them to mail them directly to the client in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 18: Financial Information Our firm is not required to provide financial information in this Brochure because: • Our firm does not require the prepayment of more than $1,200 in fees when services cannot be rendered within 6 months. • Our firm does not take custody of client funds or securities. • Our firm does not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. • Our firm has never been the subject of a bankruptcy proceeding. ADV Part 2A – Firm Brochure Page 19 X Advisors, LLC