David Rafael Garcia

Our fees are based on a percentage of client assets that we manage and do not vary based on investment type. We typically deduct fees from clients’ investment accounts each quarter in arrears. The more assets you have in the account, including cash and margin, the more you will pay us, therefore we have an incentive to encourage you to increase the assets in your account in order to increase our fees. We charge our fee even if we do not buy or sell assets in your account, or if your account is profitable or not.

You will have additional fees or costs in addition to our management fee for certain investments listed below.

• Some investments, such as mutual funds and exchange traded funds, impose additional fees that will reduce the value of your investment over time.

• Assets managed by a sub-advisor are subject to the subadvisor’s management fee as well as our fee.

• For certain investments, you will pay a transaction fee. You will also pay fees to an unaffiliated custodian (such as TD Ameritrade, Charles Schwab, or Fidelity) that will hold your assets (called “custody”). We do not receive any portion of these fees.

You will pay fees and costs whether you make or lose money on your investments. Fees and costs will reduce any amount of money you make on your investment over time. Please make sure you understand what fees and costs you are paying. For additional information, please see Item 5 of our Form ADV Part 2A.

When we act as your investment adviser, we are required to act in your best interest and not put our interests ahead of yours. At the same time, the way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you. Here are some examples to help you understand what this means:

• Retirement Plan Rollovers to an IRA - our advisory fees may be higher than your retirement plan fee

• Margin – margin increases the account size subject to our advisory fee

• Referrals to or from our related entities: comparable services may be available elsewhere for less cost

• Benefits received from our custodians

For additional information about our conflicts of interest, please see Items 10, 12, & 14 of our Form ADV Part 2A.

Our financial professionals are paid a salary however our employees are eligible for awards based on the firm’s performance. We have implemented a partnership program which qualifying employees are granted and/or may purchase partnership units based on length of service to the firm and performance. Employees also receive compensation for certain client referrals. A conflict of interest exists where an employee could be motivated to increase assets at the firm regardless of the client’s best interest, however, we are required to always act as a fiduciary when working with our clients. For additional information, please see Item 14 of ourForm ADV Part 2A.