A. Firm Information Navis Wealth Advisors, LLC (“Navis Wealth Advisors” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (“LLC”) under the laws of the State of Delaware. Navis Wealth Advisors was founded in September 2020 and became a registered investment advisor in November 2020. Navis Wealth Advisors is a wholly-owned subsidiary of Navis Wealth Management LLC, which is a wholly-owned by Navis Wealth Partners, LLC. The indirect majority owners of Navis Wealth Partners are Paul C. Fegan, Jr. and David S. Price. Navis Wealth Advisors is operated by Paul C. Fegan, Jr. (Managing Partner and Chief Compliance Officer) and David S. Price (Managing Partner). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Navis Wealth Advisors. For information regarding this Disclosure Brochure, please contact the Advisor at (914) 848-8300 or by email at [email protected]. B. Advisory Services Offered Navis Wealth Advisors offers wealth management services to individuals, high net worth individuals, trusts, estates, and businesses (each referred to as a “Client”). The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts of interest. Navis Wealth Advisors' fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading. Wealth Management Services Navis Wealth Advisors provides customized wealth management services for its Clients. This is achieved through continuous personal Client contact and interaction while providing a broad range of comprehensive financial planning in connection with discretionary investment management of Client portfolios. These services are described below. Investment Management Services - Navis Wealth Advisors provides discretionary investment management services. Navis Wealth Advisors works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. Navis Wealth Advisors will then construct an investment portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”), individual stocks, options, and alternative investments to achieve the Client’s investment goals. The Advisor may retain a Client’s legacy investments based on portfolio fit and/or tax considerations. Navis Wealth Advisors’ investment strategies are primarily long-term focused, but the Advisor may buy, sell or re- allocate positions that have been held for less than one year to meet the objectives of the Client or due to market conditions. Navis Wealth Advisors will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance by the Advisor. Navis Wealth Advisors evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Navis Wealth Advisors may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Navis Wealth Advisors may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement. Navis Wealth Advisors may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance. At no time will Navis Wealth Advisors accept or maintain custody of a Client’s funds or securities, except for the limited authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian, pursuant to the terms of the wealth management agreement. Please see Item 12 – Brokerage Practices. Use of Independent Managers - Navis Wealth Advisors may recommend that Clients utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy remains aligned with Clients investment objectives and overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations and managing the ongoing Client relationship. The Client will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures). Retirement Accounts- When the Advisor provides investment advice to Clients regarding ERISA retirement accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which

are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by the Advisor. Financial Planning Services Navis Wealth Advisors typically provides financial planning services. Services are offered in several areas of a Client’s financial situation, depending on their goals and objectives. Generally, such financial planning services involve preparing a formal financial plan or rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs and other areas of a Client’s financial situation. A financial plan developed for, or financial consultation rendered to the Client will usually include general recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations may be made that the Client start or revise their investment programs, commence or alter retirement savings, establish education savings and/or charitable giving programs. Navis Wealth Advisors may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation. For financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written summary. For standalone financial planning services, the plans or consultations are typically completed within six (6) months of contract date, assuming all information and documents requested are provided promptly. Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for investment management services or to increase the level of investment assets with the Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the Advisor. Retirement Plan Advisory Services Navis Wealth Advisors provides retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the Plan and Plan Sponsor. Services generally include: ● Plan Participant Enrollment and Education Tracking ● Investment Policy Statement (“IPS”) Design and Monitoring ● Investment Oversight Services (ERISA 3(21)) ● Ongoing Investment Recommendation and Assistance ● ERISA 404(c) Assistance ● Benchmarking Services These services are provided by Navis Wealth Advisors serving in the capacity as a fiduciary under the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is provided with a written description of Navis Wealth Advisors’ fiduciary status, the specific services to be rendered and all direct and indirect compensation the Advisor reasonably expects under the engagement. C. Client Account Management Prior to engaging Navis Wealth Advisors to provide advisory services, each Client is required to enter into one or more agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the Client. These services may include: ● Establishing an Investment Strategy – Navis Wealth Advisors, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. ● Asset Allocation – Navis Wealth Advisors will develop a strategic asset allocation that is targeted to meet the investment objectives, time horizon, financial situation and tolerance for risk for each Client. ● Portfolio Construction – Navis Wealth Advisors will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. ● Investment Management and Supervision – Navis Wealth Advisors will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs Navis Wealth Advisors does not manage or place Client assets into a wrap fee program. However, certain Independent Managers may offer their services in a wrap fee program, whereby investment advisory fees are bundled together with securities transaction fees. In such instances, the Advisor will provide the Client with the Independent Managers’ wrap fee program brochure or similar disclosure document. E. Assets Under Management As of December 31, 2023, Navis Wealth Advisors manages $409,700,513 in Client assets, all of which are managed on a discretionary basis. Clients may request more current information at any time by contacting the Advisor.