A. Firm Information Cordoba Advisory Partners LLC (“CAP” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor was organized as a Limited Liability Company “(LLC”) under the laws of the State of Delaware in September 2020 and became a registered investment advisor in July 2021. CAP is a wholly-owned subsidiary of Cordoba International Holdings, LLC, which is a wholly-owned subsidiary of Qaus Investments LLC. The Principal Officer of CAP is Rami R. Sarafa (Chief Executive Officer and Portfolio Manager). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by CAP. B. Advisory Services Offered CAP offers investment advisory services to high net worth individuals, families, trusts, estates, businesses and private funds (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 and disclose any potential conflicts of interest. CAP's 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. Investment Management Services CAP provides customized investment advisory solutions for its Clients. This is achieved through continuous spersonal Client contact and interaction while primarily providing discretionary investment management and related advisory services. CAP 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. CAP then constructs an investment portfolio, consisting of individual stocks, individual bonds, mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor may also utilize options contracts, private funds/limited partnerships, and/or other investment managers to meet the objectives of its Clients. The Advisor may retain certain types of legacy investments for a Client based on their overall fit within a portfolio strategy and/or tax and fiduciary considerations. CAP’s 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. CAP constructs, implements, and monitors the portfolio to meet the goals, objectives, circumstances, and risk tolerance agreed to by each 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. CAP evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. CAP may recommend, on occasion, redistributing investment allocations to diversify the portfolio. CAP may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movements. CAP 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 CAP accept or maintain custody of a Client’s funds or securities, except as described herein. All Client assets will be managed within their designated account(s) at the Custodian, pursuant to the Client investment advisory agreement. Please see Item 12. Page 5 Private Investment Vehicles. CAP will, as appropriate, recommend that eligible Clients invest in one or more pooled investment vehicles (which could include special purpose vehicles) whose securities are offered on a private placement basis (“private funds”), including private funds that are sponsored by one or more of CAP’s affiliates. There are numerous risks inherent in investing in private funds, and it is imperative for all prospective investors to read and understand any offering documents (including any private placement memorandum, partnership or operating agreement, and/or subscription documents) relating to such private fund which describe, among other things, the investment program, fees, risk factors, and conflicts of interest associated with an investment in such private fund. With respect to private funds sponsored by CAP’s affiliates, depending on the specific private fund, CAP and/or its affiliates can earn fees (including management fees and/or performance fees) for providing services to such private fund. Although CAP may waive its investment management fee when recommending that a Client invest assets in a proprietary private fund, a conflict of interest nonetheless exists when CAP recommends an investment in a private fund sponsored by any of its affiliates to its Clients because CAP or such affiliates may have the opportunity to earn more compensation as a result of such a recommendation than CAP would otherwise earn by recommending that the Client invest assets in another investment. Use of Independent Managers CAP may recommend that a Client utilize one or more unaffiliated investment managers or investment

platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager(s) that defines the terms in which the Independent Manager(s) will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager(s) to ensure the Independent Managers’ strategies and target allocations remain aligned with its Clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager(s) or investment platform(s), will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). At no time will CAP accept or maintain physical custody of a Client’s funds or securities and will have only deemed custody 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 advisory agreement. Please see Item 12 – Brokerage Practices. Advising private funds CAP provides advisory or sub-advisory services to private funds sponsored by both its affiliates and unaffiliated third parties. CAP receives compensation for services rendered to such private funds as described in the offering documents for such Private funds. A conflict of interest exists when CAP recommends any such private funds to its clients because of the compensation that CAP can earn as a result of advisory services rendered to such private funds. Financial Planning Services CAP will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written financial planning agreement. 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, 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, Page 6 recommendations may be made that the Client start or revise their investment program, commence, or alter retirement savings, establish education savings and/or charitable giving programs. CAP may also refer Clients to an accountant, attorney, or other specialists, as appropriate for their unique situation. For certain 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. 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. C. Client Account Management Prior to engaging CAP to provide investment 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 – CAP, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.
• Asset Allocation – CAP 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 – CAP will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.
• Investment Management and Supervision – CAP will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs CAP does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by CAP. E. Assets Under Management As of March 28, 2024, CAP oversees approximately $1,515,091,768 in assets of which approximately $984,162,098 is managed on a discretionary basis, approximately $189,750,936 is managed on a non- discretionary basis, and approximately $341,178,734 are assets under advisement. Clients may request more current information at any time by contacting the Advisor.
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