Page 5 of 28 Disclosure Brochure Assets Under Management We offer two (2) types of investment management: Portfolio Management and Portfolio Monitoring. All Portfolio Management accounts are managed on a discretionary basis – we do not manage accounts on a non- discretionary basis. Portfolio Monitoring accounts are managed by independent third-party money managers (“Independent Portfolio Managers”) and we will evaluate their performance and suggest changes if they are not effectively meeting your investment needs. As of December 31, 2023, our assets under management totaled: Discretionary Managed Accounts $404,667,532 Non-Discretionary Accounts $403,803,300 What We Do We provide financial solutions that stress the importance of you making fiscally responsible decisions and disciplined economic choices. We help you manage the complexities that wealth creates using estate planning, risk management, investment, and tax planning strategies, and philanthropic giving, to try to preserve assets for today’s needs, tomorrow’s dreams, and a strategy focused on building a lasting legacy for future generations. The focus of all our investment advice begins with a plan to identify your standards of living and quality of life expectations. We will accomplish this through an initial discovery meeting where we will review the financial documents you provide for discussion. Together questions will be asked, information shared, and an evaluation made as to whether we should move to the next step. During the meeting, we will:
• Learn about your core values and guiding principles.
• Seek to understand your financial concerns and how you have been addressing them.
• Discover your financial objectives and what success looks like for you.
• Create an internal profile consisting of your concerns, objectives, relationships, values, interests, assets, professional advisors and process preferences. After the discovery meeting, should you choose to engage us for our wealth management services, we will begin the process of identifying your life goals (i.e., core values, family, monetary needs, future plans, etc.). The best advice we can offer is that success, achievement, and contentment in life have little to do with personal wealth but are instead related to your life goals. We will make every effort to embrace these life goals and develop economical solutions that reflect how you define true wealth. Andina Capital Management, LLC’s comprehensive planning services include:
• Estate, Financial and Tax Planning
• Business Succession Planning
• Employer Retirement Plans
• Investment Management Page 6 of 28 Disclosure Brochure Comprehensive Planning Planning is one of the most important tools successful people use to bridge unexpected events, to create an extraordinary personal life, business career and the security needed in retirement years. However, such planning requires a lifetime commitment, not only from you but from us as well, your financial planner. Being Fiscally Responsible Planning for your future, whether estate, financial, and/or tax planning, is being fiscally responsible. A well- designed plan is a step-by-step process intended to identify and clarify purpose, personal and family core values, needs, and priorities to align your financial decisions with your goals in all areas of your life and business. Planning includes: 1. Arriving at a series of decisions and action items based on current and future financial circumstances and defined goals and objectives. 2. Projecting the consequences of these decisions for you in the form of an economic plan – a working blueprint; and, 3. Implementing the protocols outlined in the plan geared to achieving the plan objectives. Once complete, the plan, or working blueprint, becomes the benchmark that is used to help us evaluate where you are in terms of your financial goals, needs, and objectives. Estate, Financial & Tax Planning Components All forms of planning are a mutually defined review, analysis and evaluation of your personal financial needs and goals. In general, planning may encompass one or more of the following areas of financial need as communicated by you: Identification and clarification of personal and family core values, mission, vision, and goals. Preparation of the financial plan, which encompasses your:
• Current financial situation.
• Liquidity and asset preservation needs.
• Wealth accumulation and growth.
• Wealth distribution and transfer. Planning may also include, but is not limited to, the following modules:
• Financial Statements – Cash Flow and Balance Sheet
• Savings and Emergency Reserves
• Asset Allocation and Investment Portfolio Analysis
• Income Tax planning in collaboration with your tax advisor
• Asset protection and Risk Management
• Insurance Analysis
• Retirement and Income Analysis
• Long-Term Healthcare
• Philanthropic Planning
• Estate and Family Legacy Planning
• Business Management and Succession Planning Deliverables can include:
• Outlining recommendations, strategies, solutions, and resources.
• Prioritizing and implementing the written action plan.
• Creation and implementation of a customized investment strategy tailored to your long-term investment goals through investment consultations. This will include:
• A written Investment Policy Statement (“IPS”)
• Access to our open-architecture platform with a variety of investment management solutions.
• Facilitation of meetings with you and you current advisors and specialists within our professional network
• Coordination and facilitation of meetings with family members, business associates, partners or other key individuals to assist with implementing your action plan. Page 7 of 28 Disclosure Brochure Estate, Financial & Tax Plan Process In the development of your unique plan, we will follow the six (6) step Financial Planning Practice Standards process established by the Certified Financial Planner Board of Standards, Inc. These steps are defined as follows: Step 1: Establish and define the client-planner relationship. The first step is to conduct an introductory discovery meeting. During this meeting, we will learn about each other and whether we can work together to achieve your financial objectives. We will listen as you share your needs, concerns, priorities, and what success looks like for you. We will in-turn, share how we can help you meet your stated personal and financial objectives, and the responsibilities we have as a fiduciary to guide you on this journey. In the end, we will explain the cost of completing the desired financial planning service for you to decide whether you want to move forward with the next step in the planning process. Step 2: Gather client data identifying both financial and personal goals and objectives. In the second step of the planning process, we will learn more about you and what you want to achieve. This is accomplished through personal interviews and questionnaires4, which are designed to address your unique financial planning needs. You will have the opportunity to prioritize objectives and to remove from the process any areas that do not apply to your circumstances. The time we invest listening and catering to your wants and needs is critical for developing a strong financial planning foundation. Step 3: Analyze and evaluate client financial status. In this third step, we analyze the information you provide to determine your current financial situation and what you should do to meet your goals. Depending on the services you request, this might include analyzing: (i) your assets, liabilities and cash flow; (ii) your current insurance coverage and investments; and (iii) your tax strategies and estate planning documents. Step 4: Develop and present financial planning recommendations and/or alternatives. Once the analysis has been completed, we will begin formal documentation of your goals and objectives. We will define the plan as a road map (a series of blueprints) designed to take you from where you currently are financially, to where you want to be at some point in the future. This is the creative portion of the process. There are usually several ways to accomplish a given goal. The objective, however, is to integrate financial instruments into a plan that you will be comfortable executing. In some cases, the drafting of the plan reveals the need for us to help you reconcile the gap between your expectations and your financial realities. Once a viable plan has been drafted, it is presented to you and reviewed. The draft and review process may be repeated until you are satisfied with the financial plan. Step 4 completes the planning process. There will be additional costs for you to implement and monitor your plan as outlined under steps 5 and 6. You have the choice to allow us to implement your financial, tax & estate plan or you can use another outside professional. Step 5: Implement the planning recommendations. An estate, financial and/or tax plan is of limited value if it is not put into action. Accordingly, we assist you in implementing5 the plan. The action plan schedule provides you with a list of tasks and deadlines designed to ensure that you put your plan into action. The following are some examples of implementation: Drafting of appropriate estate documents (performed in conjunction with an estate attorney). Purchasing of various insurance policies (provided by our licensed insurance agents or another 4 The information we gather from you through personal interviews and questionnaires is vital for us to effectively advise you on your unique financial needs and help you plan for your future. Electing to dismiss certain requested documents or respond to questions with limited input can put us at a disadvantage and handicap our ability to successfully meet your financial expectations. Therefore, if you want the best advice we can offer in designing a financial plan or with any portfolio management, you should make every effort to provide us with detailed personal information and be as accurate with your responses as you possibly can. 5 Implementing the recommendations made in an estate, financial and/or tax plan often requires consultation or coordination with one or more outside professionals (e.g. attorneys, CPAs, insurance agents, and securities representatives). All personal and private information received from you will be kept entirely confidential, not only by us, but by the outside professionals as well. Your confidential information will be disclosed to third parties only with your consent or as may be permitted or required by law. Page 8 of 28

Disclosure Brochure independent agent of your choice). Providing Investment advisory services that will include preparation of an IPS and implementation of your asset allocation strategy (performed by us, or another investment adviser/broker-dealer of your choice). Adopting and monitoring a personal budget. Ongoing income tax planning (prepared by an independent Certified Public Accountant or tax accountant of your choice). Step 6: Monitor the planning recommendations. Once the plan has been built and the recommendations have been implemented it is critical that these recommendations be monitored on a continuing basis to ensure that they remain consistent with your financial parameters. Material changes in your personal circumstances, the general economy, changes in the way you want your investments allocated, or tax law changes are some of the reasons why the recommendations should be reviewed periodically and possibly adjusted. Continued monitoring of established personal budgets and the continued effects of taxation on the plan are assessed regularly at your option per an Annual Review. For information on our fees for preparing a financial plan, see “Estate, Financial & Tax Planning Fee” under Item 5 - “Fees & Compensation.” Business Succession Planning You have diligently and tirelessly grown your business, achieved great success while helping customers, employees, vendors, and others to be successful. Addressing the sale or transfer of your business should start several years before you intend to carry out the transaction. Proper planning allows you to explore the multiple options that are available and prepare your business to provide the ultimate payout. ACM can help obtain a formal business valuation and develop a business pitch-deck; these will provide you with valuable information regarding your business and will assist a potential buyer to understand your business. We guide you in building the necessary team to assist in the process; CPAs, attorneys with mergers and acquisition experience and investment bankers or business brokers. Proper planning and knowledge will help you negotiate the best terms of the sale of your business. It is not just about getting the highest sale price; many factors must be considered to optimize this transaction for you. Employer Retirement Plans ACM provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. Investment Management Services Moving forward from the financial planning sessions, if you engage us for investment management services, we will design a portfolio allocation strategy, that will include preparation of an IPS, and will be based on your unique investment parameters and risk tolerance levels. Page 9 of 28 Disclosure Brochure Portfolio Management Our portfolio management strategies focus on designing an overall portfolio to achieve your investment goals6. Depending on your eligibility and needs, we offer a diversified allocation, including but not limited to, Equities (for example, ETFs/ETNs and stocks), Fixed Income, Structured Notes, Investment Company products (“mutual funds”), Independent Portfolio Managers (see “Portfolio Monitoring” below) and Andina Branded or Affiliated Funds (including Private Real Estate, Private Equity and Private Credit). ACM manages Andina Branded Funds and has an active role in the investment committees of the Affiliated Funds. Our responsibility to you in recommending Andina Branded Funds or Affiliated Funds will be to: Recommend only investment strategies that fit your management criteria and risk tolerance level while ensuring you meet the minimum requirements of the investment. Suggest changes, if necessary, as market factors and your personal goals dictate. Handle all administrative and clerical duties as may be required by the Andina Branded and Affiliated Funds to service your account, though they will provide you updated information, statements and other correspondence directly. Portfolio Monitoring Any Independent Portfolio Managers we may recommend to manage a portion of your portfolio will implement an investment strategy that correlates best with your investment parameters. Under the arrangements with Independent Portfolio Managers, we are not involved in the day-to-day management of your portfolio assets. Our responsibility to both you and the Independent Portfolio Manager we direct to manage your account will be to: Recommend only Independent Portfolio Managers whose investment strategies fit your management criteria and risk tolerance level while ensuring you meet the minimum requirements of the Independent Portfolio Manager to open an account. Evaluate the Independent Portfolio Manager’s investment returns and performance expectations. Suggest changes in an Independent Portfolio Manager, if necessary, as market factors and your personal goals dictate. Handle all administrative and clerical duties as required by the Independent Portfolio Manager to service your account since they will have little or no direct contact with you. Additional information about the Investment Management Fees can be found under “Investment Management Services Fees” in Item 5 - “Fees & Compensation”. How we evaluate Independent Portfolio Managers is discussed in “Analysis of Independent Portfolio Managers” under Item 8 - “Methods of Analysis, Investment Strategies & Risk of Loss”. Private Funds, including conflicts of interest and strategy descriptions are discussed in under Item 10 – “Other Financial Industry Activities & Affiliations” and “Pooled Investment Vehicle Compensation” under Item 14 – “Client Referrals & Other Compensation” Consolidated Reporting Consolidated Reporting is a delivery system whereby statements and other data from multiple sources (i.e., brokerage, IRA, variable annuity accounts, managed accounts, etc.) are collected and consolidated into a single quarterly report for your review and consideration. You would be responsible for supplying direct access to all valuation statements or providing the values for the accounts on a monthly basis. 6 You may, at any time, impose restrictions in writing on the securities we may recommend (i.e., limit the types/amounts of a particular security purchased for your account, etc.). Page 10 of 28 Disclosure Brochure FEES & COMPENSATION Comprehensive Planning Fee Discovery Meeting Before our discovery meeting, we will request you bring financial documents for us to review and discuss. The objectives we strive to accomplish with you during this meeting are to: Diagnose your current financial need. Address your financial concerns and answer your questions on how we can assist you. Recommend financial resolutions aimed at lowering costs, reducing risks, increasing expected returns, and/or increasing tax efficiency to improve the likelihood of successfully achieving your goal; and, Explain the benefits of financial planning and how a comprehensive evaluation of wealth management needs is beneficial beyond just managing your investable assets. We do not charge a fee for the initial discovery meeting; we believe our years of experience and knowledge sells itself. If, however, you wish no further interaction with us, you will be responsible for implementing any recommendations coming out of the discovery meeting. Once this meeting is over, our financial collaboration will be concluded, and we are not responsible for implementing any further advice or for any on-going supervision, monitoring, and/or reporting. Comprehensive Planning We have two payment options for our Comprehensive Planning: 1. A negotiated flat fee, from $500 to $200,0007, paid annually or quarterly. OR 2. An ongoing, negotiated fee, at a maximum of 0.50% annually (charged quarterly, in advance) on all assets under management, including those that fall under Portfolio Management and Portfolio Monitoring, Andina Branded Funds and Andina Affiliated Funds (see “Investment Management Services” under Item 4 – “Advisory Business”). This option is only available if the minimum account of $250,000 is opened, unless otherwise negotiated. The fee will be fully disclosed in the agreement at the time of signing. This fee will include the cost to review your financial information and prepare a comprehensive financial plan. Modular Plans If you desire only modular planning - just one or a few of the items listed under “Estate, Financial & Tax Planning Components” the minimum fee will be $1,000. All additional fees will be predetermined in consultation with you and presented in a written proposal or engagement letter, with a completely itemized list of the core area(s) of focus. Annual Reviews It is important to note that planning is dynamic – never static. Therefore, it must be periodically re- evaluated. A financial plan is a roadmap that is only as good as how well it reflects your current financial position to then guide you on a clear path to a future financial situation. Whether you are a planning client and/or Investment Management client, annual reviews are designed to systematically identify and address any changing circumstances in your life. Once the initial comprehensive financial planning services have been completed, we will establish future “Annual Review” dates for your future reviews. The Annual Reviews generally occur after the first anniversary though they may consist of two or three visits during the calendar year. 7 Rarely will a fee exceed those costs outlined in the Agreement. However, there can be instances where we did not contract with you to perform a particular task and therefore, we will notify you of the additional cost prior to beginning such services.