Evolution Wealth Advisors, LLC, also known as EWA, is a limited liability company organized under the laws of the State of Florida since July 28, 2016. EWA is principally owned by Roberto Vainrub through the Roberto Vainrub Revocable Trust, Alan Rotter through the Alan Rotter Revocable Trust, Marcel Apeloig through the MAHR Trust, Antonino Ciulla, Michael Marciano, and Alfonso Angrisano. We have been registered as an investment adviser with the SEC since September 8, 2017, and notice filed in applicable States in order to provide the investment advisory services as described within this document. As of December 31, 2023, our assets under management totaled: Discretionary Managed Accounts $ 952,233,832 Non-Discretionary Managed Accounts $0 Assets Under Advisement1 $1,583,242,994 Total $2,535,476,826 This Disclosure Brochure provides you with information regarding our qualifications, business practices, and the nature of advisory services that should be considered before becoming our advisory client. Please contact Luciana Roditi, Chief Compliance Officer, if you have any questions about this Brochure. Individuals associated with EWA will provide investment advisory services on our behalf. Such individuals are known as Investment Advisor Representatives (“IARs”). We require IARs engaged in determining or offering investment advice to clients to be properly licensed and registered in the states, unless exempted, in which they provide investment advisory services. Below is a description of the investment advisory services we offer. For more detail on any product or service please reference your Investment Advisory Agreement (“IAA”) or contact your IAR. Your IAR will recommend various types of portfolio management services to help meet your investment goals. Portfolio Management Services We provide discretionary advisory and non-discretionary services through separately managed accounts based by your stated investment objectives and restrictions. When 1 Assets under advisement represent assets in which we provide consulting and/or consolidation services and for which we have neither discretionary authority nor responsibility for arranging or effecting the purchase or sale of recommendations provided to and accepted by the ultimate client. Inclusion of these assets will make our total assets number different from assets under management disclosed in Item 5.F of our Form ADV Part 1A due to specific calculation instructions for Regulatory Assets Under Management. you invest through a Separately Managed Account (“SMA”), you own individual securities. Although IARs will oversee many separately managed accounts and some accounts may be managed with other accounts to a specific strategy, your account is separate and distinct from all others. We have developed several model portfolios primarily utilizing Exchange Traded Funds (“ETFs”), Mutual Funds, Bonds, and Equities. In addition, we may invest in or recommend any other type of security, including but not limited to, exchange-listed securities, securities traded over-the-counter, foreign issuers, warrants, corporate debt securities (other than commercial paper), commercial paper, cryptocurrencies, certificates of deposit, municipal securities, mutual fund shares, United States governmental securities, options contracts on securities, futures contracts on tangibles, futures contracts on intangibles, asset backed securities, mortgage backed securities, non-US sovereign debt, structured notes and other alternative investments. The models range in risk tolerance from conservative to Growth Plus in Balanced Accounts and Investment Grade to High Yield in Fixed Income Accounts. Generally, in the balanced accounts, the more aggressive models have higher allocation to equity ETFs or funds, as opposed to fixed income ETFs and funds, than the more conservative models. There are different types of portfolios that we offer and that we will allocate your assets to, based on your investment objectives and risk tolerance. We regularly monitor the performance of each security selected for each model. Further, we rebalance the portfolios at least once annually. In addition to our own research, we utilize third-party research services to assist us with formulating asset allocation, industry and sector selection, and individual investment recommendations in constructing and maintaining our portfolios. Our discretionary services encompass investment supervisory and management services defined as providing continuous investment advice based on the client’s risk profile and individual needs. Non-discretionary services would authorize us to provide investment recommendations but require your approval to proceed. You make the ultimate decision regarding the purchase or sale of investment. During initial consultation(s), your IAR will have a comprehensive discussion about your financial condition, priorities, and concerns. Based upon these conversations, we will then work to create either a formal investment policy statement or informal agreed upon investment objectives to serve as the primary point of reference and ensure that your objectives are clearly defined. We review your financial situation and needs with you on an ongoing basis, to accommodate changes to your long‐term goals and objectives. One of our IARs, in consultation with you, will decide either to use the model portfolios, to use them for only a portion of your assets, or not to use them. These IARs will also tailor their recommendations and investments based on your investment objectives and risk tolerance through individual stocks, bonds, government’s, options, municipals, variable or fixed insurance products, funds, alternative investments, or other individual securities. You have the option of imposing reasonable investment restrictions on certain securities, industries, sectors, or asset classes by providing us with written instructions when you open your advisory account, or at any time thereafter. Please note, such restrictions may affect the composition and performance of your portfolio. For these reasons, the performance of the portfolio may not be identical with our average client. We offer these services through wrap fee accounts and non-wrap fee accounts. The wrap fee program is administered by our custodian Charles Schwab & Co., Inc. (“Schwab”),

StoneX Financial, Inc., (“StoneX”) and IBKR Securities Services, LLC (“IBKR”). We do not offer non-wrap fee accounts at Schwab. EWA also offers investments in Private Funds (including private equity, private debt, co- investment and/or hedge funds). Such investments are made only for clients who are qualified clients. “Qualified client” means: (i) A natural person who, or a company that, immediately after entering into the contract has at least $1,100,000 under the management of the investment adviser, (ii) A natural person who, or a company that, the investment adviser reasonably believes, immediately prior to entering into the contract, either has a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more than $2,200,000 (excluding the primary residence); or is a “qualified purchaser” as defined in the Investment Company Act of 1940 at the time the contract is entered into [the term “Qualified Purchaser” includes a trust with assets in excess of $5 million, not formed to acquire the securities offered, and whose purchase is directed by a sophisticated person], or (iii) A natural person who immediately prior to entering into the contract is (a) An executive officer, director, trustee, general partner, or person serving in a similar capacity, of the investment adviser; or (b) An employee of the investment adviser (other than an employee performing solely clerical, secretarial or administrative functions with regard to the investment adviser) who, in connection with his or her regular functions or duties, participates in the investment activities of such investment adviser, provided that such employee has been performing such functions and duties for or on behalf of the investment adviser, or substantially similar functions or duties for or on behalf of another company for at least 12 months. Prospective investors in Private Funds should be aware that the funds are unregistered investment vehicles. Additional risks, restrictions on withdrawals and redemptions, and other important information associated with the pooled unregistered investment vehicles are outlined in each Private Fund’s offering documents. Prospective investors should review these documents carefully for information regarding these and other important additional considerations and risks. Non-Discretionary Consulting Services EWA has entered into consulting arrangements with clients to provide periodic communications with opinions on investment matters including strategy, portfolio structure, asset allocation and/or risk analysis (including recommendations on individual securities). These services are offered on a non-discretionary basis where the client, at its discretion, may implement any of the recommendations by instructing us or their custodian directly. Recommendations may be based on an individual client’s specific investment objectives, needs and financial plan, but typically, are more generally based on macro market assumptions and indicators. The specificity of the recommendations will be based on each client’s preferred relationship with us. Therefore, certain recommendations will not be tailored to an individual client’s needs, but to the market in general. Given the nature of these relationships and the advice provided, we do not typically accept restrictions on accounts. Consolidation Services We can provide consolidation services to our clients. This service entails aggregating the client’s accounts that we supervise with their other accounts, assets, or alternative investments that we do not supervise. This service provides a global view of the client’s assets in order to make informed recommendations and decisions. An initial assessment of which assets will be aggregated will allow EWA to determine if there is an additional cost for this service. We may also offer this service as an independent service or as part of a consulting arrangement. IRA Rollover Recommendations In complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020- 02"), when applicable, we are providing the following acknowledgment to clients. When we provide investment advice to clients regarding their retirement plan account or individual retirement account, we are a fiduciary 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 conflicts with client interests. We operate under an exemption that requires we act in the clients’ best interest and not put our or our employees’ interests ahead of the clients’ interests. Under this exemption, we must:
• meet a professional standard of care when making investment recommendations (give prudent advice),
• never put our or our employees’ financial interests ahead of the clients when making recommendations (give loyal advice),
• avoid making misleading statements about conflicts of interest, fees, and investments,
• follow policies and procedures designed to ensure that we and our employees give advice that is in the clients’ best interests,
• charge no more than is reasonable for services, and
• give the clients basic information about conflicts of interest. We benefit financially from the rollover of the clients’ assets from a retirement account to an account that we manage or provide investment advice, because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we and our employees believe it is in the client’s best interest. Wrap Fee Program We provide management services under a “wrap fee” structure, but we do not perform portfolio management services as part of other sponsors’ wrap fee programs. EWA manages accounts similarly whether structured as a wrap account or not. Clients participating in a wrap fee arrangement pay a single fee for advisory, brokerage and custodial services. Clients’ portfolio transactions will be executed without commissions in a wrap fee arrangement. For further details regarding our wrap fee program, please refer to the Evolution Wealth Advisors Wrap Brochure.