Cohen Investment Advisors offers a variety of advisory services, which include financial planning, consulting, and investment management services. Prior to the rendering of any of the foregoing advisory services, clients are required to enter into one or more written agreements with Cohen Investment Advisors setting forth the relevant terms and conditions of the advisory relationship (the “Agreement”). Cohen Investment Advisors provides its services in an effort to improve clients’ overall financial wellbeing. To that end, the Firm will analyze client information to assess their current situation, define their goals and determine what should be done in order to meet those goals. Depending on what services the Firm is engaged to provide, this could entail analyzing client assets, liabilities and cash flow, current insurance coverage, investments, tax strategies and other less tangible concerns. The Firm believes an approach that carefully monitors client portfolios is integral in achieving client objectives. Cohen Investment Advisors has been a registered investment adviser since October 2013 and is wholly owned by Daniel M. Cohen, Chief Executive Officer, Chief Investment Officer and Chief Compliance Officer. While this brochure generally describes the business of Cohen Investment Advisors, certain sections also discuss the activities of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying a similar status or performing similar functions), employees or any other person who provides investment advice on Cohen Investment Advisors’ behalf and is subject to the Firm’s supervision or control. Financial Planning and Consulting Services Financial Planning and Consulting Services may be offered as a component of the overall investment advisory services, which may include any or all of the following functions:
• Tax and Cash Flow Forecasting
• Investment Management and Consulting
• Retirement Planning
• Estate Planning
• Financial Reporting
• Investment Consulting
• Insurance Needs Analysis
• Retirement Plan Analysis Cohen Investment Advisors does not charge a separate fee for financial planning services. Cohen Investment Advisors may recommend the services of itself, its Supervised Persons in their individual capacities as insurance agents, and/or other professionals to implement its recommendations. Clients are advised that a conflict of interest exists if clients engage Cohen Investment Advisors to provide additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation and are under no obligation to act upon any of the recommendations made by Cohen Investment Advisors under a financial planning or consulting engagement or to engage the services of any such recommended professionals, including Cohen Investment Advisors itself. Clients are advised that it remains their responsibility to promptly notify the Firm of any change in their financial situation or investment objectives for the purpose of reviewing, evaluating, or revising Cohen Investment Advisors’ previous recommendations and/or services. Investment Management and Wealth Management Services Cohen Investment Advisors primarily manages client investment portfolios on a discretionary basis; however, the Firm does have some non-discretionary accounts. Cohen Investment Advisors may also provide clients with wealth management services that, in addition to managing investment portfolios, includes a broad range of comprehensive financial planning and consulting services. Cohen Investment Advisors allocates client assets among various models it produces based on proprietary research which focuses primarily on individual debt and equity securities, mutual funds, exchange-traded funds (“ETFs”) and only occasionally will assets be allocated to independent investment managers (“Independent Managers”); the Firm may also be called upon to advise on the securities components of variable annuities and variable life insurance contracts, all in accordance with the investment objectives of its individual clients. In addition, Cohen Investment Advisors may also recommend that clients who qualify as accredited investors, as defined by Rule 501 of the Securities Act of 1933, invest in privately placed securities, which may include debt, equity and/or interests in pooled investment vehicles (e.g., hedge funds). Where appropriate, the Firm may also provide advice about any type of legacy position or other investment held in client portfolios. Clients may also engage Cohen Investment Advisors to advise on certain investment products that are not maintained at their primary custodian, such as variable life insurance and annuity contracts and assets held in employer sponsored retirement plans and qualified tuition plans (i.e., 529 plans). In these situations, Cohen Investment Advisors directs or recommends the allocation of client assets among the various investment options available with the product. These assets are generally maintained at the underwriting insurance company, or the custodian designated by the product’s provider. Cohen Investment Advisors tailors its advisory services to meet the needs of its individual clients and continuously seeks to ensure that client portfolios are managed in a manner consistent with their specific investment profiles. Cohen Investment Advisors consults with clients on an

initial and ongoing basis to determine their specific risk tolerance, time horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios. Clients are advised to promptly notify Cohen Investment Advisors if there are changes in their financial situation or if they wish to place any limitations on the management of their portfolios. Clients may impose reasonable restrictions or mandates on the management of their accounts if Cohen Investment Advisors determines, in its sole discretion, the conditions would not materially impact the performance of a management strategy or prove overly burdensome to the Firm’s management efforts. Private Fund Cohen Real Estate Advisors, LLC is the General Partner to The Cohen Real Estate Fund 2017 and The Cohen Real Estate Fund II, LLLP (the Funds); private real estate funds in which certain clients invest. Daniel M. Cohen is the Manager of the General Partners. Additional information, including fees and specific procedures and restrictions for withdrawals from, and terminations of a position in the Funds are described in the Funds’ Private Placement Memorandums. Use of Independent Managers As mentioned above, Cohen Investment Advisors may select or recommend certain Independent Managers to actively manage a portion of its clients’ assets. The specific terms and conditions under which a client engages an Independent Manager are set forth in a separate written agreement between the designated Independent Manager and either Cohen Investment Advisors or the client. In addition to this brochure, clients may also receive the written disclosure documents of the designated Independent Managers engaged to manage their assets. Cohen Investment Advisors does not receive compensation from any such Independent Managers. Cohen Investment Advisors evaluates various information about the Independent Managers it chooses to manage client portfolios, which may include the Independent Managers’ public disclosure documents, materials supplied by the Independent Managers themselves and other third-party analyses it believes are reputable. To the extent possible, the Firm seeks to assess the Independent Managers’ investment strategies, past performance, and risk results in relation to its clients’ individual portfolio allocations and risk exposure. Cohen Investment Advisors also takes into consideration each Independent Manager’s management style, returns, reputation, financial strength, reporting, pricing, and research capabilities, among other factors. Cohen Investment Advisors continues to provide services relative to the discretionary selection of the Independent Managers. On an ongoing basis, the Firm monitors the performance of those accounts being managed by Independent Managers. Cohen Investment Advisors seeks to ensure the Independent Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall best interests. Fiduciary Statement We are fiduciaries under the Investment Advisers Act of 1940 and when we provide investment advice to you regarding your retirement plan account or individual retirement account, we are also fiduciaries 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. We have to act in your best interest and not put our interest ahead of yours. At the same time, the way we make money creates some conflicts with your interests. We must take into consideration each client’s objectives and act in the best interests of the client. We are prohibited from engaging in any activity that is in conflict with the interests of the client. We have the following responsibilities when working with a client:
• To render impartial advice;
• To make appropriate recommendations based on the client’s needs, financial circumstances, and investment objectives;
• To exercise a high degree of care and diligence to ensure that information is presented in an accurate manner and not in a way to mislead;
• To have a reasonable basis, information, and understanding of the facts in order to provide appropriate recommendations and representations;
• Disclose any material conflict of interest in writing; and
• Treat clients fairly and equitably. Regulations prohibit us from:
• Employing any device, scheme, or artifice to defraud a client;
• Making any untrue statement of a material fact to a client or omitting to state a material fact when communicating with a client;
• Engaging in any act, practice, or course of business which operates or would operate as fraud or deceit upon a client; or
• Engaging in any manipulative act or practice with a client. We will act with competence, dignity, integrity, and in an ethical manner, when working with clients. We will use reasonable care and exercise independent professional judgement when conducting investment analysis, making investment recommendations, trading, promoting our services, and engaging in other professional activities. Wrap Fee Programs Cohen Investment Advisors does not participate in a Wrap Fee Program. Client Assets As of January 24, 2024, the Firm has $187,312,716 in assets under management, managed solely on a discretionary basis.