A. Firm Information Octavia Wealth Advisors, LLC (“Octavia” or the “Advisor”) is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”), which is organized as a Limited Liability Company (LLC) under the laws of Delaware. Octavia was founded in January 2020 and is a wholly owned subsidiary of Octavia Financial Holdings, LLC. Octavia is operated by Maxim Meyers (Chief Executive Officer and Chief Compliance Officer), Luis Strohmeier, Donald Hughett, Marc Wagner (Chief Financial Officer), Mark Bodnar (Chief Investment Officer), Michael Ingram, Justin Setzekorn, and Andrew Seni. This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by Octavia.
B. Advisory Services Offered Octavia offers investment advisory services to individuals, high net worth individuals, trusts, estates, businesses, institutions and retirement plans (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. Octavia’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 Octavia provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while providing discretionary investment management and related advisory services. Octavia works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to determine a portfolio strategy. For Clients with more than $1,000,000 in assets under management, financial planning services will be included in the scope of investment management services.
Internal Investment Management—Octavia will place Client assets into proprietary models which consist primarily of low-cost, diversified exchange-traded funds (“ETFs”), mutual funds, and individual stocks and bonds to achieve the Client’s investment goals. The Advisor may also utilize alternative investments, structured products, real estate investment trusts, oil and gas interests to meet the needs of its Clients, or retain certain legacy investments based on portfolio fit and/or tax considerations.
Octavia’s investment approach is 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. Octavia 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.
octaviawa.com | 5 9999 Carver Road, Suite 130, Cincinnati, OH 45242, T: 513.762.7701, F: 513.762.7741 Octavia evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. Octavia may recommend, on occasion, redistributing investment allocations to diversify the portfolio. Octavia 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. Octavia 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 Octavia 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 advisory agreement. Please see Item 12 – Brokerage Practices.
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.
Use of Independent Managers—When deemed to be in the Client’s best interest, Octavia will recommend that Clients utilize one or more unaffiliated investment managers (herein “Independent Managers”) for all or a portion of a Client’s investment portfolio, based on the Client’s needs and objectives. In such instances, the Client may be required to authorize and enter into an investment management agreement with the Independent Manager[s] that defines the terms in which the Independent Manager[s] will provide its services. 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, prior to entering into an agreement with an Independent Manager, will be provided with the Independent Manager’s Form ADV Part 2A - Disclosure Brochure (or a brochure

that makes the appropriate disclosures).
Use of Sub-Advisors—Octavia may periodically recommend and refer clients to unaffiliated money managers or investment advisors (herein a “Sub-Advisor”) at Octavia’s discretion or the Client’s request. Octavia will remain your primary Advisor and oversee the Client’s investment allocation[s] octaviawa.com | 6 9999 Carver Road, Suite 130, Cincinnati, OH 45242, T: 513.762.7701, F: 513.762.7741 and overall investment performance. While the Sub-Advisor will assume day-to-day investment management of the assets, Octavia will be responsible establishing the Client’s investment objectives and recommending a Sub-Advisor’s investment strategy to meet those objectives. The Client will be provided with the Sub-Advisor’s Form ADV 2A (or a brochure that makes the appropriate disclosures).
Trust Fiduciary Services—Octavia may offer certain Clients access to custody and trust administrative services to certain Clients through National Advisors Holdings, Inc. and its various subsidiaries (“NAH”). Clients will enter into a separate agreement with NAH. Octavia will serve as the investment manager to any accounts established with NAH and earn an investment management fee as noted above. Octavia does not serve as a trustee for any account relationships.
Financial Planning Services Octavia 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, 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.
Octavia 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 poses 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. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. Additionally, 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 Octavia 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 octaviawa.com | 7 9999 Carver Road, Suite 130, Cincinnati, OH 45242, T: 513.762.7701, F: 513.762.7741 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 available include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Discretionary Investment Management (ERISA 3(38))
• Investment Oversight (ERISA 3(21))
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
• Provider Search These services are provided by Octavia 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 Octavia’s 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 Octavia 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—Octavia, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives.

• Asset Allocation—Octavia 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—Octavia will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client.

• Investment Management and Supervision—Octavia will provide investment management and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs Octavia does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by Octavia.
E. Assets Under Management As of December 31, 2022, Octavia manages $1,067,345,675 in Client assets, $857,882,325 of which is on a discretionary basis and $209,463,350 on a non-discretionary basis. Clients may request more current information at any time by contacting the Advisor.
octaviawa.com | 8 9999 Carver Road, Suite 130, Cincinnati, OH 45242, T: 513.762.7701, F: 513.762.7741