Entoro Investments, LLC ("Entoro Investments" or “The Adviser”) is located in Houston Texas. Entoro Investments is wholly owned by Entoro, LLC of which James C. Row is the majority owner. Entoro Investments is under common control with Entoro Securities, LLC, its affiliated broker/dealer member firm of the Financial Industry Regulatory authority ("FINRA-"). Assets Under Management As of December 31, 2022, Entoro Investments manages approximately $6,750,000 in client assets broken down as follows:
• Discretionary: $5,000,000
• Non-Discretionary: $0 Entoro Gray Swan Fund Entoro Investments will provide investment advisory services to the Entoro Gray Swan Fund, a Delaware statutory trust, which will be registered with the Securities and Exchange Commission (the "SEC") as a registered investment company. Financial Advisory Services to Individuals Entoro Investments provides comprehensive financial advisory services to individual clients (“Comprehensive Services”). These Comprehensive Services bundle investment advisory services, financial planning services, and other related services into a single fee-based offering. Comprehensive Advisory Services will be tailored to a client's specific needs and goals through a dialogue concerning their assets, liabilities, income, expenses, goals, and objectives. Entoro Investments provides investment advisory services to its clients on a discretionary basis, that is, the Adviser executes securities transactions for clients without having to obtain specific client consent prior to each transaction. Entoro Investments places trades for clients under a limited power of attorney. Discretionary authority is limited to investments within a client’s managed account. The Adviser does not act as a custodian of client assets. The client always maintains asset control. Entoro Investments’ investment advisory services generally include advice regarding asset allocation, the selection of investments, investment plan implementation, and ongoing investment monitoring. The Adviser relies on the stated objectives of the client and considers the client’s risk profile and financial status prior to making any recommendations. Upon entering into an advisory agreement, the Adviser will collect information concerning the client's investment goals and experience, risk tolerance, and income needs, as well as financial information such as assets, liabilities, and portfolio statements. Based on the information provided by the client, the Adviser will recommend investment solutions consistent with the client's stated goals and objectives. While Entoro Investments does not limit to the types of investments offered, clients may impose restrictions on investing in certain securities or types/classes of securities. Actively Managed Liquid Securities Entoro Investments manages different liquid asset allocation models, each designed to meet a specific investment goal. Security selection within each model may be comprised of load and no- load mutual funds, exchange-traded funds (ETFs), and/or individual securities. Each model has a strategic asset allocation. However, the Adviser may alter a model’s actual asset allocation based on fundamental /technical analysis of the markets, and/or macroeconomic forecasts. The Adviser, acting in a limited discretionary capacity, chooses when to execute any trade. Illiquid Direct Participation Investments (DPIs) The Adviser conducts due diligence on different illiquid direct participation investments (DPIs). DPI offering structures may be private equity (for example, Regulation D, Regulation A, etc.), public non-traded offerings (for example, S-1 offerings, Intrastate offerings, Business Development Companies (BDCs), non-traded mutual funds, etc.), non-traded Real Estate Investment Trusts (REITs), and/or non-traded oil and gas programs. DPIs will often have minimum investor suitability standards, which are disclosed within an investment’s prospectus or offering circular. More restrictive State or firm-level suitability or concentration standards may be applied. For purposes of determining suitability, the Adviser defines the following terms:
• Annual Income – Personal income from sources such as employment, alimony, social security, investment income, etc.
• Household Net Worth – The value of all assets minus all liabilities. Assets include stocks, bonds, mutual funds, other securities, bank accounts, real assets (e.g., real estate), and other personal property as well as primary residence. Liabilities include mortgage, margin loans, outstanding loans, credit card balances, taxes, etc.
• Investable Net Worth – The value of “investable” assets minus liabilities associated with those assets. Investable assets include stocks, bonds, mutual funds, other securities, bank accounts, hard assets (e.g., real estate), and other investments less any costs associated with liquidating such assets (e.g., redemption fees, contingent sales charges, sales commissions, taxes and tax penalties if the client is less than 59.5 years old and liquidating qualified accounts, etc.) Primary residence, personal-use automobiles, and personal belongings are not included. Liabilities include any margin loans and other associated outstanding loans. Any mortgage on the primary residence is not included unless the mortgage balance is greater than the fair market value of the primary residence. If this should happen, the amount of the mortgage that is greater than the value of the home is included as a liability. Any amount of the mortgage balance that has increased over the prior 60 calendar days of calculating net worth is included.
• Liquid Net Worth – Investable New Worth minus assets that cannot be converted quickly and easily into cash, such as real estate, business equity, personal property and automobiles, expected inheritances, assets earmarked for other purposes, and investments or accounts subject to substantial penalties (e.g., penalties

or redemption fees greater than five percent of the face value of the investment) if they were sold or if assets were withdrawn from them.
• Accredited Investor – As defined under Rule 501 of Regulation D under the Securities Act, an Accredited Investor is an individual or joint with spouse with greater than $1,000,000 in Investable Net Worth, or individual Annual Income in excess of $200,000 in each of the two most recent years, $300,000 if jointly, and has a reasonable expectation of reaching the same income level in the current year.) While DPIs may offer interval-based (i.e., quarterly), periodic tender offers, or some other form of an early redemption feature, in general, any DPI should be considered illiquid. That is, an investor should consider any DPI as being illiquid and without a secondary market upon which to sell one’s investment and thus no opportunity to convert one’s investment into cash. Anticipated holding periods will vary depending on the nature and strategy of the DPI. The Adviser will communicate anticipated holding periods per language provided within each DPI’s prospectus or offering circular. However, there is no guarantee that a liquidity event will occur within the prescribed timeframe if at all. All DPIs should be considered speculative in nature, subject to a high degree of risk, including the risk of losing one’s entire investment. Special Circumstance Direct Participation Investments (SCDPIs) Entoro Investments offers the management of various Special Circumstance Direct Participation Investments (SCDPIs). While the Adviser’s security selection capacity is broad, a common feature of a SCDPI is the potential to derive some tax mitigation benefit. Common SCDPIs include: Section 1031 Exchanges, Conservation Easements, and Oil and Gas Drilling Programs. Each SCDPI will have specific investor Net Worth and Suitability standards, which will be disclosed per each prospectus or offering circular. In general, most SCDPIs will require the investor to be “accredited”, which is defined as an investor who earns an individual income of more than $200,000 per year, or a joint income of $300,000, in each of the last two years and expect to reasonably maintain the same level of income, or has a net worth exceeding $1 million, either individually or jointly with his or her spouse. In general, SCDPIs have long holding periods and should be considered illiquid. The Adviser will communicate anticipated holding periods per language provided within each SCDPI prospectus or offering circular. However, there is no guarantee that a liquidity event will occur within the prescribed timeframe or at all. While each SCDPI will have its own unique set of risks, all SCDPIs should be considered speculative in nature, subject to a high degree of risk, including the risk of losing one’s entire investment. A minimum of $100,000 in assets is required; however, the Adviser may waive such minimum at its sole discretion. Third-Party Separately Managed Account Programs Entoro Investments may use a third-party separately managed account (SMA) program offered through various custodians. With SMA programs, the SMA sponsor selects the investments, monitors and evaluates investment performance, and executes portfolio transactions without commission charges. All of these services are generally provided via a single management fee in which the client pays to the SMA sponsor. Specifics regarding these offerings are described in separate fee program brochures prepared and distributed by the SMA sponsor. The total fees charged by the fee program sponsor, including brokerage and custodial fees, may in total exceed the cost of separately obtaining brokerage, custody, and other services if such fees were negotiated separately. the Adviser maintains discretion on SMA-managed accounts. A minimum of $25,000 in assets is required; however, the Adviser may waive such minimum at its sole discretion. Wrap-Fee Programs Entoro Investments does not sponsor nor is a portfolio manager for a wrap fee program, and is not compensated in the program for sponsoring, organizing or administering a program, or for selecting, or providing advice to clients regarding the selection of other investment advisers in the program. Investment Advisory Services to Institutions Entoro Investments offers investment advisory services specifically tailored to the needs and special circumstances of businesses, including their pension and retirement plans. These services are generally provided in conjunction with other professionals and include investment management services for pension and profit-sharing plans, 401(k) plans, 403(b) plans, SEP IRA plans, SIMPLE IRA plans, non-qualified deferred compensation plans, asset protection plans, executive salary continuation plans, cross-purchase and stock redemption agreements, and employee advisory services. The Adviser also provides general investment advisory services specifically tailored to the needs of a trustee or other fiduciary, including but not limited to, meeting the definition of “fiduciary” under the Employee Retirement Income Security Act of 1974 (“ERISA”) or an employee benefit plan subject to ERISA. Investment Advisory Services to Financial Intermediaries Entoro Investments offers investment advisory services to financial intermediaries (e.g., broker- dealers and registered investment advisers), serving as a sub-adviser to the financial intermediary. The Adviser’s investment advisory services may include assisting the financial intermediary with investment policy statement determination, asset allocation, investment selection, portfolio management, and client reporting. The Adviser’s investment advisory services are generally provided on a discretionary basis. Entoro Investments may also offer investment advisory services on a non-discretionary basis. For these clients, the Adviser will contact the client before making recommendations the Adviser deems to be appropriate for the client.