A. Ownership Banco de Crédito e Inversiones, S.A. (“BCI”), a Chilean bank, is the majority shareholder of Bci Securities. Empresas Juan Yarur SpA, a Chilean holding company, is the majority shareholder of Banco de Crédito e Inversiones. Mr. Luis Enrique Yarur Rey is the majority shareholder of Empresas Juan Yarur SpA. Following is a depiction of the Firm’s ownership structure in a hierarchical chart: B. Services GENERAL INFORMATION. Through a Wrap Fee Program (the “Program”), we provide personalized discretionary as well as non-discretionary investment management services. We also provide various discretionary managed model portfolios to which the advisory client may subscribe. For all accounts, clients are asked to provide us with certain information including their age, employment status, current financial holdings, investment purpose and objectives, investment experience and risk tolerance, liquidity needs, and time horizon. For personalized discretionary accounts, we also inquire as to the restrictions if any the client wishes to impose on the management of the account. NON-DISCRETIONARY ACCOUNTS. For non-discretionary accounts, we will recommend an investment strategy, allocation mix, or changes to the client's existing portfolio that we believe are suitable for that client. We have an ongoing responsibility to make recommendations to the client based upon the client's financial and investment profile. The client approves or disapproves each recommendation made by the Firm. Upon approval of any recommendation, we will arrange for effecting the securities transaction(s) recommended. DISCRETIONARY ACCOUNTS. From the information that is supplied by the client, we construct a personalized investment policy that we believe is suitable for that client. The discretionary management agreement gives us complete discretionary authority to buy and sell securities within the account without the client’s prior consent for each transaction. We strive to make investment decisions to fulfill the client’s objectives consistent with the client’s financial information and risk tolerance as such information is communicated to us. As the client’s objectives and risk tolerance change, we continue to tailor the advisory service to match the client’s needs. Bci Securities, Inc.
Banco de Crédito e Inversiones Empresas Juan Yarur SpA Luis Enrique Yarur Rey DISCRETIONARY MODEL PORTFOLIOS. We offer a series of diversified asset allocation models that range from conservative to aggressive. These models are designed to address a variety of risk levels and investment and income objectives. There are four distinct models: Smart, Alpes, Sierra, and the JPM Strategic Portfolios. Within each, we offer three asset allocation strategies to address various risk appetites and goals. Each model portfolio utilizes primarily a mix of mutual funds, exchange-traded funds (“ETFs”) and cash (or cash equivalents). As of the brochure distributed November 30, 2023, the Firm is no longer offering these strategies in certain of its model portfolios as follows:
• In the Alpes and Sierra model portfolios, the Firm no longer offers the “Conservative” or “Moderately Aggressive” asset allocation strategies.
• In the Smart model portfolios, the Firm no longer offers the “Conservative” or “Aggressive” asset allocation strategies. The Firm has established that Clients invested in these model portfolios have until May 31, 2024 to transition to any of the remaining asset allocation strategies. The Firm will not charge a fee for this transition. For each model (with the exception of the Alpes and Sierra models), we contract with a third-party investment adviser/model provider (which may be foreign or domestic) that provides us with asset allocation signals for that model. Set forth below is a brief description of each type of portfolio we offer at present: ▪ SMART – Portfolios are invested in securities worldwide, including in the U.S., Latin America, Europe, and/or Asia. These portfolio models are developed by our affiliate, Bci Asset Management Administradora General de Fondos S.A. (“Bci Asset Management” or “BAM”), based in Santiago, Chile. ▪ ALPES – Portfolios are generated in-house and are not constrained by any particular region, security type, or asset class, and are geared towards offshore investors. ▪ SIERRA Portfolios are generated in-house and are not constrained by any particular region, security type, or asset class, and are geared towards onshore investors. We offer allocation strategies ranging from “Moderately Conservative” to “Aggressive”, depending on the model, as follows. For Alpes and Sierra, we offer three strategies:
• Moderately Conservative
• Moderate
• Aggressive For the Smart models, we offer three strategies:
• Moderately Conservative
• Moderate
• Moderately Aggressive Generally, the risk tolerance associated with the Alpes and Sierra models listed above is as follows: o Moderately Conservative –This type of allocation seeks to provide both income and capital preservation by primary investing in multiple asset classes, including stocks, bonds, and cash. A moderately conservative allocation strategy prioritizes capital preservation over appreciation. o Moderate –This type of allocation seeks to provide both income and capital appreciation by investing in multiple asset classes, including stocks, bonds, to balance capital preservation with appreciation. There is some degree of volatility in these portfolios. o Aggressive–This allocation seeks to provide both income and capital appreciation by primarily investing in multiple asset classes, including stocks, bonds, and cash and prioritizes capital appreciation over capital preservation. The assets will be invested in securities that have more significant risk. Generally, the risk tolerance associated with the Smart models listed above is as follows: o Moderately Conservative –This type of allocation seeks to provide both income and capital preservation by primary investing in multiple asset classes, including stocks, bonds, and cash. A moderately conservative allocation strategy prioritizes capital preservation over appreciation. o Moderate–This type of allocation seeks to provide both income and capital appreciation by investing in multiple asset classes, including stocks, bonds, to balance capital preservation with appreciation. There is some degree of volatility in these portfolios. o Moderately Aggressive –This allocation seeks to provide both income and capital appreciation by primarily investing in multiple asset classes, including stocks, bonds, and cash and prioritizes capital appreciation over capital preservation. The assets will be invested in securities that have more significant risk. The Firm also has an agreement with J.P. Morgan Investment Management, Inc.(“JPM”), whereby it offers recommendations to the Firm of its JPM Strategic ETF Portfolios (the “JPM Portfolios”). The JPM Portfolios are comprised of J.P. Morgan ETFs across a range of risk profiles stated below and take a long-term, benchmark approach to asset allocation with a focus on risk-adjusted returns. Pursuant to this agreement, the Firm offers an additional series of discretionary models for which we offer three asset allocation strategies:
• Conservative
• Moderately Conservative
• Growth. Generally, the risk tolerance associated with each of these JPM asset allocation strategies listed above is as follows: o Conservative–This type of allocation seeks to provide both income and capital preservation by primary investing in multiple asset classes, including stocks, bonds, and cash. A moderately conservative allocation strategy prioritizes capital preservation over appreciation. o Moderately Conservative–This type of allocation seeks to provide both income and capital appreciation by investing in multiple asset classes, including stocks, bonds, to balance capital preservation with appreciation. There is some degree of volatility in these portfolios. o Growth–This allocation seeks to provide both income and capital appreciation by primarily investing in multiple asset classes, including stocks, bonds, and cash and prioritizes capital appreciation over capital preservation. The assets will be invested in securities that have more significant risk. JPM has a conflict of interest in selecting certain funds for its JPM Portfolios because JPM and its affiliates provide services and receive fees from such funds and, therefore, a client’s investment in those funds in the model portfolio will benefit the model providers and their affiliates. The Firm has an agreement with BlackRock Financial Management, Inc. (“BlackRock”) whereby it offers recommendations to the Firm of two BlackRock model portfolios (one domestic and one offshore), and three asset allocation strategies for each as follows:
• BlackRock Long Horizon US Exchange-Traded Funds (“ETF”) o Conservative—BlackRock Long Horizon ETF 20/80 Model. o Moderately Conservative—BlackRock Long Horizon ETF 50/50 Model. o Moderately Aggressive—BlackRock Long Horizon ETF 80/20 Model.
• BlackRock Long Horizon Undertaking for Collective Investment in Transferable Securities (“UCITS”) o Conservative--BlackRock Long Horizon 20/80 UCITS Portfolio. o Moderately Conservative—BlackRock Long Horizon 40/60 UCITS Portfolio. o Moderately Aggressive—BlackRock Long Horizon 80/20 UCITS Portfolio. Generally, the risk tolerance associated with each of these BlackRock asset allocation strategies listed above is as follows:
• Conservative—this type of allocation seeks to provide both income and capital appreciation by investing in multiple asset classes including stocks, bonds, and cash. A conservative allocation strategy prioritizes capital preservation over appreciation and is generally less volatile than a moderately conservative strategy.
• Moderately Conservative—This type of allocation seeks to provide both income and capital appreciation by investing in multiple asset classes, including stocks, bonds, and cash. A moderately conservative strategy prioritizes preservation of capital over appreciation. There is some degree of volatility in these portfolios.
• Moderately Aggressive—This type of allocation seeks to provide both income and capital appreciation by investing in multiple asset classes, including stocks, bonds, and cash. A moderately aggressive strategy prioritizes capital appreciation over capital preservation. There may be greater volatility in these portfolios. BlackRock has a conflict of interest in selecting certain funds for its portfolios because Blackrock and its affiliates provide services and receive fees from such funds and therefore a client’s investment in those funds in the model portfolio will benefit the model providers and their affiliates. In order to determine the model most suited to a client’s needs, we speak with the client to discuss the client’s specific situation and/or gather from the client information about his/her objectives, needs, risk tolerance, time horizon, and desired investment restrictions. Based on the information the client provides, we assist the client in determining which model portfolio is most suitable. When a client subscribes to one of the model portfolios, we have the authority to determine the securities to be purchased or sold and the amount of securities to be purchased or sold within the Program accounts consistent with each model’s objectives. Such discretionary authority includes the ability to select and modify the investments underlying each model. ▪ Rebalancing. At the inception of the advisory relationship, the client’s assets are invested to match the model’s then-current allocation. As markets fluctuate and securities values change, amounts originally allocated to a specific security or asset class will either exceed or fall below the target allocation. We therefore periodically adjust account holdings to be in line with the asset allocation target

set forth in the model consistent with the signals we receive from the providers. This is referred to as “rebalancing” the account. We do not rebalance accounts on a continual basis. For that reason, asset allocations may drift away from the target associated with the model before we rebalance the accounts. ▪ Reallocation. For each model (with the exception of the “Alpes” and “Sierra” models), the third-party with whom we contract provides us with reallocation signals. We review the recommended changes to the target percentages or asset classes for the model and determine whether to implement the changes. Changes in the model may be based on a variety of factors, including without limitation, changes in the economic or financial climate, or changes in the management of the underlying securities used in the model, and performance. We may replace a security (or securities) if we believe that a different security would be better suited for the portfolio. Any changes in the portfolio’s securities or the investment allocation will be consistent with the objectives of the model the client has chosen. DISCRETIONARY ACCOUNTS WITH THIRD PARTY REGISTERED INVESTMENT ADVISER. Bci Securities may also select for clients a sub-adviser third-party RIA to manage a portfolio or segment of a portfolio of an advisory client on a full discretionary basis. The client will sign a discretionary agreement with Bci Securities which permits it to delegate its authorities to that third-party. Bci Securities will conduct due diligence on such third-party RIAs, over which Bci Securities will not have responsibility or control for the portion managed by the third-party RIA. Bci Securities will monitor the performance of the portfolios, but the third-party RIA will manage the account without further approval by Bci Securities or the client and will conduct rebalancing. Pershing will collect advisory fees from the client account and will pay agreed upon fees to the third-party RIA and the balance to Bci Securities. PROGRAM BROKER. Bci Securities is registered as a broker-dealer and, in that capacity serves as the “Program Broker” for these wrap fee program accounts. As broker-dealer, we place the transactions for the advisory accounts and use our clearing firm Pershing LLC as the executing broker and custodian. The transaction costs associated with such trading activity are covered by the wrap fee. As custodian, Pershing performs the execution and custody services. The advisory client enters into an agreement with Pershing for it to provide execution and custody. The “wrap fee” includes Pershing’s execution and custody services. In limited instances, clients may transfer funds from their managed advisory account to another financial institution account using the Automated Clearing House network (“ACH”). The use of ACH may trigger the custody rule. In addition, the custody rule applies when clients enter into agreements for non-purpose loans with our affiliates pledging the assets in their investment accounts as collateral. When the custody rule is triggered, the Firm as an adviser must:
• Maintain client funds and securities at a Qualified Custodian;
• Have reasonable basis to believe that the Custodian sends account statements directly to the client on at least a quarterly basis;
• If it also sends reports to the client on a regular basis, include a statement urging the client to compare the statement and report and promptly report to the Firm any discrepancies; and
• Undergo an Annual Surprise Examination by an independent public accountant of the assets over which the Firm has custody. C. Assets Under Management As of December 31, 2023, in the Wrap Fee Program Accounts, we were managing approximately $219,392,970 in assets on a non-discretionary basis (where we make recommendations to the client and arrange for the transactions in the account if the client approves the recommendations). We were also managing $101,606,468 in assets on a discretionary basis. Of that amount, $98,417,410 were invested in the discretionary model portfolios. We were not managing any assets for non- wrap relationships. D. Fees The client pays a “wrap fee” for the advisory services offered by us and the execution of transactions in the advisory account. Generally, for the discretionary and non-discretionary portfolio management services, we charge an annualized fee between 1.00% and 2.00% according to the following schedule: AUM Annualized Fee (%) Up to $1,000,000 2.00% 1,000,001 – 2,000,000 1.75% 2,000,001 – 3,000,000 1.50% 3,000,001 – 5,000,000 1.25% 5,000,001 and up 1.00% When subscribing to a model portfolio, we generally charge the client the following fees: AUM Annualized Fee (%) Up to $1,000,000 2.00% 1,000,001 – 2,000,000 1.75% 2,000,001 – 3,000,000 1.50% 3,000,001 – 5,000,000 1.25% 5,000,001 and up 1.00% "AUM" means the market value of the client’s assets under our management. The fees listed in the schedules above are annualized figures. Fees will be charged quarterly and in arrears. The quarterly fee will be based upon the market value of all assets held within the client's managed accounts on the last business day of the calendar quarter. By way of example, if the total market value of the client’s accounts is $2,500,000 on the last day of the calendar quarter, the quarterly fee will be 0.375% of the $2,500,000. The advisory services commence on the date on which the advisory agreement is signed by us. For the first calendar quarter, fees will be adjusted pro rata based on the number of calendar days in the quarter for which the advisory agreement was effective. We will charge a pro rata fee in the event the advisory services are terminated on a day other than the last business day of the calendar quarter. In that event, the full amount of the pro rata fee will be due and payable upon termination of the service. No fee will be charged if the agreement for services is terminated within five (5) business days of signing the agreement. The client's account will be debited for the above-mentioned fees. We collect the fees from the amount of any contribution or transfer, from available cash in the client's account, or by liquidating the client's assets held in the client's account in an amount equal to the fees that are due. The custodian has no responsibility to verify the accuracy of the fee calculation. We may adjust the fee schedule upon thirty (30) days' prior written notice to the client. Fees are often negotiated for family members of our employees. Fees may also be negotiated for other advisory clients depending on such factors as whether a relationship exists with an affiliate and the type and duration of such relationship, and the amount invested. Thus, some clients may pay more or less than others for the same or similar services. FEE CONSIDERATIONS. The management fees set forth above are based on the aggregate value of the assets invested by the client and are not dependent on the amount of trading in the account of the advice given over any particular time period. In determining whether to establish a Wrap Fee Program account, the client should be aware that the overall cost to the client may be higher than the client might incur by purchasing separately the types of securities available in the Program. The Program costs may be particularly comparatively higher when there are a low number of transactions in the advisory account. The Program might not be suitable for clients whose accounts have fewer than a certain number of transactions per year or for clients who simply want to purchase individual securities. To meaningfully compare the cost of the Program with unbundled services, the client should ask us about and consider the portfolio turnover rate. LOWER FEE DISCLOSURE. Bci Securities' wrap fees may be higher than those charged by other investment advisers offering comparable services. In some instances, clients may sign an advisory agreement with a third-party registered investment adviser that Bci Securities may select for the client for a portion of the portfolio or the entire portfolio to be managed on a full discretionary basis by the third-party RIA. In this case, there is a conflict of interest as the client could enter into an advisory agreement directly with the third-party RIA and possibly pay a lower fee. However, where Bci Securities selects the third-party RIA for the client, it also provides due diligence and monitoring of the portfolio. E. Other Fees In addition to the wrap fee, other fees may apply. The wrap fee does not include: (1) sales loads, sales charges, management fees, administrative fees, account maintenance fees, and other fees that may be charged by the custodian (if any), and/or by the distributor, issuer or fund issuing the securities purchased and sold within the Program accounts; (2) administrative fees, such as wire fees, charged by us or Pershing for the clearance and settlement of the trades executed in the advisory accounts; (3) certain odd-lot differentials; (4) transfer taxes; (5) postage and handling fees; (6) advisory fees and expenses of mutual funds (including money market funds), closed-end investment companies, ETFs, or other managed investments, if any, that are held in the Program account; or (7) interest charged by any custodian or lender on loans taken. The client is solely responsible for paying all such charges. The Firm may receive a portion of interest charged against loans taken. Please see item # 9 section F.1 for more information. In addition, the client should understand that mutual funds and certain ETFs pay management fees to their investment advisers, which reduce their respective assets. To the extent that the client’s portfolio has investments in mutual funds or ETFs, the client may pay two levels of advisory fees for the management of their assets: one directly to Bci Securities, and the other indirectly to the managers of the mutual funds and ETFs held in the Program portfolios. Clients should understand that mutual funds or closed-end investment companies purchased for a Program account that collect certain types of additional fees from the client (e.g. 12b-1 or shareholder servicing fees) generally pay us a proportionate share of these fees. F. Compensation Some investment adviser representatives who recommend the Program to the client will receive compensation as a result of the client's participation in the Program. The amount of this compensation may be more than what the investment adviser representative would receive if the client paid separately for brokerage and other services. To the extent the investment adviser representative will receive more compensation if the client enters into a wrap fee program account, the investment adviser representative will have a financial incentive to recommend the Program over unbundled services. Bci Securities is affiliated with Bci Asset Management, which formulates and provides asset management signals for the International models. Although we might pay the same or a lower percentage to our affiliate than to other providers, because of our affiliation, we have an interest in recommending the models provided by Bci Asset Management. Certain providers with whom we have contracted to construct model portfolios charge more than others to generate the reallocation signals. To the extent that the third-party provider charges us more, we may have less incentive to recommend their models. Where Bci Securities selects a third-party RIA to manage all or part of a client portfolio on a full discretionary basis, a portion of the wrap fee is paid to the third-party RIA. The client should direct any questions about these incentives and inherent conflicts of interest to the Investment Adviser Representative servicing the client’s account. G. Termination The Program may be terminated either by Bci Securities or by the client upon thirty (30) days' written notice to the other party.