Brite Advisors USA, Inc. (“Brite USA” or the “Firm”) is a registered investment adviser with the U.S. Securities and Exchange Commission (“SEC”). The Firm’s advisory clients (“Clients”) consist primarily of United Kingdom (“U.K.”) expatriates residing in the United States (“U.S.”) who have pension assets located overseas. Brite USA provides customized, non-discretionary investment advisory services to Clients based upon such factors as their age, income, assets and debts, education, need for cash flow, investment goals and experience, and risk tolerance. The Firm collects this information during Client meetings, interviews, and telephone calls, as well as written communications. Brite USA Investment Adviser Representatives (“IARs”) analyze each Client’s financial situation and formulate an investment strategy using a combination of investments that is tailored for, and in the best interest of, the Client. The IARs are persons who, for compensation, (a) make any recommendation or otherwise render advice regarding securities; (b) manage accounts or portfolios of clients; or (c) determine which recommendations or advice regarding securities should be given. Prior to engaging Brite USA to provide investment advisory services, each Client is required to enter into one or more written agreements with the Firm setting forth the terms and conditions under which Brite USA renders such services (collectively, the “Agreement”). The Firm has been operational in the U.S. since September 2012. Effective December 19, 2023, Martin A. Byrne, Chief Executive Officer, acquired Brite USA from David McKenna, the Firm’s prior owner. As a result of the change of ownership, Mr. Byrne directly wholly-owns the Firm and is the sole control person of the Firm. Mr. McKenna no longer has any ownership interest, directly or indirectly, in the Firm. This disclosure brochure (“brochure”) describes the business of Brite USA. Certain sections also describe the activities of supervised persons of Brite USA, including its officers, directors (or other persons occupying a similar status or performing similar functions), or employees, or another person who provides investment advice on the Firm’s behalf and who is subject to Brite USA’s supervision or control. Description of Investment Advisory Services Clients engage the Firm to manage all or a portion of their assets on a non-discretionary basis only. The Firm does not act on a discretionary basis for Clients. The Firm’s investment advisory services primarily focus on the use of International Pension (including both SIPP and QROPS) schemes, described below, and the allocation of Client assets among mutual funds, exchange-traded funds (“ETFs”), individual debt and equity securities, Undertakings for Collective Investment in Transferable Securities (“UCITS”), and currency, consistent with the investment objectives of each Client. Clients may elect to allocate their assets according to model portfolios utilized by the Firm. Portfolios of Clients on the Brite Platform (described in Section E below) are automatically rebalanced to their starting allocations approximately annually. For Clients invested in a Brite Platform model portfolio, investments will be automatically rebalanced in order to maintain recommended asset allocations. On average, model portfolios are rebalanced annually, but rebalancing may occur more or less frequently depending on the circumstances. There may be substitutions of different underlying securities over time within an asset class, but there will be no change in asset allocations without prior notice and written consent obtained from Client. In addition to the Firm’s focus on International Pension schemes, the Firm’s investment advisory services include the management of Client assets custodied in the U.S. These services include the allocation of Client assets among mutual funds, ETFs, and individual debt and equity securities, consistent with the investment objectives of each Client. When recommending mutual funds, Brite will generally seek to recommend the lowest overall cost share class of mutual funds available to clients under the circumstances. The Firm tailors its investment advisory services to the individual needs of Clients. The Firm consults with Clients initially and on an ongoing basis to evaluate their financial situation, risk profile and recent developments that may impact their investment goals. Brite USA utilizes a number of technologies to assist with the process of providing advisory services to its clients. The Firm seeks investments that it believes are in the best interest of each of its Clients. Clients are advised to promptly notify the Firm if there are changes in their financial situation or investment objectives or if they wish to impose any reasonable restrictions upon the Firm’s investment advisory services. Use of International Pension Schemes The Firm’s business model focuses on advising Clients with respect to their U.K.-based pension plans and the investments held within those plans. A. Qualifying Recognised Overseas Pension Scheme (“QROPS”) In 2017, the U.K. Chancellor of the Exchequer announced that pension transfers requested on or after March 9, 2017, to certain QROPS, a type of international pension scheme, could be subject to an overseas tax charge of 25% on the value of the pension transfer. In light of this announcement, the Firm has determined to cease accepting any new advisory business from persons residing in the United States who seek to transfer their U.K. pension assets to a QROPS. Additional investments cannot be added to existing QROPS arrangements. The Firm currently intends to continue to service existing Clients who have QROPS arrangements. B. Self-Invested Personal Pension (“SIPP”) If in the best interest of the Client, Brite USA IARs may recommend that Clients transfer their U.K. pension assets to a SIPP, which is a type of personal pension plan offered by third party providers. A SIPP, subject to any applicable restrictions, allows Clients to invest in a range of assets. The value of SIPP retirement benefits is determined by, among other things, (i) the amount of contributions made, (ii) the period that each contribution has been invested, and (iii) investment performance over the period. C. General Brite USA does not maintain pension assets. All International Pension assets are administered by an overseas third-party pension trustee (regulated by the relevant financial services regulator where the pension plan is held) and custodied by a third-party custodian. International Pension assets are subject to the terms and conditions of a separate agreement between Client and the pension trustee. The QROPS pension trustees with which Clients currently have agreements include STM Malta Trust and Company Management Ltd (“STM Malta”), Trireme Pension Services (“Trireme”), and MC Trustees (MC) each an overseas financial services company. The pension trustees for the SIPPs that the Firm recommends currently include London and Colonial Services Limited (“L&C”), and the Pension Solutions Group SIPP Limited (“PSG”). L&C and PSG are each companies authorized and regulated by the U.K. Financial Conduct Authority (“FCA”). L&C is wholly owned by STM Group Plc, which also owns STM Malta. PSG is indirectly wholly owned by Brite Advisory Group Limited, a Hong Kong company (“BAG”) via its controlling interest in Basi & Basi Financial Planning Limited (“B&B”), a financial advisory firm based in the United Kingdom. See “E. The Brite Platform,” below. Other International Pension providers may be available through other investment advisers under different arrangements, including but not limited to applicable fees and charges, and residency requirements. Clients are strongly encouraged to review their agreements with their pension trustees and any and all other disclosure materials provided by the pension trustees or other parties for a full understanding of the services provided by the pension trustees and any associated costs therein. The pension trustees generally send account statements on at least an annual basis directly to Clients. The pension trustees also make account information available online to Clients through the investment platforms utilized in connection with International Pension arrangements. Clients are strongly encouraged to review such

material carefully for more information about the services offered by the pension trustees, the costs associated with the management of such pension plans, and the activity in their accounts. Questions regarding Brite USA’s services and fees may be addressed directly with Firm personnel. D. Tax Matters Brite USA does not provide any tax advice including, without limitation, in relation to any U.S. tax reporting requirements and/or other tax implications arising in relation to Clients’ pension transfers. Although, from time to time, the Firm may inform Clients of tax developments, the Firm recommends that Clients seek their own tax advice, including advice on procedures under tax treaties between the U.S. and the U.K. (or other applicable jurisdiction) for the avoidance of double taxation on their respective pension arrangements. E. The Brite Platform (Brite USA no longer recommends the Brite Platform) The Firm has entered into a platform agreement with BAG (the “Platform Provider”), pursuant to which BAG, through one or more of its direct and indirect wholly-owned companies, has agreed to make available to Clients an end-to-end retirement solution that is tailored for U.K. expatriates residing in the U.S. who desire to transfer their U.K. pension assets out of the U.K. (“Brite Platform”). The Brite Platform also is available to Clients with existing International Pension accounts. The Brite Platform integrates the U.K. pension asset transfer process with overseas pension trusteeship, asset management, trading, custody, and reporting, as follows: Service Provider Pension Transfer Analysis Onvestor Reporting, a trading name of Basi & Basi Financial Planning Limited. Pension Trustees SIPPs: L&C and PSG QROPS: MC Trustees (Malta) Ltd. (“MC Trustees Malta”) Trireme Pension Services and STM Malta Investment Adviser Brite Advisors USA, Inc. Trading and Custody Interactive Brokers (Australia) Pty. Ltd (“IB”) Custody and Reporting Brite Advisors Pty. Ltd (Australia) (“PTY”) Onvestor Reporting is a trading name of Basi & Basi Financial Planning Limited (“B&B”), which is authorized and regulated by the FCA. Michael Basi, managing director of B&B, owns a non-controlling interest in BAG. B&B is directly wholly owned by BAG. In turn, B&B directly wholly owns PSG. Brite Advisors Pty Ltd (Pty) is directly wholly owned by Brite Advisory Group Limited (BAG). BAG indirectly owns a non-controlling interest in MC Trustees Malta. As consideration to BAG for making the Brite Platform available to Firm Clients, the Firm has agreed to pay BAG a quarterly fee at the annual rate of 0.10% of the Clients’ pension assets on the Platform (“Platform Fee”). The Firm pays the Platform Fee out of the 1% advisory fee it charges Clients, as discussed in “Item 5. Fees and Compensation,” below. It is not a separate or additional charge. For performing the Pension Transfer Analysis required by FCA regulation, Onvestor Reporting charges a fee that is described in “U.K. Appropriate Pension Transfer Advice Fee” under “Item 5 – Fees and Compensation – Additional Compensation, below.” For existing Clients who are currently utilizing a QROPS or a SIPP from one of the pension trustees discussed above in “C. General” under “International Pension Schemes,” the Brite Platform is expected to offer cost savings. Accordingly, it may be in the best interest of Clients to transfer their pension assets to the Brite Platform. To help determine whether a transfer to the Brite Platform is in a Client’s best interest, the Firm’s IARs will provide the Client with a comparative analysis of the fees and costs, available investment alternatives, and other features of the Client’s current International Pension arrangement as compared to those available under the Brite Platform (“Comparative Analysis”). In October 2023, the Company learned of an interim consent order (“Interim Order”) by the Australian Securities & Investments Commission (“ASIC”) involving Pty, the custodian of the Brite Platform. See Australian Securities & Investments Commission v. Brite Advisors Pty Ltd, ACN 135 024 412, No. WAD262/2023, Federal Court of Australia, Western District Registry (“Australia Action”). The Interim Order and subsequent orders (“Orders”) of the Federal Court of Australia place limitations on Pty’s ability to remove property, incur new liabilities, and withdraw or transfer monies. The Orders apply to all property of Pty, including assets held in accounts at Interactive Brokers (Australia) Pty. Ltd. Further, ASIC appointed “Corporate Receivers and Managers” namely, McGrath Nicol, over Pty and its property. The Firm has retained counsel in Australia for advice and assistance regarding the Australia Action. F. Brite Transfer Program for Clients with Existing International Pension Accounts Existing Clients who wish to transfer their current International Pension to the Brite Platform generally will incur exit fees charged by their existing pension trustees and platforms. The amount of the exit fees will vary depending on such factors as the pension trustee, the platform, and how long the International Pension account has been in existence. In addition, the platform exit fees are generally a percentage of assets and can be as high as 10% of the original pension assets invested. The specifics of the arrangement with your International Pension provider may be different. Please review the terms and conditions of your arrangement or ask the Firm IAR who handles your advisory account for more information, including information regarding pension trustee fees. To help mitigate the cost of such exit fees for Clients who decide to transfer to the Brite Platform, PTY has agreed, for a limited time, to advance the cost of any platform exit fees (related to the establishment fee of the life bond) imposed on transfer, subject to reimbursement of the fees over an agreed period not exceeding 10 years. Please ask your IAR for a Comparative Analysis and for more information. This transfer program (“Transfer Program”) allows Clients to transfer 100% of their pension assets to the Brite Platform. To participate in the Transfer Program, Clients must submit a completed application to the applicable Pension Trustee and PTY for approval, which the Pension Trustees and PTY may or may not approve in their sole discretion. PTY may modify or terminate the Transfer Program at any time and in any manner in its sole discretion without prior notice, except for applications it has already approved. Non-International Advisory Services In managing a Client’s non-international assets, Brite USA does not follow a specific investment strategy but rather utilizes strategies driven by and tailored to each Client’s needs and specific circumstances. In developing investment recommendations, the Firm’s IARs principally will employ an analysis of a Client’s financial and other information regarding such matters as the Client’s age, investment objectives, annual income, assets and debts, tax status, investment experience, liquidity needs, risk tolerance, and employment/retirement status. For some Clients, the Firm’s IARs may determine to seek more information in order to get a clearer picture of the client’s overall financial situation. The Firm’s IARs do not provide tax advice regarding Client non-international pension assets. See Item 8 below for more information regarding the types of securities used in these Client portfolios and related supervision. Assets Under Management As of December 31, 2022, Brite USA had $468,148,435.00 of assets under management on a non-discretionary basis. The Firm does not manage assets under management on a discretionary basis. For assets under management custodied on the Brite Platform, due to the current liquidation of PTY (see further information at Item. 4 above) Brite USA is unable, at this time, to accurately state the assets under management custodied on the Brite Platform for the reasons outlined by McGrathNicol in their reports to the Federal Court of Australia. Brite USA is awaiting further information in this regard and will update its ADV, accordingly. Please reach out to your investment adviser representative if you have any questions. Sponsor / Manager of Wrap Program Brite USA does not sponsor or participate in wrap fee programs.