A. Description of the Advisory Firm Lotus Investment Advisors LLC ("LIA") provides discretionary investment management services. It is established as a Limited Liability Corporation whose fiscal year end is December 31. It is 100% owned by Lotus Holdings, LLC, which is 100% owned by David Brandman, and was formed in August 2008, though was not active until early 2014.
B. Types of Advisory Services Lotus Investment Advisor's mission is to run individually managed accounts, tailored to the needs, objectives, and risk tolerance level of the client. Our role is to remain aware of client’s circumstances in order to make investments which are suitable for the client, in equities, fixed income instruments, ETF’s, mutual funds, and occasionally other asset groups.
Growth and balanced growth investment management focuses primarily upon the identification and purchase of stocks experiencing or expected to experience accelerated earnings momentum. Value stocks are representative of companies that have stable and viable businesses but are more cash flow oriented and not considered growth stocks. These may include companies that pay dividends or have reached a turning point in their previous growth trajectory. As an active investment manager, in consideration of our clients needs, we will allocate assets between these securities classes. When we feel that economic conditions call for a change in strategy, we will typically reduce the client’s equity exposure, shifting to bonds, or cash equivalents. Investments are not limited to stocks of certain levels of capitalization, but span the range from small

to medium to large, with the emphasis at any given time placed on those areas deemed most value attractive.
A general approach to bond management is employed. Bond portfolio durations are targeted using economic analysis and interest rate forecasts. Information derived from further research will cause sector, coupon and quality weightings to vary according to expected opportunities and risks.
C. Client Tailored Services and Client Imposed Restrictions Our firm provides continuous advice to clients regarding investment of client funds based upon their individual objectives. At the outset of a relationship a client is asked to define objectives and constraints while we provide information about investment opportunities and review expectations. From these discussions a portfolio is developed which will attempt to meet the client’s needs. During our data- gathering process, we determine the client's individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client's prior investment history, tax situation, and estate plan in order to increase our understanding of the client’s needs.
In certain cases, clients may object to investing in certain industries or asset classes. In these cases, we will do our utmost to observe the client’s wishes. If a client imposes an outright restriction concerning certain types of investment, we will observe it.
D. Wrap Fee Programs Lotus Investment Advisors does not participate in Wrap Fee Programs.
E. Amounts Under Management Total Amount: $46,000,000 Discretionary Amounts: $41,000,000