CORDOBA ADVISORY PARTNERS LLC

Cordoba Advisory Partners LLC Form ADV Part 2A – Disclosure Brochure Effective: March 28, 2025 This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices of Cordoba Advisory Partners LLC (“CAP” or the “Advisor”). If you have any questions about the content of this Disclosure Brochure, please contact the Advisor at (917) 746-4806. CAP is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure Brochure provides information about CAP to assist you in determining whether to retain the Advisor. Additional information about CAP and its Advisory Persons is available on the SEC’s website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310199. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co  Item 2 – Material Changes Cordoba Advisory Partners LLC has the following material changes to report to its disclosure brochure since its last annual updating amendment dated March 29, 2024: CAP does not have anything to report in response to this item. At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Advisor Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310199. You may also request a copy of this Disclosure Brochure at any time by contacting the Advisor at (917) 746-4806. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 2  Item 3 – Table of Contents Item 2 – Material Changes ........................................................................................................................................ 2 Item 3 – Table of Contents ....................................................................................................................................... 3 Item 4 – Advisory Services ...................................................................................................................................... 4 A. Firm Information .......................................................................................................................................................................... 4 B. Advisory Services Offered ........................................................................................................................................................... 4 C. Client Account Management ....................................................................................................................................................... 6 D. Wrap Fee Programs .................................................................................................................................................................... 6 E. Assets Under Management ......................................................................................................................................................... 6 Item 5 – Fees and Compensation ............................................................................................................................ 7 A. Fees for Advisory Services .......................................................................................................................................................... 7 B. Fee Billing .................................................................................................................................................................................... 8 C. Other Fees and Expenses .......................................................................................................................................................... 8 D. Advance Payment of Fees and Termination ................................................................................................................................ 9 E. Compensation for Sales of Securities ......................................................................................................................................... 9 Item 6 – Performance-Based Fees and Side-By-Side Management ..................................................................... 9 Item 7 – Types of Clients ........................................................................................................................................ 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 10 A. Methods of Analysis .................................................................................................................................................................. 10 B. Risk of Loss ............................................................................................................................................................................... 11 Item 9 – Disciplinary Information .......................................................................................................................... 13 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 13 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .................. 13 A. Code of Ethics ........................................................................................................................................................................... 14 B. Personal Trading with Material Interest ..................................................................................................................................... 14 C. Personal Trading in Same Securities as Clients ....................................................................................................................... 14 D. Personal Trading at Same Time as Client ................................................................................................................................. 14 Item 12 – Brokerage Practices ............................................................................................................................... 14 A. Recommendation of Custodian(s) ............................................................................................................................................. 14 B. Aggregating and Allocating Trades ............................................................................................................................................ 15 Item 13 – Review of Accounts ............................................................................................................................... 15 A. Frequency of Reviews ............................................................................................................................................................... 15 B. Causes for Reviews .................................................................................................................................................................. 15 C. Review Reports ......................................................................................................................................................................... 15 Item 14 – Client Referrals and Other Compensation ........................................................................................... 16 A. Compensation Received by CAP .............................................................................................................................................. 16 B. Client Referrals from Solicitors .................................................................................................................................................. 16 Item 15 – Custody ................................................................................................................................................... 16 Item 16 – Investment Discretion ............................................................................................................................ 16 Item 17 – Voting Client Securities ......................................................................................................................... 16 Item 18 – Financial Information ............................................................................................................................. 16 Privacy Policy ....................................................................................................................................................... 18 Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 3  Item 4 – Advisory Services A. Firm Information Cordoba Advisory Partners LLC is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The Advisor was organized as a Limited Liability Company “(LLC”) under the laws of the State of Delaware in September 2020 and became a registered investment advisor in July 2021. CAP is a wholly- owned subsidiary of Cordoba International Holdings, LLC, which is a wholly-owned subsidiary of Qaus Investments LLC. The Principal Officer of CAP is Rami R. Sarafa (Chief Executive Officer and Portfolio Manager). This Disclosure Brochure provides information regarding the qualifications, business practices, and the advisory services provided by CAP. B. Advisory Services Offered CAP offers investment advisory services to high net worth individuals, families, trusts, estates, businesses and private funds (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 and disclose any potential conflicts of interest. CAP'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 CAP provides customized investment advisory solutions for its Clients. This is achieved through continuous personal Client contact and interaction while primarily providing discretionary investment management and related advisory services. CAP works closely with each Client to identify their investment goals and objectives as well as risk tolerance and financial situation in order to create a portfolio strategy. CAP then constructs an investment portfolio, consisting of individual stocks, individual bonds, mutual funds and/or exchange-traded funds (“ETFs”) to achieve the Client’s investment goals. The Advisor will also, as appropriate, utilize options contracts, private funds/limited partnerships, and/or other investment managers to meet the objectives of its Clients. The Advisor may retain certain types of legacy investments for a Client based on their overall fit within a portfolio strategy and/or tax and fiduciary considerations. CAP’s investment strategies are 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. CAP constructs, implements, and monitors the portfolio to meet the goals, objectives, circumstances, and risk tolerance agreed to by each 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. CAP evaluates and selects investments for inclusion in Client portfolios only after applying its internal due diligence process. CAP may recommend, on occasion, redistributing investment allocations to diversify the portfolio. CAP may recommend specific positions to increase sector or asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against market movements. CAP 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. CAP does not maintain physical custody of a Client’s funds or securities, except as described herein. All Client assets will be managed within their designated account(s) at the Custodian, pursuant to the Client investment advisory agreement. Please see Item 12. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 4  Private Investment Vehicles. CAP will, as appropriate, recommend that eligible Clients invest in one or more pooled investment vehicles (which could include special purpose vehicles) whose securities are offered on a private placement basis (“private funds”), including, without limitation, private funds that are sponsored by one or more of CAP’s affiliates. There are numerous risks inherent in investing in private funds, and it is imperative for all prospective investors to read and understand any offering documents (including any private placement memorandum, partnership or operating agreement, and/or subscription documents) relating to such private fund which describe, among other things, the investment program, fees, risk factors, and conflicts of interest associated with an investment in such private fund. With respect to private funds sponsored by CAP’s affiliates, depending on the specific private fund, CAP and/or its affiliates can earn fees (including management fees and/or performance fees) for providing services to such private fund. Although CAP may waive its investment management fee when recommending that a Client invest assets in a proprietary private fund, a conflict of interest nonetheless exists when CAP recommends an investment in a private fund sponsored by any of its affiliates to its Clients because CAP or such affiliates may have the opportunity to earn more compensation as a result of such a recommendation than CAP would otherwise earn by recommending that the Client invest assets in another investment. Use of Independent Managers CAP may recommend that a Client utilize one or more unaffiliated investment managers or investment platforms (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances, the Client may be required to authorize and enter into an advisory agreement with the Independent Manager(s) that defines the terms in which the Independent Manager(s) will provide investment management and related services. The Advisor may also assist in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor will perform initial and ongoing oversight and due diligence over the selected Independent Manager(s) to ensure the Independent Managers’ strategies and target allocations remain aligned with its Clients’ investment objectives and overall best interests. The Client, prior to entering into an agreement with unaffiliated investment manager(s) or investment platform(s), will be provided with the Independent Manager's Form ADV 2A (or a brochure that makes the appropriate disclosures). At no time will CAP accept or maintain physical custody of a Client’s funds or securities and will have only deemed custody 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. Advising private funds CAP provides advisory or sub-advisory services to private funds sponsored by both its affiliates and unaffiliated third parties. CAP receives compensation for services rendered to such private funds as described in the offering documents for such Private funds. A conflict of interest exists when CAP recommends any such private funds to its clients because of the compensation that CAP can earn as a result of advisory services rendered to such private funds. Financial Planning Services CAP 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, and other areas of a Client’s financial situation. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 5  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 program, commence, or alter retirement savings, establish education savings and/or charitable giving programs. CAP 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 pose 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, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. 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. C. Client Account Management Prior to engaging CAP 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 – CAP, in connection with the Client, will develop a strategy that seeks to achieve the Client’s goals and objectives. • Asset Allocation – CAP 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 – CAP will develop a portfolio for the Client that is intended to meet the stated goals and objectives of the Client. • Investment Management and Supervision – CAP will provide investment management and ongoing oversight of the Client’s investment portfolio. D. Wrap Fee Programs CAP does not manage or place Client assets into a wrap fee program. Investment management services are provided directly by CAP. E. Assets Under Management As of December 31, 2024, CAP oversees approximately $2,609,381,208 in assets of which approximately $1,515,898,869 is managed on a discretionary basis, approximately $230,482,339 is managed on a non- discretionary basis, and approximately $863,000,000 are assets under advisement. Clients may request more current information at any time by contacting the Advisor. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 6  Item 5 – Fees and Compensation The following paragraphs detail the fee structure and compensation methodology for services provided by the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one more written agreements with the Advisor. A. Fees for Advisory Services Investment Management Services Investment advisory fees are paid quarterly, at the end of each calendar quarter pursuant to the terms of the investment advisory agreement. Investment advisory fees are based on the average of the ending market value of assets under management at the end of each of the three months during the quarterly billing period. Investment advisory fees range from 0.50% to 1.50% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be managed; and the overall relationship with the Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a higher fee. The investment advisory fee in the first quarter of service is prorated from the inception date of the account(s) to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by CAP will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the Custodian’s valuations. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. For advisory services rendered to private funds, CAP can earn asset-based management fees and/or performance- based compensation as set forth in the offering documents for such private funds. Use of Independent Managers For Client assets allocated to an Independent Manager, the Independent Manager’s fee will vary based on the manager and investment mandate selected. The Advisor’s fee, as noted above, is separate and in addition to the Independent Manager’s fee. Financial Planning Services CAP offers financial planning services either on an hourly basis or a fixed engagement fee. Hourly fees range from $500 to $1,500 per hour. Fixed engagement fees are negotiated based on the expected number of hours to complete the engagement at the Advisor’s hourly rate. Fees may be negotiable based on the nature and complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these services. Data Aggregation and Reporting Services Reporting fees are paid quarterly, at the end of each calendar quarter. Reporting fees are based on the average of the ending market value of reporting assets at the end of each of the three months during the quarterly billing period. Reporting fees range from 0.12% to 0.50% annually based on several factors, including: the scope and complexity of the services to be provided; the level of assets to be reported; and the overall relationship with the Advisor. The reporting fee in the first quarter of service is prorated from the inception date of the account(s) to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and other related costs and expenses described Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 7  in Item 5.C below, which may be incurred by the Client. However, the Advisor shall not receive any portion of these commissions, fees, and costs. B. Fee Billing Investment Management Services Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account(s) at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account(s) following the end of each calendar quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the average of the ending market value of assets under management at the end of each month during the quarterly billing period. The three (3) month-end values are averaged to determine the assets under management for the billing calculation. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by CAP to be paid directly from their account(s) held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers For Clients allocated to an Independent Manager, the Independent Manager’s fee is separately billed and deducted from the Client’s account(s) with the respective manager. Financial Planning Services The timing and frequency of payments for financial planning fixed fee and hourly fee arrangements are as agreed upon with the Clients. Data Aggregation and Reporting Services Reporting fees are calculated by the Advisor or its delegate and deducted from the Client’s account(s) at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account(s) following the end of each calendar quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the average of the ending market value of assets under management at the end of each month during the quarterly billing period. The three (3) month-end values are averaged to determine the assets under management for the billing calculation. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the reporting fee. Clients are urged to also review the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting reporting fees to be deducted by CAP to be paid directly from their account(s) held by the Custodian as part of the reporting agreement and separate account forms provided by the Custodian. C. Other Fees and Expenses Clients may incur certain fees or charges imposed by third parties, other than CAP, in connection with investments made on behalf of the Client’s account(s). The Client is responsible for all custody and securities execution fees charged by the Custodian, as applicable. The Advisor does not recommend a specific Custodian but assists clients with selecting and vetting a Custodian that meets the Client’s needs and facilitates competitive transaction and custody fees. The fees charged by CAP are separate and distinct from all Custodian fees. The fees charged by CAP are separate and distinct from all Custodian fees. In addition, all fees paid to CAP for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 8  other fund expenses, account administration (e.g., custody, brokerage, and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of CAP, but would not receive the services provided by CAP which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund(s) and the fees charged by CAP to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information. D. Advance Payment of Fees and Termination Investment Management Services CAP will be compensated for its investment management services at the end of the quarter after services are rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance written notice to the other party. The Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the average of the ending market value of assets under management at the end of each month during the quarterly billing period. The quarterly billing period will be pro-rated till the point of termination, so the Client only pays for the time in which their advisory agreement was active. The Client’s investment advisory agreement with the Advisor is non-transferable without the Client’s prior consent. Use of Independent Managers In the event that a Client should wish to terminate their relationship with the Independent Manager, the terms for termination will be set forth in the respective agreements between the Client and that Independent Manager. CAP will assist the Client with the termination and transition as appropriate. Financial Planning Services CAP may be partially compensated for its financial planning services in advance of the engagement. Either party may terminate the financial planning agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost to the Client. The Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. Upon termination, the Advisor will promptly refund any unearned, prepaid planning fees. The Client’s financial planning agreement with the Advisor is nontransferable without the Client’s prior consent. Data Aggregation and Reporting Services CAP will be compensated for its reporting services at the end of the quarter after services are rendered. Either party may terminate the reporting agreement, at any time, by providing advance written notice to the other party. The Client will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and payable by the Client. The amount due is calculated by applying the quarterly rate (annual rate divided by 4) to the average of the ending market value of assets under management at the end of each month during the quarterly billing period. The quarterly billing period will be pro-rated till the point of termination, so the Client only pays for the time in which their reporting agreement was active. The Client’s investment advisory agreement with the Advisor is nontransferable without the Client’s prior consent. E. Compensation for Sales of Securities CAP does not buy or sell securities to earn commissions and does not receive any compensation for securities transactions in any Client account, other than the investment advisory fees noted above. Item 6 – Performance-Based Fees and Side-By-Side Management For certain Clients, CAP is eligible to receive a performance fee instead or in addition to its investment management fee based upon any gains obtained in the accounts of “Qualified Clients” (as defined below) pursuant to the terms of an investment management agreement and/or addendum. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 9  The performance fee will be calculated at the close of the applicable measurement period with a clear invoice calculation provided to a Client’s Custodian before fees are deducted. The performance fee charged is generally a percentage of gains in a Client account(s) for the measurement period, subject, in certain circumstances, to a hurdle rate. In such circumstances only gains above the hurdle rate shall be subject to the performance fee. Performance fee structures are negotiable at the discretion of CAP. For certain Clients who invest in private funds, CAP or an affiliate of CAP is generally eligible to receive compensation based on the performance of such private funds which is typically reflected as a percentage of the gains realized upon disposition of investments. Who is a “Qualified Client”? The Investment Advisers Act of 1940 (the “Advisers Act”), Rule 205-3(d)(1) defines a “Qualified Client” who is financially sophisticated and meets one or more of the following conditions: • Client is a natural person who, or a company that, immediately after entering into the contract has at least $1,100,000 under the management of the Advisor; • Client is a natural person who, or a company that, immediately prior to entering into the contract has a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more than $2,200,000 at the time the contract is entered into. The receipt of a performance fee by CAP from certain Clients results in a potential conflict of interest, where the Advisor has the potential for higher compensation from a Client. Qualified Clients that are charged a performance fee may be offered a lower investment advisory fee. CAP does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a hedge fund). Nonetheless, its affiliates sponsor one or more private funds and are eligible to receive compensation in connection with the fund’s investments. Item 7 – Types of Clients CAP offers investment advisory services to high net worth individuals, families, trusts, estates, businesses, and private funds. CAP imposes a minimum relationship size of $1,000,000 in assets under management. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis CAP primarily employs fundamental and technical analysis methods in developing investment strategies for its Clients. Research and analysis from CAP are derived from numerous sources, including financial media companies, third-party research materials, Internet sources, and review of company activities, including annual reports, prospectuses, press releases and research prepared by others. Fundamental analysis utilizes economic and business indicators as investment selection criteria. These criteria consist generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 10  Technical analysis involves the analysis of past market data rather than specific company data in determining the recommendations made to Clients. Technical analysis may involve the use of charts to identify market patterns and trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no guarantee that CAP will be able to accurately predict such a reoccurrence. As noted above, CAP generally employs a long-term investment strategy for its Clients, as consistent with their financial goals. CAP will typically hold all or a portion of a security for more than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, CAP may also buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals of the security, sector, or asset class. B. Risk of Loss Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should be prepared to bear the potential risk of loss. CAP will assist Clients in determining an appropriate strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their investment goals. While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may lose value and may have negative investment performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of Accounts. Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon, tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client participation in this process, including full and accurate disclosure of requested information, is essential for the analysis of a Client's account(s). The Advisor shall rely on the financial and other information provided by the Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or other factors that may affect this analysis. The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process. Following are some of the risks associated with the Advisor’s investment strategies: Market Risks The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall financial markets. Among other things, a Client’s portfolio could be adversely affected from time to time by such matters as changes in general economic, industrial and international conditions, changes in tax laws, prices and cost and other factors of a general nature that are beyond the control of CAP. Geopolitical and other events (e.g., war or terrorism) may disrupt securities markets and adversely affect global economies and markets, thereby decreasing the value of an account’s investments. Sudden or significant changes in the supply or prices of commodities or other economic inputs such as oil may have material and unexpected effects on both global securities markets and individual countries, regions, sectors, companies, or industries, which could significantly reduce the value of an account’s investments. War, terrorism and related geopolitical events have led, and in the future may lead, to increased shortterm market volatility and may have adverse long-term effects on U.S. and world economies and markets generally. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 11  ETF Risks The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bidask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a short time later. Bond ETFs Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e., the risk that bond prices will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the bond. Mutual Fund Risks The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price as a mutual fund purchased later that same day. Options Contracts Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. Margin Borrowings The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory liquidation of the pledged securities to compensate for the decline in value. Alternative Investments (Limited Partnerships) The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An investor could lose all or a portion of their investment. Such investments often have concentrated positions and investments that may carry higher risks. Client should only have a portion of their assets in these investments. Real Estate Investment Trusts (“REITs”) Investing in Real Estate Investment Trusts (“REITs”) involves certain distinct risks in addition to those risks associated with investing in the real estate industry in general. For Example, equity REITs may be affected by changes in the value of the underlying property owned by the REITs, while mortgage REITs may be affected by the quality of credit extended. REITs are subject to heavy cash flow dependency, default by borrowers and selfliquidation. REITs, especially mortgage REITs, are also subject to interest rate risk (i.e., as interest rates rise, the value of the REIT may decline). Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 12  Oil and Gas Interests Investing oil and gas interest whether directly or as part of a fund/ETF involves distinct risks. The price of oil and gas interests may fluctuate to a greater degree than other securities and contain additional risks based on the supply and demand for oil and gas. Some of these additional risks include, the ability to obtain reliable oil and gas supply, oil and gas reserve estimates, the ability to locate markets for oil and gas, fluctuations in prices. The values of oil and gas interests are subject to market risk by a range of variables that could cause trends to differ materially. Investments in Private Funds CAP will recommend that certain Clients invest in privately placed collective investment vehicles (e.g., hedge funds, private equity funds, etc.). The managers of these vehicles have broad discretion in selecting the investments. There are few limitations on the types of securities or other financial instruments which may be traded and no requirement to diversify. Hedge funds may trade on margin or otherwise leverage positions, thereby potentially increasing the risk to the vehicle. In addition, because the vehicles are not registered as investment companies, there is an absence of regulation. There are numerous other risks in investing in these securities. Clients should consult each fund’s private placement memorandum and/or other documents explaining such risks prior to investing. The information and technology systems of CAP and key service providers to CAP and its Clients may be vulnerable to potential damage or interruption from computer viruses; network failures; computer and telecommunication failures; infiltration by unauthorized persons and security breaches; usage errors by their respective professionals; power outages; and catastrophic events such as fires, tornadoes, floods, hurricanes, and earthquakes. Although CAP has implemented various measures designed to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time, or cease to function properly, it may be necessary for CAP to make a significant investment to fix or replace them and to seek to remedy the effect of these issues. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in the operations of CAP or its Clients’ accounts and result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information. Past performance is not a guarantee of future returns. Investing in securities and other investments involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss these risks with the Advisor. Item 9 – Disciplinary Information There are no legal, regulatory, or disciplinary events involving CAP or its management persons. CAP values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 310199. Item 10 – Other Financial Industry Activities and Affiliations As described in more detail in Item 4, various CAP affiliates, including Cordoba Capital, sponsor pooled investment vehicles whose securities are offered on a private placement basis. Such affiliates typically serve as general partner of, managing member of, or in a similar position with such private funds. CAP provides advisory or sub-advisory services to some such Private funds. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 13  A. Code of Ethics CAP has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each Client. This Code applies to all persons associated with CAP (“Supervised Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. CAP and its Supervised Persons owe a duty of loyalty, fairness, and good faith towards each Client. It is the obligation of CAP’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (917) 746-4806. B. Personal Trading with Material Interest CAP allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. CAP does not act as principal in any transactions. In addition, the Advisor does not act as the general partner of a fund, or advise an investment company although its affiliates may sponsor private funds. CAP does not have a material interest in any securities traded in Client accounts. C. Personal Trading in Same Securities as Clients CAP allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public information controls); gifts and entertainment; outside business activities and personal securities reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated by CAP requiring reporting of personal securities trades by its Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public information. D. Personal Trading at Same Time as Client While CAP allows Supervised Persons to purchase or sell the same securities that may be recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no time will CAP, or any Supervised Person of CAP, transact in any security to the detriment of any Client. Item 12 – Brokerage Practices A. Recommendation of Custodian(s) CAP does not have discretionary authority to select the broker-dealer/custodian for custody and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and authorize CAP to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further, CAP does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade basis. Where CAP does not exercise discretion over the selection of the Custodian, it may recommend the Custodian to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by CAP. However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged. CAP may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s offices. Following are additional details regarding the brokerage practices of the Advisor: Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 14  Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor 1. enters into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other services. CAP does not participate in soft dollar programs sponsored or offered by any broker dealer/custodian. Brokerage Referrals - CAP does not receive any compensation from any third party in connection with the 2. recommendation for establishing an account. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where CAP will place or 3. recommend trades within the established account(s) at the Custodian designated by the Client. Further, all Client accounts are traded within their respective account(s). The Advisor will not engage in any principal transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security into one Client account from another Client’s account(s)). CAP will not be obligated to select competitive bids on securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs are determined by the Custodian. B. Aggregating and Allocating Trades The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. CAP will execute its transactions through the Custodian as authorized by the Client. CAP may aggregate orders in a block trade or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually purchased or sold by the close of each business day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts. Item 13 – Review of Accounts A. Frequency of Reviews Securities in Client accounts are monitored on a regular and continuous basis by Advisory Persons of CAP and periodically by its CCO. Formal reviews are generally conducted at least annually or more frequently depending on the needs of the Client. B. Causes for Reviews In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or withdrawals in the Client’s account(s). The Client is encouraged to notify CAP if changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be triggered by material market, economic or political events. C. Review Reports The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage statements will include positions, transactions and fees relating to the Client’s account(s). The Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and performance. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 15  Item 14 – Client Referrals and Other Compensation A. Compensation Received by CAP CAP is a fee-based advisory firm that is compensated solely by its Clients and not from any investment product. CAP does not receive commissions or other compensation from product sponsors, broker-dealers or any un-related third party. CAP may refer Clients to various unaffiliated, non-advisory professionals (e.g., attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise, CAP may receive non-compensated referrals of new Clients from various third-parties. B. Client Referrals from Solicitors CAP does currently pay solicitors for Client referrals. . Item 15 – Custody CAP does not accept or maintain custody of any Client accounts, except for the authorized deduction of the Advisor’s fees and as further described below. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian to retain their funds and securities and direct CAP to utilize that Custodian for the Client’s security transactions. Clients should review statements provided by the Custodian and compare to any reports provided by CAP to ensure accuracy, as the Custodian does not perform this review. For more information about custodians and brokerage practices, see Item 12 – Brokerage Practices. CAP and/or its affiliates serve as general partner of, managing member of, or in another similar position with certain private funds in which CAP Clients invest. As such, CAP is deemed to have custody with respect to the assets invested by its Clients in such private funds. CAP intends to avail itself of the pooled investment vehicle exception found in Rule 206(4)-2 under the Advisers Act from having to obtain an annual surprise examination of client funds and securities over which it is deemed to have custody. Item 16 – Investment Discretion CAP generally has discretion over the selection and amount of securities to be bought or sold in Client accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by CAP. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such authority. All discretionary trades made by CAP will be in accordance with each Client's investment objectives and goals. For non-discretionary accounts, the Advisor will contact the Client and obtain approval prior to executing trades or allocating investment assets. Item 17 – Voting Client Securities CAP does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole responsibility for proxy decisions and voting. Item 18 – Financial Information Neither CAP nor its management, have any adverse financial situations that would reasonably impair the ability of CAP to meet all obligations to its Clients. Neither CAP, nor any of its Advisory Persons, have been subject to a bankruptcy or financial compromise. CAP is not required to deliver a balance sheet along with this Disclosure Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 16  Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or more in the future. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 17  Privacy Policy Effective: April 28, 2022 Our Commitment to You Cordoba Advisory Partners LLC (“CAP” or the “Advisor”) is committed to safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as described here in our Privacy Policy (“Policy”). Our relationship with you is our most important asset. We understand that you have entrusted us with your private information, and we do everything that we can to maintain that trust. CAP (also referred to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and implements controls to ensure that such information is used for proper business purposes in connection with the management or servicing of our relationship with you. CAP does not sell your non-public personal information to anyone. Nor do we provide such information to others except for discrete and reasonable business purposes in connection with the servicing and management of our relationship with you, as discussed below. Details of our approach to privacy and how your personal non-public information is collected and used are set forth in this Policy. Why you need to know? Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose how we collect, share, and protect your personal information. What information do we collect from you? Passport Copy / National ID / Driver’s License Date of birth Social security or taxpayer identification number Assets and liabilities Name, address, and phone number(s) Income and expenses E-mail address[es] Investment activity Account information (including other institutions) Investment experience and goals What Information do we collect from other sources? Custody, brokerage, and advisory agreements Account applications and forms Other advisory agreements and legal documents Transactional information with us or others Investment questionnaires and suitability documents Other information needed to service account How do we protect your information? To safeguard your personal information from unauthorized access and use we maintain physical, procedural, and electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a secure office environment. Our technology vendors provide security and access control over personal information Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 18  and have policies over the transmission of data. Our associates are trained on their responsibilities to protect Client’s personal information. We require third parties that assist in providing our services to you to protect the personal information they receive from us. How do we share your information? An RIA shares Client personal information to effectively implement its services. In the section below, we list some reasons we may share your personal information. Basis For Sharing Do we share? Can you limit? Yes No No Not Shared Yes Yes No Not Shared Servicing our Clients We may share non-public personal information with affiliated and nonaffiliated third parties (such as administrators, brokers, custodians, regulators, credit agencies, other financial institutions) as necessary for us to provide agreed upon services to you, consistent with applicable law, including but not limited to: processing transactions; general account maintenance; responding to regulators or legal investigations; and credit reporting. Marketing Purposes CAP does not disclose, and does not intend to disclose, personal information with non-affiliated third parties to offer you services. Certain laws may give us the right to share your personal information with financial institutions where you are a customer and where CAP or the Client has a formal agreement with the financial institution. We will only share information for purposes of servicing your accounts, not for marketing purposes. Authorized Users Your non-public personal information may be disclosed to you and persons that we believe to be your authorized agent(s) or representative(s). Information About Former Clients CAP does not disclose and does not intend to disclose, non-public personal information to non-affiliated third parties with respect to persons who are no longer our Clients, except as required by law. Changes to our Privacy Policy We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us. Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal information other than as described in this notice unless we first notify you and provide you with an opportunity to prevent the information sharing. Any Questions? You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting us at (917) 746-4806. Cordoba Advisory Partners LLC 488 Madison Avenue, 24th Floor New York, NY 10022 | Phone: (917) 746-4806 https://cordobapartners.co Page 19