AMERICAN ALPHA ADVISORS, LLC

AMERICAN ALPHA ADVISORS, LLC D/B/A DOMANI ADVISORS FIRM BROCHURE – WRAP FEE PROGRAM ITEM 1 COVER PAGE March 27, 2025 AMERICAN ALPHA ADVISORS, LLC D/B/A Domani Advisors 10 West 33rd Street, Suite 802 New York NY, 10001 FIRM CONCTACT: SAM HADDAD, CHIEF COMPLIANCE OFFICER WWW.DOMANIADVISORS.COM FIRM CRD #291796 This wrap brochure provides information about the qualifications and business practices of American Alpha Advisors, LLC. If you have any questions about the contents of this brochure, please contact Sam Haddad at (917) 810-5530 or by email at domani@domaniadvisors.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about American Alpha Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site using a unique identifying number, known as a CRD number. American Alpha Advisors, LLC CRD # is 291796 The use of the term “registered investment advisor,” “registered,” or “registration” does not imply a certain level of skill or training. Registration with the SEC as an investment adviser does not imply that American Alpha Advisors, LLC or any Principals or Employees of American Alpha Advisors, LLC possess a particular level of skill or training in the investment advisory business or any other business. As used in this brochure, the words "we", "our" and "us" refer to AAA and the words "you", "your" and "client" refer to you as either a client or prospective client of our firm. 1  ITEM 2: MATERIAL CHANGES As a registered investment adviser, American Alpha Advisors, LLC dba Domani Advisors (hereinafter, “AAA”) must ensure that the ADV Part 2 is current and accurate and makes full disclosure of all material facts relating to the advisory relationship. AAA will ensure that Clients receive a summary of any material changes and subsequent Brochures within 120 days of the close of our business fiscal year. Furthermore, AAA will provide Clients with other interim disclosures about material changes as necessary. This Item discusses only the material changes that have occurred since Advisor’s last annual update dated March 2024.  Item 4 – Description of Advisory Services The Firm added key descriptions of its advisory services provided to clients with retirement assets- including those with individual retirement accounts and, retirement benefit plan clients. 2  ITEM 3: TABLE OF CONTENTS ITEM 2: MATERIAL CHANGES ......................................................................................................2 ITEM 3: TABLE OF CONTENTS ......................................................................................................3 ITEM 4. ADVISORY BUSINESS .......................................................................................................4 ITEM 5: TYPES OF CLIENTS ...........................................................................................................7 ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION ....................................................7 ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS .....................................16 ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS ..........................................................16 ITEM 9: ADDITIONAL INFORMATION .........................................................................................16 3  ITEM 4. ADVISORY BUSINESS A. Description of Advisory Services American Alpha Advisors, LLC dba Domani Advisors (hereinafter, “AAA”) primarily offers ongoing Investment Management and Reporting Services to Clients. AAA provides advisory services to Clients through individuals registered as investment adviser representatives (“IARs”). AAA is the sponsor of the wrap fee program. Our wrap fee program allows you to pay a single fee that covers advisory services, trade execution, custody and other standard brokerage services. AAA offers ongoing wrap fee portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each Client. AAA creates an Investment Policy Statement for each Client, which outlines the Client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: (cid:127) (cid:127) (cid:127) Determine investment strategy Asset allocation Assessment of risk tolerance (cid:127) (cid:127) (cid:127) Personal investment policy Security selection Ongoing portfolio monitoring AAA evaluates the current investments of each Client with respect to their risk tolerance levels and time horizon. AAA will request discretionary authority from Clients in order to select securities and execute transactions without permission from the Client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each Client. Rollover Recommendations As part of our investment management services, AAA can recommend that Clients withdraw the assets from their employer’s retirement plan and roll the assets over to an individual retirement account (“IRA”) that the Firm will manage on the Client’s behalf. If Clients elect to roll the assets to an IRA that is managed by AAA, the Firm will charge an asset-based fee as set forth in the agreement the Client executed with our Firm. This is a conflict of interest because AAA has an incentive to recommend a rollover for the purpose of generating fee-based compensation rather than solely based on the Client’s needs. Clients are under no obligation to complete the rollover and/or have the assets in an IRA managed by AAA. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes transfer assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, Clients should consider the costs and benefits of: 4  (1) Leaving the assets in their employer’s (or former employer’s) plan; (2) moving the funds to a new employer’s retirement plan; (3) cashing out and taking a taxable distribution from the plan; and/or (4) rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages. Clients should speak with their CPA and/or tax attorney before making a change. AAA’s recommendations can include any of these options, depending on what we determine is in your best interest. The Firm is held to the fiduciary duty standard under the Investment Advisers Act of 1940. Additionally, when AAA provides advice regarding a retirement plan account or an individual retirement account, the Firm is also a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. Pension and Other Retirement Plans AAA provides advisory services to pension plans and retirement plan clients. These advisory services are tailored to the required needs of each client and typically include our investment management services through our Wrap Fee Program. B. Compensation for Advisory Services AAA charges a single asset-based fee for its advisory services covered by the wrap program. AAA’s annual fee for advisory services follows a tiered (blended) fee schedule: Assets Under Management - - - - - - - 1,000,000 2,000,000 10,000,000 20,000,000 50,000,000 100,000,000 200,000,000 0 1,000,000 2,000,000 10,000,000 20,000,000 50,000,000 100,000,000 200,000,000 + Incremental Fee Rate 1.00% 0.80% 0.70% 0.60% 0.50% 0.40% 0.30% 0.20% The advisory fee is calculated by multiplying the incremental fee rate for each range of AUM. AAA bills in arrears and the advisory fee is calculated using the value of the assets on the last business day of the billing period. Tiered fee schedules can be billed based on household market values. 5  AAA generally bills monthly based on the following calculation: Sample Computation ∗ 𝐴𝑈𝑀 𝐴𝑛𝑛𝑢𝑎𝑙 𝐹𝑒𝑒 𝑅𝑎𝑡𝑒 % 12 Fees are negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients can terminate the agreement without penalty for a full refund of AAA’s fees within five business days of signing the Investment Advisory Contract. Thereafter, Clients can terminate the Investment Advisory Contract with 30 days written notice. AAA believes that its advisory fees are reasonable, but the firm’s fees can be more than the cost of purchasing the same or comparable services through other investment advisors. AAA can, in its sole discretion, reduce, waive or calculate differently its fee with respect to certain Clients, including employees or family members. Portfolio management fees are withdrawn directly from the Client’s accounts with Client’s written authorization on a monthly basis. Fees are paid in arrears. AAA uses the value of the account as of the last business day of the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Schwab’s Brokerage Services In addition to the advisory services, the wrap fee program includes certain brokerage services of Schwab Advisor Services, which is part of Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer registered with the Securities and Exchange Commission and a member of FINRA and SIPC. AAA is independently owned and operated and not affiliated with Schwab. Schwab will act solely as a broker-dealer and not as an investment advisor. Schwab will have no discretion over Client accounts and will act solely on instructions it receives from AAA or the Client. Schwab has no responsibility for AAA’s services and undertakes no duty to our Clients to monitor our Firm’s management of accounts or other services we provide. Fees We Pay Schwab The fee Clients pay to AAA for advisory services and wrap fee, allows the Firm to pay for brokerage and execution services provided by Schwab. C. Contributing Cost Factors You can be able to find advisory services and brokerage services elsewhere for a combined fee that is less than what you pay or will pay at AAA. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. D. Additional Fees AAA will wrap third party fees for portfolio management accounts. AAA will charge Client one fee, and pay all transaction fees using the fee collected from the Client. AAA exclusively manages portfolios in a wrap fee program for the purposes of simplicity and transparent pricing. 6  AAA receives the advisory fee stated in Item 4.B (or the Client’s Investment Advisory Agreement) as a management fee under the wrap free program. Our wrap fee does not cover all fees and costs. Certain fees are not included in the wrap fee and are paid for separately by the Client. These include, but are not limited to, margin interest costs, charges imposed directly by a mutual fund or exchange traded fund (i.e., fund management fees and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, deferred sales charges, fees for trades executed away from the Custodian at another broker-dealer, odd- lot differentials, transfer taxes, wire transfer, check fees, electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Conflict of Interest. When managing Client portfolios on a wrap fee basis, the more costs that are incurred for custodial, trading and other administrative costs (including execution and transaction fees), the less profitable it is to our firm. Accordingly, AAA has a conflict of interest because the Firm has a financial incentive to maximize compensation by seeking to reduce or minimize the total costs incurred in your account(s). AAA resolves this conflict of interest by treating every account invested in a particular strategy substantially the same regardless of account size and investing in the Client’s best interest. E. Compensation of Client Participation Neither AAA, nor any representatives of AAA receive any additional compensation beyond advisory fees for the participation of Client’s in the wrap fee program. However, compensation received can be more than what would have been received if Client paid separately for investment advice, brokerage, and other services. Therefore, AAA can have a financial incentive to recommend the wrap fee program to Clients. ITEM 5: TYPES OF CLIENTS AAA offers services for individuals, high net worth individuals, trusts, retirement benefit plans, families and/or small businesses in a family office style. There is no minimum account size. ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION A. Selecting/Reviewing Portfolio Managers AAA will not select outside portfolio managers for management of this wrap fee program; it will be the sole portfolio manager for this wrap fee program. AAA will use industry standards to calculate portfolio manager performance. AAA reviews the performance information to determine and verify its accuracy and compliance with presentation standards. The performance information is reviewed annually by AAA. 7  B. Related Persons AAA and its personnel serve as the portfolio managers for all wrap fee program accounts. This is a conflict of interest in that no outside adviser assesses AAA’s management of the wrap fee program. However, AAA addresses this conflict by acting in its Clients’ best interest consistent with its fiduciary duty as sponsor and portfolio manager of the wrap fee program. C. Advisory Business See Item 4 of this Wrap Fee Program Brochure for information about our wrap fee advisory programs. We offer individualized investment advice to Clients utilizing the services described in Item 4 of this Wrap Fee Program Brochure. Each Client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio D. Services Limited to Specific Types of Investments AAA generally limits its investment advice to mutual funds, ETFs, REITs, bonds, individual stocks, or options to help diversify or hedge a portfolio. E. Client Tailored Services and Client Imposed Restrictions AAA will tailor a program for each individual Client. This will include an interview session to get to know the Client’s specific needs and requirements as well as a plan that will be executed by AAA on behalf of the Client. AAA can use model allocations together with a specific set of recommendations for each Client based on their short-term and long-term objectives, targets, and personal restrictions. Clients are permitted to impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. F. Wrap Fee Programs As discussed herein, AAA sponsors and acts as portfolio manager for this wrap fee program. AAA manages the investments in the wrap fee program, but does not manage those wrap fee accounts any differently than it would manage non-wrap fee accounts. The fees paid to the wrap account program will be given to AAA as a management fee. G. Amounts Under Management Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $ 304,356,000 $0.00 December 31, 2024 H. Performance-Based Fees and Side-By-Side Management AAA does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a Client. 8  I. Methods of Analysis and Investment Strategies Methods of Analysis AAA’s methods of analysis include Fundamental analysis, Quantitative analysis, Technical Analysis, and Cyclical Analysis  Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Fundamental analysis attempts to measure the intrinsic value of a security to determine if the security is underpriced or overpriced.  Quantitative analysis is a technique that seeks to understand behavior by using  mathematical and statistical modeling, measurement and research. Technical analysis involves the analysis of historical chart patterns and past market data, such as, price, volume, money flows and investor behavior.  Cyclical analysis measures the movements of a particular security against the overall stock market in an attempt to understand trends and predict the price movement of the security. Investment Strategies AAA uses long term trading, short term trading, short sales, option trading (including covered options, uncovered options or spread trades) and margin. The primary investment strategy implemented in Client accounts is asset allocation. Based on AAA’s market and economic outlook and Client’s profile, we consider factors such as income needs, risk/return profile, investment time horizon and tax consequences; we diversify investments across different asset classes and investment styles. Investing in securities involves risk of loss that Clients should be prepared to bear. J. Material Risks Involved Methods of Analysis   Fundamental analysis involves risk as the inputs used in the analysis of a security can change suddenly or over time. The security is exposed to the movements of the broader market or the market can fail to reach the expectations of perceived value.  Quantitative analysis involves risk as the investment strategy can act differently than expected as a result of the model. The construction and implementation of the model can be skewed as a result of trends, weight placed on each factor, or technical issues. Technical analysis involves risk as the market will not follow the exact discernible patterns recognized in the past. The market can perform with little or no connection to past patterns and new patterns can emerge over time.  Cyclical analysis involves risk as cycles can invert or disappear either suddenly or over time. General Risk of Loss 9  Investing in securities involves the risk of loss. Clients should be prepared to bear such loss. Investments in securities and other financial instruments and products are subject to many types of risk that can cause the permanent loss of capital as a result of adverse market conditions. General Risks  Currency Risk – fluctuations in “local” market security prices can result if positions are not hedged  Geopolitical Risk – changes in the political status of any country can have profound  effects on the value of securities within that country Liquidity Risk – particular investments can be difficult to sell at the best price at a particular point in time  Market Risk – market prices of securities held can fall rapidly or dramatically due to a variety of unpredictable factors, including changing economic, political or market conditions  Non-Diversification Risk – lack of diversification can result in stronger fluctuations in  market value Sector Risk – companies that are in similar industry sectors can be similarly affected by particular economic or market events  Volatility Risk – higher volatility can result in dramatic changes in security values  Counterparty Risk – risk that either party to a contract will not meet their respective obligations  Credit Risk – issuers of bonds or other debt securities can be unable to meet interest or principal payments when the bonds come due  Credit Quality – lower quality bonds can experience a higher risk of default  Duration – fluctuations in interest rates can have a greater impact on longer duration  assets Inflation Risk – the price of an asset, or the income generated by an asset, can not keep up with the cost of living Interest Rate Risk – changing interest rates affect the value of bonds   Municipal Market Risk – factors unique to the municipal bond market can negatively affect the value of municipal bonds, including risk of payment default and priority in which payments can be made by municipal issuers Mutual Funds and Exchange Traded Funds An investment in a mutual fund or ETF involves risk, including the loss of principal through trading. Mutual fund and ETF shareholders are also subject to the risks stemming from the individual issuers of the fund. Shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains should they sell securities for a profit that cannot be offset by a corresponding loss. 10  Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholder costs (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares can differ significantly from the NAV during periods of market volatility, which can, among other factors, lead to the mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies can cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder can have no way to dispose of such shares. Fund overlap is a situation where an investor invests in several mutual funds with overlapping positions. Fund overlap can be caused by owning several mutual funds or exchange-traded funds (ETFs). Fund overlap reduces the benefits of diversification for the investor. Equity Securities The value of the equity securities held are subject to market risk, including changes in economic conditions, growth rates, profits, interest rates and the market’s perception of these securities. While offering greater potential for long-term growth, equity securities are more volatile and generally carry more risk than some other forms of investment. Option Transactions The purchase or sale of an option involves the payment or receipt of a premium payment and the corresponding right or obligation, as the case could be, to either purchase or sell the underlying investment for a specific price at a certain time or during a certain period. Purchasing options involves the risk that the underlying investment does not change in price in the manner expected, so that the option expires worthless and the investor loses its premium. Selling options, on the other hand, involves potentially greater risk because the investor is exposed to the extent of the actual price movement in the underlying investment in excess of the premium payment received. Market Risks 11  The profitability of a significant portion of the Advisor’s recommendations can depend to a great extent upon correctly assessing the future course of price movements of stocks (either long, or, short positions) and bonds. There can be no assurance that the Advisor will be able to predict those price movements accurately over a sustained period of time. Use of Margin Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account can fall below the brokerage firm’s threshold thereby triggering a margin call. This can force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option can expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. Use of Independent Managers The Advisor can recommend the use of Independent Managers for certain Clients. The Advisor will continue to do ongoing due diligence of such managers, but such recommendations rely, to a great extent, on the Independent Manager’s ability to successfully implement their investment strategy. In addition, the Advisor does not have the ability to supervise the Independent Managers on a day-to-day basis. Use of Private Pooled Investment Vehicles The Advisor can recommend the investment by certain Clients into private pooled investment vehicles (some of which are typically called “hedge funds”). The managers of these vehicles (which can include the Advisor with respect to an affiliated Fund) will have broad discretion in selecting the investments. There are few limitations on the types of securities or other financial instruments which can be traded and no requirement to diversify. The hedge funds can trade on margin or otherwise leverage positions, or utilize short-selling or derivatives, thereby potentially increasing the risk to the vehicle. In addition, there can be restricted liquidity, and because the vehicles are not registered as investment companies, there is an absence of regulation. There are numerous other risks in investing in these private funds. The Client will receive a private placement memorandum and/or other documents explaining such risks. Real estate funds Real Estate Funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in 12  performance. Revenues and cash flows can be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Limited Liquidity of Investments Certain investment funds, including real estate, fixed income, venture capital and closed-end funds, are generally illiquid, with very limited or non-existent transfer and withdrawal rights; investors cannot liquidate or transfer such investments even in an emergency. Fund managers and Independent Managers can invest in securities that trade at a low volume and that are relatively illiquid. These can include, among others, private securities, secured debt securities, real estate, and certain publicly traded equity securities, particularly those with small capitalizations. Managers cannot liquidate these investments promptly if needed. In addition, sales of those securities in an illiquid market could depress their market value. Illiquid securities can include privately placed or “restricted” securities that are subject to substantial holding periods or cannot be traded in public markets. Restricted securities generally are difficult or impossible to sell at prices comparable to the market prices of similar securities that are publicly traded. No assurance can be given that any restricted securities will become registered so as to be eligible to be traded on a public market. Valuation Risks Some investments can be difficult to value, including interests in private funds and other private securities. The managers generally determine the value of such investments in good faith. Any mis-valuation could adversely affect investors, including causing them to pay AAA and the other managers higher fees than they would pay if the valuations were accurate. Multiple Layers of Fees and Expenses In addition to AAA’s management fees, and potential custodian fees, Clients bear the management fees and other expenses charged by mutual funds and private funds in which their accounts are invested. Clients whose accounts are invested with Independent Managers bear the fees of those managers and the other expenses of those accounts. AAA evaluates the fee level of all investments it selects and can have access to lower cost share classes or other lower-cost structures that are not be available to clients investing on their own. However, the multiple layers of fees and expenses can result in a higher cost of investment than would be the case if a Client were to invest directly in those funds, accounts managed 13  by Independent Managers, or securities or other assets in which any of those funds and accounts invest. Cyber Risk AAA’s information and technology systems can be vulnerable to 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. The failures of these systems or the failure of AAA’s Disaster Recovery Plans for any reason could cause significant interruptions in the AAA’s operations and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including private information relating to Clients. Public Health Risk Large-scale outbreaks of infectious disease that can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. Firm personnel work remotely from time to time and have the ability to work remote full- time should any unforeseen public health circumstances arise. Force Majeure AAA shall not be responsible for delays or failures if such delay arises out of causes beyond its control. Such causes can include, but are not restricted to, acts of God, acts of the public enemy, acts or omissions of subcontractors or other third parties, fires, floods, epidemics, riots, quarantine restrictions, strikes, freight embargoes, earthquakes, electrical outages, computer or communications failures, and severe weather. Investing in securities involves risk of loss that Clients should be prepared to bear. K. Material, Significant, or Unusual Risks Certain investment strategies are signal based and utilize market timing techniques and/or leveraged products. Managers often rely on decision making models that, if incorrect, can result in significant losses over a short period of time. AAA is aware of these risks and will only allocate Client assets in a manner that is consistent with the Client’s profile. However, as discussed in Item 4.B and Item 5.A of the ADV Part 2A, Clients can elect to hire and direct AAA solely to invest in certain strategies in a particular weighting. If applicable, AAA will invest Client assets consistent with its fiduciary duty, but will not necessarily be privy to the Client’s overall net worth for the purposes of monitoring the suitability of these investments over time. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a Client, should be prepared to bear. 14  L. Voting Client Securities (Proxy Voting) Client can choose to direct shareholder and proxy voting material to the Advisor on the Custodian’s new account paperwork. If Client authorizes AAA to vote proxies, Client understands that AAA will generally determine how to vote proxies based on reasonable judgment of what would most likely produce favorable financial results for Client and all other clients owning the security. AAA has retained an independent proxy voting service (the “Proxy Service”) to assist in voting proxies in a timely manner. The Proxy Service will maintain records of the AAA’s proxy voting records. AAA shall provide proxy-voting information to Client upon its written or oral request. Copies of AAA’s proxy voting policies are available to Client upon request. Client will maintain exclusive responsibility for all legal proceedings or other type of events relating to their holdings, including but not limited to class action lawsuits. Proxy Voting Policies and Procedures AAA will generally cast proxy votes in favor of proposals that maintain or strengthen the shared interests of the issuer’s shareholders and management, increase shareholder value, maintain or increase shareholder influence over the issuer’s board of directors and management, and maintain or increase the rights of shareholders. AAA will generally cast proxy votes against proposals having the opposite effect. However, AAA will consider both sides of each proxy issue to be voted on. AAA can vote in a manner that is contrary to the general guidelines if it believes that it would be in a client’s best interest to do so. AAA can abstain from voting of proxies if it determines that a client’s interests are best served by abstaining. AAA will not take into account social considerations unless written instructions from Client have been otherwise provided. Client understands that AAA will not vote proxies for restricted securities owned by Client. Conflicts of Interest In the unlikely event that AAA is presented with a material conflict between AAA’s interest and a Client’s interest, AAA will resolve the manner as follows:  If applicable, follow the guidelines presented in AAA’s Proxy Voting Policies and Procedures  AAA will disclose the conflict of interest to the relevant Clients and obtain their consent to the proposed vote. AAA will sufficiently explain the conflict and clearly outline the Clients’ options. If a Client chooses not to respond to AAA’s inquiry, AAA will abstain from voting the proposal. 15   Client can direct AAA to forward the proxy material to an independent third party selected by the Client. AAA will vote the proposal consistent with the independent third party’s recommendation. If the independent third party does not respond in a timely manner, AAA will abstain from voting the Client proposal. More Information Client can request, in writing, information on how proxies for their shares were voted. Client can request a copy of AAA’s Proxy Voting Policies and Procedures free of charge, which will be delivered in a timely manner to the Client. Requests should be made to AAA’s Chief Compliance Officer at (917) 810-5530, or by email to domani@domaniadvisors.com. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS All Client information material to managing the portfolio (including basic information, risk tolerance, sophistication level, and income level) is provided to the portfolio manager. The portfolio manager will also have access to that information as it changes and is updated. ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS AAA does not restrict Clients from contacting portfolio managers. AAA’s representatives can be contacted during regular business hours using the information on the Form ADV Part 2A or ADV Part 2B cover page. ITEM 9: ADDITIONAL INFORMATION A. Disciplinary Action and Other Financial Industry Activities There are no legal or disciplinary events that are material to a client’s or prospective client’s evaluation of this advisory business or the integrity of our management. Other Industry Activities and Affiliations None 16  Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Neither AAA nor its representatives have registration relationships to report. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections AAA does not have sole discretion to select third-party investment advisers on behalf of clients. AAA can direct or introduce Clients to third-party investment advisers to access diversifying strategies. AAA does not accept compensation from third-party advisers. AAA can continue to receive a fee from the Client on those assets as part of the overall advisory fee or as part of the Reporting Service. The Client will pay the third-party adviser the standard fee for services, which will be known to Client at the time of engaging with the third-party adviser. AAA will always act in the best interest of the Client when researching which third-party investment advisers the Client should consider allocation to. AAA has relationships with independent outside advisors (“Signal Providers”) to provide research and signals on select investment strategies or models. AAA can engage or terminate any Signal Provider as it deems appropriate and any fees or compensation to the Signal Provider shall be paid by the Advisor. B. Code of Ethics, Client Referrals, and Financial Information AAA has a written Code of Ethics that covers the following areas: AAA has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. AAA's Code of Ethics is available free upon request to any Client or prospective Client. C. Recommendations Involving Material Financial Interests AAA typically does not have any material financial interest in the securities it recommends to Clients. D. Investing Personal Money in the Same Securities as Clients Representatives and related persons of AAA can buy or sell securities for themselves that they also recommend to Clients. Such transactions can create a conflict of interest if a representative or related person of AAA buys or sells the same security before or after recommending the security to a Client, profiting off the recommendation. AAA does not allow its representatives or related persons to engage in trading that is to a Client’s disadvantage. AAA will document any 17  transactions that could be construed as a conflict of interest. AAA maintains a restricted securities list. Representatives and related persons of AAA must first receive written approval from the CCO before purchasing/selling any restricted security or its derivatives. E. Trading Securities at/around the Same Time as Clients’ Securities Representatives and related persons of AAA can buy or sell securities for themselves that they also recommend to Clients. Such transactions can create a conflict of interest if a representative or related person of AAA buys or sells the same security before or after recommending the security to a Client, profiting off the recommendation. AAA does not allow its representatives or related persons to engage in trading that is to a Client’s disadvantage. AAA will document any transactions that could be construed as a conflict of interest. AAA maintains a restricted securities list. Representatives and related persons of AAA must first receive written approval from the CCO before purchasing/selling any restricted security or its derivatives. F. Frequency and Nature of Periodic Reviews All managed Client accounts are reviewed at least annually by an investment adviser representative to ensure allocations are consistent with the Client’s risk/return profile. G. Factors That Will Trigger a Non-Periodic Review of Client Accounts A non-periodic review of a Client’s accounts can be triggered as a result of material market, economic or political events, or by changes in the Client’s financial situation or goals. Client can request a review of accounts at any time. H. Content and Frequency of Regular Reports Provided to Clients Each Client of AAA with an account will receive a report from the custodian in the form of a statement. Statements are generally delivered monthly, detailing the Client’s account, holdings, asset value, and transactions (including fees). AAA can also deliver consolidated reporting to Clients, either by mail or electronically. Client should carefully compare the reports with the statements they receive from the custodian, market values can differ as a result of calculation methods. I. Economic Benefits Provided by Third Parties for Advice Rendered to Clients AAA does not receive any economic benefit, directly or indirectly from any third party for advice rendered to AAA Clients. However, AAA receives services from Schwab as a result of recommending Schwab as a custodian and broker-dealer for our Client accounts, as described in Item 12 of the Firm’s Form ADV Part 2A Brochure. J. Compensation to Non – Advisory Personnel for Client Referrals AAA does not directly or indirectly compensate non-advisory personnel for Client referrals. 18  K. Balance Sheet AAA neither requires nor solicits prepayment of more than $1,200 in fees per Client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. L. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients AAA does not have any financial condition that would impair its ability to meet contractual commitments to Clients. M. Bankruptcy Petitions in Previous Ten Years AAA has not been the subject of a bankruptcy petition. 19 

AMERICAN ALPHA ADVISORS, LLC D/B/A DOMANI ADVISORS FORM ADV PART 2A – FIRM BROCHURE ITEM 1 COVER PAGE March 27, 2025 AMERICAN ALPHA ADVISORS, LLC D/B/A Domani Advisors 10 West 33rd Street, Suite 802 New York NY, 10001 FIRM CONCTACT: SAM HADDAD, CHIEF COMPLIANCE OFFICER WWW.DOMANIADVISORS.COM FIRM CRD #291796 This brochure provides information about the qualifications and business practices of American Alpha Advisors, LLC. If you have any questions about the contents of this brochure, please contact Sam Haddad at (917) 810-5530 or by email at domani@domaniadvisors.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about American Alpha Advisors, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site using a unique identifying number, is 291796. known as a CRD number. American Alpha Advisors, LLC CRD # The use of the term “registered investment advisor,” “registered,” or “registration” does not imply a certain level of skill or training. Registration with the SEC as an investment adviser does not imply that American Alpha Advisors, LLC or any Principals or Employees of American Alpha Advisors, LLC possess a particular level of skill or training in the investment advisory business or any other business. As used in this brochure, the words "we", "our" and "us" refer to AAA and the words “you", “your" and "client" refer to you as either a client or prospective client of our firm. 1  ITEM 2. MATERIAL CHANGES As a registered investment adviser, American Alpha Advisors, LLC d/b/a Domani Advisors (hereinafter, “AAA” or “the Firm”) must ensure that the ADV Part 2 is current and accurate and makes full disclosure of all material facts relating to the advisory relationship. AAA will ensure that you receive a summary of any material changes and subsequent Brochures within 120 days of the close of our business fiscal year. Furthermore, AAA will provide you with other interim disclosures about material changes as necessary. This Item discusses only the material changes that have occurred since Advisor’s last annual update dated March 2024.  Item 4.B – Description of Advisory Services The Firm added key descriptions of its advisory services provided to clients with retirement assets - including those with individual retirement accounts and retirement benefit plans. 2  ITEM 3. TABLE OF CONTENTS ITEM 2. MATERIAL CHANGES.......................................................................................................2 ITEM 3. TABLE OF CONTENTS ......................................................................................................3 ITEM 4. ADVISORY BUSINESS .......................................................................................................4 ITEM 5. FEES AND COMPENSATION .............................................................................................8 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT ...................................10 ITEM 7. TYPES OF CLIENTS .........................................................................................................10 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS .............................10 ITEM 9. DISCIPLINARY INFORMATION .......................................................................................16 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS ......................................16 ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTERST IN CLIENT TRANSACTIONS AND PERSONAL TRADING..................................................................................................................18 ITEM 12. BROKERAGE PRACTICES ..............................................................................................19 ITEM 13. REVIEW OF ACCOUNTS ...............................................................................................22 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION .......................................................22 ITEM 15. CUSTODY ....................................................................................................................23 ITEM 16. INVESTMENT DISCRETION ..........................................................................................24 ITEM 17. VOTING CLIENT SECURITIES ........................................................................................24 ITEM 18. FINANCIAL INFORMATION ..........................................................................................25 3  ITEM 4. ADVISORY BUSINESS A. Description of Advisory Firm American Alpha Advisors, LLC d/b/a Domani Advisors (hereinafter, “AAA”) is a Limited Liability Company organized in the State of New York in October 2014 and in business as a registered investment adviser since 2017. As of August 2018, the principal owner of AAA is Sam Haddad. AAA’s principal office and place of business is located at: 10 West 33rd Street, Suite 802 New York, NY 10001 Regular business hours are from 9:00 AM to 6:00 PM Monday through Friday. AAA has an additional office located at: 1 Main Street, Suite 401 Eatontown, NJ 07724 Meetings at the Eatontown office are by appointment only. AAA provides Clients with Investment Management and Reporting of investments across different asset classes. B. Description of Advisory Services AAA primarily offers ongoing Investment Management and Reporting Services to Clients. AAA provides advisory services to Clients through individuals registered as investment adviser representatives (“IARs”). AAA offers advisory services based on the individual goals, objectives, time horizon, and risk tolerance of each Client. AAA creates an Investment Policy Statement for each Client, which outlines the Client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: (cid:127) (cid:127) (cid:127) Determine investment strategy Asset allocation Assessment of risk tolerance (cid:127) (cid:127) (cid:127) Personal investment policy Security selection Ongoing portfolio monitoring AAA evaluates the current investments of each Client with respect to their risk tolerance levels and time horizon. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each Client. AAA maintains an institutional relationship with Schwab Advisor Services, part of Charles Schwab & Co., Inc. (“Schwab”) a broker-dealer registered with the Securities and Exchange Commission and a member of FINRA and SIPC, to custody advisory assets. AAA will request discretionary authority from Clients in order to select securities and execute transactions in Client accounts. 4  AAA provides advisory services in accordance with its fiduciary duty and without consideration of AAA’s own economic interest or financial benefit. AAA’s services are designed to assist Clients in meeting their financial goals and objectives using various investments. AAA will conduct periodic meetings with Clients to review portfolio, risk tolerance, financial situation and goals. If a Client undergoes a significant change to his/her financial situation or goals, the Client should notify AAA so that we can consider this information in managing the Client’s investments. Investment Management AAA provides advisory Clients with Investment Management services. AAA utilizes several different investment strategies and will allocate Client assets to one or more strategies on a discretionary basis in a particular proportion. AAA will allocate so that the overall risk/return profile of the Client’s assets across all strategies is suitable to the Client. AAA’s managed portfolios primarily consist of mutual funds, typically institutional share class with the lowest expense ratio available. AAA can use other instruments, such as, ETFs, REITs, bonds, individual stocks, or options to help diversify or hedge a portfolio. In addition to core strategies, AAA offers several other strategies that are based on research and/or signals provided by third-party managers. These strategies can utilize market timing and/or leveraged products. Client will be made aware that these strategies, which require opt- in, have a higher fee (“Strategy Fee”). The Strategy Fee will be disclosed to the Client, either orally or in writing. Due to the unique nature of these strategies, AAA will only allocate Client assets with prior oral or written approval. A Client can elect to hire AAA solely for Investment Management in a particular strategy, in which case he/she will forego the typical holistic advisory services and AAA will not monitor the Client’s overall financial situation. AAA has relationships with independent outside advisors (“Signal Providers”) to provide research and signals on select investment strategies or models. AAA can engage or terminate any Signal Provider as it deems appropriate and any fees or compensation to the Signal Provider shall be paid by the Advisor. Certain strategies have different costs to the Firm associated with them. Some strategies are more profitable to our Firm than others. We eliminate this conflict by acting in your best interest and allocating across strategies consistent with your risk/return profile. Reporting Services Clients can elect to hire AAA to monitor, oversee and report on external managers and investments for a mutually agreed upon fee to be invoiced to the Client. Managers can include third-party advisers, hedge fund managers, private equity managers or any other managing- member of a passive investment. Investments can include passive real estate holdings, hedge fund, private equity or any other passive investment syndication. AAA does not accept compensation from managers of external investments to which we provide Reporting Services. 5  The Reporting Service consists of tracking performance while also documenting contributions, distributions, and income of an external investment. AAA will communicate directly with managers to facilitate the cash management process, receive investment updates and assist with paperwork. Such external investments will be included on the Client’s consolidated net worth report and provided to Clients on a periodic basis either in person, by mail or electronically. Rollover Recommendations As part of our investment management services, AAA can recommend that Clients withdraw the assets from their employer’s retirement plan and roll the assets over to an individual retirement account (“IRA”) that the Firm will manage on the Client’s behalf. If Clients elect to roll the assets to an IRA that is managed by AAA, the Firm will charge an asset-based fee as set forth in the agreement the Client executed with our Firm. This is a conflict of interest because AAA has an incentive to recommend a rollover for the purpose of generating fee-based compensation rather than solely based on the Client’s needs. Clients are under no obligation to complete the rollover and/or have the assets in an IRA managed by AAA. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes transfer assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, Clients should consider the costs and benefits of: (1) Leaving the assets in their employer’s (or former employer’s) plan; (2) moving the funds to a new employer’s retirement plan; (3) cashing out and taking a taxable distribution from the plan; and/or (4) rolling the funds into an IRA rollover account. Each of these options has advantages and disadvantages. Clients should speak with their CPA and/or tax attorney before making a change. AAA’s recommendations can include any of these options, depending on what we determine is in your best interest. The Firm is held to the fiduciary duty standard under the Investment Advisers Act of 1940. Additionally, when AAA provides advice regarding a retirement plan account or an individual retirement account, the Firm is also a fiduciary within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. 6  Pension and Other Retirement Plans AAA provides advisory services to pension plans and retirement plan clients. These advisory services are tailored to the required needs of each client and typically include our investment management services through our Wrap Fee Program. C. Tailoring of Advisory Services and Client Imposed Restrictions Regardless of the services provided, AAA will tailor the services to the individual needs of the Client. AAA will conduct an assessment to understand the risk tolerance, goals, time horizon and financial situation of the individual Client or entity. Clients can request to impose a restriction on discretionary accounts relating to the types of investments or securities, in accordance with his/her beliefs. Since AAA primarily allocates advisory assets in mutual funds, we cannot guarantee that a restricted security is not a position in a mutual fund that is owned by a Client. D. Wrap Fee Program AAA acts as a portfolio manager and sponsor of a wrap free program, which is a program where a Client pays one stated fee that includes advisory fees for portfolio management, transaction costs, and other certain administrative fees. This brochure describes AAA’s general services; Clients should also see AAA’s separate Wrap Free Program Brochure. AAA exclusively manages portfolios in a wrap fee program for the purposes of simplicity and transparent pricing. AAA receives the advisory fee stated in Item 5 (or the Client’s Investment Advisory Agreement) as a management fee under the wrap free program. You can likely find advisory services and brokerage services elsewhere for a combined fee that is less than what you pay or will pay at AAA. The benefits under a wrap fee program depend, in part, upon the size of the account, the costs associated with managing the account, and the frequency or type of securities transactions executed in the account. Conflict of Interest. When managing Client portfolios on a wrap fee basis, the more costs that are incurred for custodial, trading and other administrative costs (including execution and transaction fees), the less profitable it is to our firm. Accordingly, AAA has a conflict of interest because the Firm has a financial incentive to maximize compensation by seeking to reduce or minimize the total costs incurred in your account(s). AAA resolves this conflict of interest by treating every account invested in a particular strategy substantially the same regardless of account size and investing in the Client’s best interest. Additionally, many custodians do not charge commissions or transaction fees for online trades of U.S. exchange-listed equities, U.S. exchange-listed ETFs, and no-transaction-fee (“NTF”) mutual funds. This means that, in most cases, when AAA buys these types of securities, the Firm can do so without paying commissions to the custodian. In order to evaluate whether the cost of AAA’s Wrap Fee Program and Portfolio Management arrangement is appropriate for you, you should compare the agreed-upon Advisory Fee with those amounts that would be charged by other firms. See Item 5 and Item 12 of this brochure. 7  E. Regulatory Assets Under Management Discretionary Amounts: Non-Discretionary Amounts: Date Calculated: $304,356,000 $0.00 December 31, 2024 ITEM 5. FEES AND COMPENSATION A. Compensation for Advisory Services AAA’s annual fee for all of its advisory services described above in Item 4.B, follows a tiered (blended) fee schedule: Assets Under Management - - - - - - - 1,000,000 2,000,000 10,000,000 20,000,000 50,000,000 100,000,000 200,000,000 0 1,000,000 2,000,000 10,000,000 20,000,000 50,000,000 100,000,000 200,000,000 + Incremental Fee Rate 1.00% 0.80% 0.70% 0.60% 0.50% 0.40% 0.30% 0.20% The advisory fee is calculated by multiplying the incremental fee rate for each range of AUM. AAA bills in arrears and the advisory fee is calculated using the value of the assets on the last business day of the billing period. Tiered fee rates can be calculated based on household market values at the discretion of AAA. AAA generally billed monthly based on the following calculation: Sample Computation ∗ 𝐴𝑈𝑀 𝐴𝑛𝑛𝑢𝑎𝑙 𝐹𝑒𝑒 𝑅𝑎𝑡𝑒 % 12 Fees are negotiable and the final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients can terminate the agreement without penalty for a full refund of AAA’s fees within five business days of signing the Investment Advisory Contract. Thereafter, Clients can terminate the Investment Advisory Contract with 30 days written notice. AAA believes that its advisory fees are reasonable, but the AAA’s fees can be more than the cost of purchasing the same or comparable services through other investment advisors. AAA can, in its sole discretion, reduce, waive or calculate differently its fee with respect to certain Clients, including employees or family members. 8  Strategy Fees As discussed in Item 4.B, Clients can elect to hire AAA for Investment Management services or choose to participate in a particular strategy with an associated Strategy Fee. Strategy Fees can vary, but the maximum combined annual fee a Client will pay for advisory fees and/or Strategy Fees is 2.00%. Reporting Services Clients and AAA can agree on a fee for Reporting Services, separate from the advisory fee set forth in the above tiered fee schedule. AAA will monitor, oversee and report on external managers and investments for an agreed upon additional fee as disclosed in the investment management agreement. Payment of Fees AAA deducts advisory fees directly from Client accounts at the end of each billing period. Client provides written authorization to do so in the Investment Advisory Contract and the custodian account opening paperwork. A Client can request to be billed or invoiced for advisory fees. If AAA and Client agree to such an arrangement, AAA will invoice Client at the end of each billing period using an electronic invoice. If applicable, AAA will invoice Client for fees associated with Reporting Services, which are separate from the advisory fee. Other Fees or Expenses Clients utilizing AAA’s Wrap Fee Program should see the separate Wrap Fee Program Brochure for additional details regarding third party fees. All Clients are subject to additional expenses, such as, mutual fund expenses, interest (margin) expense, wire fees and check fees or other fees that are separate and distinct from the fees and expenses associated with AAA. Please see Item 12 of this brochure for more details regarding broker/custodian. Each Client will be responsible for certain charges imposed by unaffiliated third parties and incurred in connection with AAA’s provision of the services, including in the course of the investment of, or arising from the investment or administration of each Client’s assets. B. Prepayment of Fees AAA charges advisory fees in arrears. It does not collect fees in advance. C. Outside Compensation for the Sale of Securities to Clients Neither AAA nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. 9  ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT AAA does not accept performance-based fees. ITEM 7. TYPES OF CLIENTS AAA offers services for individuals, high net worth individuals, trusts, foundations, families and/or small businesses in a family office style. There is no minimum account size. ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES & RISK OF LOSS A. Methods of Analysis and Investment Strategies Methods of Analysis AAA’s methods of analysis include Fundamental analysis, Quantitative analysis, Technical Analysis, and Cyclical Analysis  Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Fundamental analysis attempts to measure the intrinsic value of a security to determine if the security is underpriced or overpriced.  Quantitative analysis is a technique that seeks to understand behavior by using  mathematical and statistical modeling, measurement and research. Technical analysis involves the analysis of historical chart patterns and past market data, such as, price, volume, money flows and investor behavior.  Cyclical analysis measures the movements of a particular security against the overall stock market in an attempt to understand trends and predict the price movement of the security. Investment Strategies AAA uses long term trading, short term trading, short sales, option trading (including covered options, uncovered options or spread trades) and margin. The primary investment strategy implemented in Client accounts is asset allocation. Based on AAA’s market and economic outlook and Client’s profile, we consider factors such as income needs, risk/return profile, investment time horizon and tax consequences; we diversify investments across different asset classes and investment styles. Investing in securities involves risk of loss that Clients should be prepared to bear. 10  B. Material Risks Involved Methods of Analysis   Fundamental analysis involves risk as the inputs used in the analysis of a security can change suddenly or over time. The security is exposed to the movements of the broader market or the market can fail to reach the expectations of perceived value.  Quantitative analysis involves risk as the investment strategy can act differently than expected as a result of the model. The construction and implementation of the model can be skewed as a result of trends, weight placed on each factor, or technical issues. Technical analysis involves risk as the market will not exactly follow the discernible patterns recognized in the past. The market can perform with little or no connection to past patterns and new patterns can emerge over time.  Cyclical analysis involves risk as cycles can invert or disappear either suddenly or over time. Investment Strategies General Risk of Loss Investing in securities involves the risk of loss. Clients should be prepared to bear such loss. Investments in securities and other financial instruments and products are subject to many types of risk that can cause the permanent loss of capital as a result of adverse market conditions. General Risks  Currency Risk – fluctuations in “local” market security prices can result if positions are not hedged  Geopolitical Risk – changes in the political status of any country can have profound  effects on the value of securities within that country Liquidity Risk – particular investments can be difficult to sell at the best price at a particular point in time  Market Risk – market prices of securities held can fall rapidly or dramatically due to a variety of unpredictable factors, including changing economic, political or market conditions  Non-Diversification Risk – lack of diversification can result in stronger fluctuations in  market value Sector Risk – companies that are in similar industry sectors can be similarly affected by particular economic or market events  Volatility Risk – higher volatility can result in dramatic changes in security values  Counterparty Risk – risk that either party to a contract will not meet their respective obligations 11   Credit Risk – issuers of bonds or other debt securities cannot be able to meet interest or principal payments when the bonds come due  Credit Quality – lower quality bonds can experience a higher risk of default  Duration – fluctuations in interest rates can have a greater impact on longer duration  assets Inflation Risk – the price of an asset, or the income generated by an asset, cannot keep up with the cost of living Interest Rate Risk – changing interest rates affect the value of bonds   Municipal Market Risk – factors unique to the municipal bond market can negatively affect the value of municipal bonds, including risk of payment default and priority in which payments can be made by municipal issuers Mutual Funds and Exchange Traded Funds An investment in a mutual fund or ETF involves risk, including the loss of principal through trading. Mutual fund and ETF shareholders are also subject to the risks stemming from the individual issuers of the fund. Shareholders are also liable for taxes on any fund-level capital gains, as mutual funds and ETFs are required by law to distribute capital gains should they sell securities for a profit that cannot be offset by a corresponding loss. Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily per share net asset value (“NAV”), plus any shareholder costs (e.g., sales loads, purchase fees, redemption fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices of a mutual fund’s shares can differ significantly from the NAV during periods of market volatility, which can, among other factors, lead to the mutual fund’s shares trading at a premium or discount to NAV. Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least once daily for indexed-based ETFs and more frequently for actively managed ETFs. However, certain inefficiencies can cause the shares to trade at a premium or discount to their pro rata NAV. There is also no guarantee that an active secondary market for such shares will develop or continue to exist. Generally, an ETF only redeems shares when aggregated as creation units (usually 50,000 shares or more). Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder can have no way to dispose of such shares. Fund overlap is a situation where an investor invests in several mutual funds with overlapping positions. Fund overlap can be caused by owning several mutual funds or 12  exchange-traded funds (ETFs). Fund overlap reduces the benefits of diversification for the investor. Equity Securities The value of the equity securities held are subject to market risk, including changes in economic conditions, growth rates, profits, interest rates and the market’s perception of these securities. While offering greater potential for long-term growth, equity securities are more volatile and generally carry more risk than some other forms of investment. Option Transactions The purchase or sale of an option involves the payment or receipt of a premium payment and the corresponding right or obligation, as the case could be, to either purchase or sell the underlying investment for a specific price at a certain time or during a certain period. Purchasing options involves the risk that the underlying investment does not change in price in the manner expected, so that the option expires worthless and the investor loses its premium. Selling options, on the other hand, involves potentially greater risk because the investor is exposed to the extent of the actual price movement in the underlying investment in excess of the premium payment received. Market Risks The profitability of a significant portion of the Advisor’s recommendations can depend to a great extent upon correctly assessing the future course of price movements of stocks (either long, or, short positions) and bonds. There can be no assurance that the Advisor will be able to predict those price movements accurately over a sustained period of time. Use of Margin Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account can fall below the brokerage firm’s threshold thereby triggering a margin call. This can force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option can expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. 13  Use of Independent Managers The Advisor can recommend the use of Independent Managers for certain Clients. The Advisor will continue to do ongoing due diligence of such managers, but such recommendations rely, to a great extent, on the Independent Manager’s ability to successfully implement their investment strategy. In addition, the Advisor does not have the ability to supervise the Independent Managers on a day-to-day basis. Use of Private Pooled Investment Vehicles The Advisor can recommend the investment by certain Clients into private pooled investment vehicles (some of which can be typically called “hedge funds”). The managers of these vehicles (which can include the Advisor with respect to an affiliated Fund) will have broad discretion in selecting the investments. There are few limitations on the types of securities or other financial instruments which can be traded and no requirement to diversify. The hedge funds can trade on margin or otherwise leverage positions, or utilize short-selling or derivatives, thereby potentially increasing the risk to the vehicle. In addition, there can be restricted liquidity, and because the vehicles are not registered as investment companies, there is an absence of regulation. There are numerous other risks in investing in these private funds. The Client will receive a private placement memorandum and/or other documents explaining such risks. Real estate funds Real Estate Funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows can be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Limited Liquidity of Investments Certain investment funds, including real estate, fixed income, venture capital and closed-end funds, are generally illiquid, with very limited or non-existent transfer and withdrawal rights; investors cannot liquidate or transfer such investments even in an emergency. Fund managers and Independent Managers can invest in securities that trade at a low volume and that are relatively illiquid. These can include, among others, private securities, secured debt securities, real estate, and certain publicly traded equity securities, particularly those with small capitalizations. Managers are not able to liquidate these investments promptly if 14  needed. In addition, sales of those securities in an illiquid market could depress their market value. Illiquid securities can include privately placed or “restricted” securities that are subject to substantial holding periods or unable to be traded in public markets. Restricted securities generally are difficult or impossible to sell at prices comparable to the market prices of similar securities that are publicly traded. No assurance can be given that any restricted securities will become registered so as to be eligible to be traded on a public market. Valuation Risks Some investments are difficult to value, including interests in private funds and other private securities. The managers generally determine the value of such investments in good faith. Any mis-valuation could adversely affect investors, including causing them to pay AAA and the other managers higher fees than they would pay if the valuations were accurate. Multiple Layers of Fees and Expenses In addition to AAA’s management fees, and potential custodian fees, Clients bear the management fees and other expenses charged by mutual funds and private funds in which their accounts are invested. Clients whose accounts are invested with Independent Managers bear the fees of those managers and the other expenses of those accounts. AAA evaluates the fee level of all investments it selects and can have access to lower cost share classes or other lower-cost structures that are not be available to clients investing on their own. However, the multiple layers of fees and expenses can result in a higher cost of investment than would be the case if a Client were to invest directly in those funds, accounts managed by Independent Managers, or securities or other assets in which any of those funds and accounts invest. Cyber Risk AAA’s information and technology systems can be vulnerable to 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. The failures of these systems or the failure of AAA’s Disaster Recovery Plans for any reason could cause significant interruptions in the AAA’s operations and result in a failure to maintain the security, confidentiality or privacy of sensitive data, including private information relating to Clients. Public Health Risk Large-scale outbreaks of infectious disease that can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. 15  Firm personnel work remotely from time to time and have the ability to work remote full- time should any unforeseen public health circumstances arise. Force Majeure AAA shall not be responsible for delays or failures if such delay arises out of causes beyond its control. Such causes can include, but are not restricted to, acts of God, acts of the public enemy, acts or omissions of subcontractors or other third parties, fires, floods, epidemics, riots, quarantine restrictions, strikes, freight embargoes, earthquakes, electrical outages, computer or communications failures, and severe weather. Investing in securities involves risk of loss that Clients should be prepared to bear. C. Material, Significant, or Unusual Risks Certain investment strategies are signal based and utilize market timing techniques and/or leveraged products. Managers often rely on decision making models that, if incorrect, can result in significant losses over a short period of time. AAA is aware of these risks and will only allocate Client assets in a manner that is consistent with the Client’s profile. However, as discussed in Item 4.B and Item 5.A, Clients can elect to hire and direct AAA solely to invest in certain strategies in a particular weighting. If applicable, AAA will invest Client assets consistent with its fiduciary duty, but will not necessarily be privy to the Client’s overall net worth for the purposes of monitoring the suitability of these investments over time. ITEM 9. DISCIPLINARY INFORMATION AAA has no criminal or civil actions to report, no administrative proceedings to report and no self-regulatory organization (SRO) proceedings to report. ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS A. Registration as a Broker/Deal or Broker/Deal Representatives Neither AAA nor its representatives are reregistered as, or have pending application to become, a broker/deal or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither AAA nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. 16  C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interest Neither AAA nor its representatives have registration relationships to report. D. Selection of Other Advisers or Managers and Adviser Compensation AAA does not have sole discretion to select third-party investment advisers on behalf of clients. AAA can direct or introduce Clients to third-party investment advisers to access diversifying strategies. AAA does not accept compensation from third-party advisers. AAA can continue to receive a fee from the Client on those assets as part of the overall advisory fee or as part of the Reporting Service. The Client will pay the third-party adviser the standard fee for services, which will be known to Client at the time of engaging with the third-party adviser. AAA will always act in the best interest of the Client when researching which third-party investment advisers the Client should consider allocation to. AAA has relationships with independent outside advisors (“Signal Providers”) to provide research and signals on select investment strategies or models. AAA can engage or terminate any Signal Provider as it deems appropriate and any fees or compensation to the Signal Provider shall be paid by the Advisor. 17  ITEM 11. CODE OF ETHICS, PARTICIPATION OR INTERST IN CLIENT TRANSACTIONS AND PERSONAL TRADING A. Code of Ethics AAA has a written Code of Ethics that covers the following areas: AAA has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. AAA's Code of Ethics is available free upon request to any Client or prospective Client. B. Recommendations Involving Material Financial Interests AAA typically does not have any material financial interest in the securities it recommends to Clients. C. Investing Personal Money in the Same Securities as Clients Representatives and related persons of AAA can buy or sell securities for themselves that they also recommend to Clients. Such transactions can create a conflict of interest if a representative or related person of AAA buys or sells the same security before or after recommending the security to a Client, profiting off the recommendation. AAA does not allow its representatives or related persons to engage in trading that is to a Client’s disadvantage. AAA will document any transactions that could be construed as a conflict of interest. AAA maintains a restricted securities list. Representatives and related persons of AAA must first receive written approval from the CCO before purchasing/selling any restricted security or its derivatives. D. Trading Securities at/around the Same Time as Clients’ Securities Representatives and related persons of AAA can buy or sell securities for themselves that they also recommend to Clients. Such transactions can create a conflict of interest if a representative or related person of AAA buys or sells the same security before or after recommending the security to a Client, profiting off the recommendation. AAA does not allow its representatives or related persons to engage in trading that is to a Client’s disadvantage. AAA will document any transactions that could be construed as a conflict of interest. AAA maintains a restricted securities list. Representatives and related persons of AAA must first receive written approval from the CCO before purchasing/selling any restricted security or its derivatives. 18  ITEM 12. BROKERAGE PRACTICES AAA manages Clients’ assets in accounts held at a qualified custodian. AAA recommends the brokerage and custodial services of Schwab Advisor Services (“Custodian”), member SIPC, a subsidiary of Charles Schwab & Co. We are independently owned and operated and are not affiliated with Schwab. A. How We Select Custodians/Broker-dealers AAA recommends a custodian/broker-dealer that will hold your assets and execute transactions on terms that are, overall, the most favorable compared to other available custodians. AAA considers various factors, such as:  Ability to buy and sell securities for your account  Trade execution, including “best execution”  Investment research and tools  Quality of services  Reputation, financial strength and stability  Relationship with our firm and our clients  Overall client experience AAA is not required to select the broker-dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although AAA is not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is consistent with our duty to seek “best execution” of Client trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see “How We Select Custodians/Broker-dealers”). Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like AAA. Schwab provides AAA and its Clients with access to institutional brokerage services (trading, custody, reporting, and related services). Schwab also makes available various support services. Some of those services help AAA manage or administer Clients’ accounts, while others help AAA manage and grow its business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to AAA. Following is a more detailed description of Schwab’s support services: Services that Benefit You Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. Schwab makes certain investment products available to AAA which we might not otherwise have access to or that would require a significantly higher minimum investment. 19  Services that Do Not Directly Benefit You Schwab makes available to AAA products and services that benefit the Firm but do not directly benefit you as a Client. These products and services assist us in managing and administering our Clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. In addition to investment research, Schwab also makes available software and other technology that: Provides access to client account data and records Facilitates trade execution and allocate aggregated trade orders Provides pricing and other market data Facilitates payment of our fees from our Clients’ accounts      Assists with back-office functions, recordkeeping, and client reporting Services that Generally Benefit Only Us Schwab offers services intended to help AAA manage and further develop its business. These services include: Educational conferences and events Technology, compliance, legal and business consulting Publications and conferences on practice management and business succession     Access to employee benefit providers, human capital consultants and insurance providers Schwab can provide some of these services itself or arrange for third-party vendors to provide the services to AAA. Schwab can discount or waive its fees for some of these services or pay all or a part of a third party’s fees. In conducting its business relationship with AAA, Schwab can provide benefits to firm personnel through occasional entertainment. Our Interest in Schwab’s Services The availability of these services from Schwab benefits AAA because we do not have to produce or purchase them. The fact that AAA receives these benefits from Schwab is an incentive for AAA to recommend the use of Schwab rather than consider the custodian most suitable for each specific Client situation. This is a conflict of interest. We believe, however, that taken in the aggregate, AAA’s recommendation of Schwab as custodian and broker-dealer is in the best interests of its Clients. AAA’s selection is primarily supported by the scope, quality, and price of Schwab’s services described above. 1. Research and Other Soft-Dollar Benefits While AAA has no formal soft dollars program in which soft dollars are used to pay for third party services, AAA can receive research, products, or other services from custodians and broker- dealers in connection with Client securities transactions (“soft dollar benefits”). 20  2. Brokerage for Client Referrals AAA receives no referrals from a broker-dealer or third party in exchange for using that broker- dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use AAA can permit Clients to direct it to execute transactions through a specified broker-dealer. If a Client directs brokerage, then the Client will be required to acknowledge in writing that the Client’s direction with respect to the use of brokers supersedes any authority granted to AAA to select brokers; this direction can result in higher commissions, which will result in a disparity between free and directed accounts; the Client can be unable to participate in block trades (unless AAA is able to engage in “step outs”); and trades for the Client and other directed accounts can be executed after trades for free accounts, which can result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their Clients to direct brokerage. Schwab charges Clients a fee as a “prime broker” for trade away for each trade that we have executed by a different broker dealer but where the securities or the funds from the securities sold are deposited (settled) into the Client’s Schwab account. These fees are in addition to the commissions or other compensation paid to the executing broker-dealer. Because of this, in order to minimize trading costs, AAA has selected Schwab to execute most trades. B. Aggregating (Block) Trading for Multiple Client Accounts If AAA buys or sells the same securities on behalf of more than one Client, then it can (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple Clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, AAA would place an aggregate order with the broker on behalf of all such Clients in order to ensure fairness for all Clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. AAA would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). 21  ITEM 13. REVIEW OF ACCOUNTS A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All managed Client accounts are reviewed at least annually by an investment adviser representative to ensure allocations are consistent with the Client’s risk/return profile. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts A non-periodic review of a Client’s accounts can be triggered as a result of material market, economic or political events, or by changes in the Client’s financial situation or goals. Client can request a review of accounts at any time. C. Content and Frequency of Regular Reports Provided to Clients Each Client of AAA with an account will receive a report from the custodian in the form of a statement. Statements are generally delivered monthly, detailing the Client’s account, holdings, asset value, and transactions (including fees). AAA can also deliver consolidated reporting to Clients, either by mail or electronically. Client should carefully compare the reports with the statements they receive from the custodian, market values can differ as a result of calculation methods. ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) AAA does not receive any economic benefit, directly or indirectly from any third party for advice rendered to AAA Clients. However, AAA receives services from Schwab as a result of recommending Schwab as a custodian and broker-dealer for our Client accounts, as described in Item 12. B. Compensation to Non-Advisory Personnel for Client Referrals AAA does not directly or indirectly compensate non-advisory personnel for Client referrals. 22  ITEM 15. CUSTODY AAA deducts advisory fees directly from Client accounts at the custodian. AAA will be deemed to have limited custody of Client’s assets. AAA can only debit fees from Client accounts with written authorization. Client will receive account statements directly from the custodian at least quarterly, typically monthly. AAA urges Clients to carefully review the statements they receive from the custodian for accuracy. AAA’s Client accounts will be held in custody by unaffiliated qualified custodians. AAA will not have physical custody of any Client assets. AAA generally will not have custody of the assets of its Clients, since it will not have the authority to hold, directly or indirectly, such Clients’ funds or securities or have the authority to obtain possession of them. Standing Letters of Authorization Our firm, or persons associated with our firm, can process wire transfers, ACH payments, journals or check disbursements from Client accounts to one or more third parties designated, in writing, by the Client without obtaining written Client consent for each separate, individual transaction. Such written authorization is known as a Standing Letter of Authorization (“SLOA”). An adviser with authority to conduct such third-party transfers has access to the Client's assets, and therefore has custody of the Client's assets in any related accounts. However, we do not have to obtain a surprise annual audit, as we otherwise would be required to by reason of having custody, as long as we meet the following criteria outlined in the SEC’s no-action letter on February 21, 2017 which includes (in summary):        client will provide instruction for the SLOA to the custodian; client will authorize the Firm to direct transfers to the specific third party; the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; the client will have the ability to terminate or change the instruction; the Firm will have no authority or ability to designate or change the identity or any information about the third party; the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and the custodian will send the client an initial and annual notice confirming the SLOA instructions. 23  ITEM 16. INVESTMENT DISCRETION AAA manages Client assets on a discretionary and non-discretionary basis. Both the standard Investment Advisory Agreement and Client account agreement grant AAA discretionary authority over Client accounts. Where investment discretion has been granted, AAA will trade securities and make investment decisions without consultation with the Client. The choice of security, direction (buy/sell), quantity, market value and order type are determined solely by AAA. Client can impose reasonable restrictions on AAA’s discretionary authority or investment approach, which should be provided by the Client to AAA in writing. AAA will always managed Client assets consistent with the investment objectives of the Client. AAA can provide non-discretionary investment management services with respect to each Client’s investable assets. AAA will work with each Client to develop investment guidelines based on the Client’s investment objectives, risk tolerance, and other factors. AAA will make recommendations to each Client with respect to asset allocation and the investment and reinvestment of the Client’s assets, but shall purchase or sell securities or other financial instruments for each Client’s account only upon the Client’s authorization. ITEM 17. VOTING CLIENT SECURITIES Client can choose to direct shareholder and proxy voting material to the Advisor on the Custodian’s new account paperwork. If Client authorizes AAA to vote proxies, Client understands that AAA will generally determine how to vote proxies based on reasonable judgment of what would most likely produce favorable financial results for Client and all other clients owning the security. AAA has retained an independent proxy voting service (the “Proxy Service”) to assist in voting proxies in a timely manner. The Proxy Service will maintain records of the AAA’s proxy voting records. AAA shall provide proxy-voting information to Client upon its written or oral request. Copies of AAA’s proxy voting policies are available to Client upon request. Client will maintain exclusive responsibility for all legal proceedings or other type of events relating to their holdings, including but not limited to class action lawsuits. Proxy Voting Policies and Procedures AAA will generally cast proxy votes in favor of proposals that maintain or strengthen the shared interests of the issuer’s shareholders and management, increase shareholder value, maintain or increase shareholder influence over the issuer’s board of directors and management, and maintain or increase the rights of shareholders. AAA will generally cast proxy votes against proposals having the opposite effect. However, AAA will consider both sides of each proxy issue 24  to be voted on. AAA can vote in a manner that is contrary to the general guidelines if it believes that it would be in a client’s best interest to do so. AAA can abstain from voting of proxies if it determines that a client’s interests are best served by abstaining. AAA will not take into account social considerations unless written instructions from Client have been otherwise provided. Client understands that AAA will not vote proxies for restricted securities owned by Client. Conflicts of Interest In the unlikely event that AAA is presented with a material conflict between AAA’s interest and a Client’s interest, AAA will resolve the manner as follows:  If applicable, follow the guidelines presented in AAA’s Proxy Voting Policies and Procedures  AAA will disclose the conflict of interest to the relevant Clients and obtain their consent to the proposed vote. AAA will sufficiently explain the conflict and clearly outline the Clients’ options. If a Client chooses not to respond to AAA’s inquiry, AAA will abstain from voting the proposal.  Client can direct AAA to forward the proxy material to an independent third party selected by the Client. AAA will vote the proposal consistent with the independent third party’s recommendation. If the independent third party does not respond in a timely manner, AAA will abstain from voting the Client proposal. More Information Client can request, in writing, information on how proxies for their shares were voted. Client can request a copy of AAA’s Proxy Voting Policies and Procedures free of charge, which will be delivered in a timely manner to the Client. Requests should be made to AAA’s Chief Compliance Officer at (917) 810-5530, or by email to domani@domaniadvisors.com. ITEM 18. FINANCIAL INFORMATION AAA is not required to provide financial information to Clients because:  AAA does not require or solicit prepayment of more than $1,200 in fees per Client, six months or more in advance.  AAA nor its management has any financial conditions that is likely to reasonable impair AAA’s ability to meet contractual commitments to Clients.  AAA has not been the subject of a bankruptcy petition in the last ten years. 25