GLOBAL VIEW CAPITAL MANAGEMENT LLC

Version date: March 13, 2025 Form ADV-Part 2A - Disclosure Brochure www.gvcmanagement.com N1423833 Stone Ridge Drive, Suite 350 Waukesha, WI 53188 262.650.1030 (Phone) 262.650.1085 (Fax) Introduction SEC File No. 801-72887 This brochure provides information about the qualifications and business practices of Global View Capital Management LLC. (“GVCM”). If you have any questions about the contents of this brochure, please contact GVCM’s Compliance Department at 262-650-1030 or via email at compliance@gvcaponline.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about GVCM also is available on the SEC’s website at www.adviserinfo.sec.gov. Item 2 - Material Changes GVCM’s last annual update was February 21, 2024. GVCM has the following material changes to report. Material changes relate to GVCM’s policies, practices, or conflicts of interest. • GVCM disclosed that it has custody due to Standing Letters of Authorization. (Item 15) Item 3 - Table of Contents Item 4 - Advisory Business Page 2 Item 5 - Fees and Compensation Page 4 Item 6 - Additional Fee Considerations Page 7 Item 7 - Types of Clients Page 7 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Page 8 Item 9 - Disciplinary Information Page 10 Item 10 - Other Financial Industry Activities and Affiliations Page 10 Item 11 - Code of Ethics Page 12 Item 12 - Brokerage Practices Page 12 Item 13 - Review of Accounts Page 13 Item 14 - Client Referrals and Other Compensation Page 14 Item 15 - Custody of Client Assets Page 14 Item 16 - Investment Discretion Page 14 Item 17 - Voting Client Securities Item 18 - Financial Information Page 15 Page 15 Page 1  Item 4 - Advisory Business GVCM is a corporation organized under Wisconsin state law. Dina Fliss founded the Waukesha County based investment adviser in 2011. The firm is a wholly- owned subsidiary of Global View Capital Partners, LTD. (“GVCP”), which is owned by Dina Fliss and Dean Fliss. GVCM is a SEC registered investment adviser. Registration as an investment adviser does not imply any level of skill or training. As of December 31, 2024, GVCM had $707,976,833 of discretionary assets under management. GVCM does not perform accounting, legal, tax, mortgage or other financial services, nor does it have direct or indirect custody of client assets. Investment Advisory Representatives (“IAR”) of GVCM may have properly disclosed outside business activities where they act in the capacity of an accountant, attorney, insurance agent, registered representative or mortgage broker. This may present a conflict of interest. The investment advisory services of GVCM are described in detail below. Investment Advisory Services GVCM serves as an investment adviser to clients under individual investment management agreements. GVCM requires clients to complete a suitability questionnaire as part of its investment process. This questionnaire establishes the client’s relative risk profile (conservative, moderate, balanced, growth or aggressive) and investment time horizon which guides the selection of strategies for the client’s account. Additionally, clients may impose restrictions that may affect the ability of GVCM to manage the client’s assets. There are no differences between GVCM’s management of wrap-fee accounts and management of other accounts, other than the variety of the strategies available and the underlying product’s or platform’s fee structure. GVCM receives a portion of the wrap fee for its services. Sub-Advisor to Flexible Plan Investments, Ltd. We provide investment advisory services as a sub-advisor to Flexible Plan Investments, Ltd. (“FPI”). FPI is a federally-registered investment adviser which sponsors the Strategic Solutions Program (the “Program”). Model portfolios are designed to meet various investment objectives. These model portfolios are actively managed and are offered through the Program. GVCM manages models to specific objectives rather than to the individual needs of clients. The IARs that monitor the client accounts and utilize GVCM’s services match the suitability of the strategies to their clients’ personal financial situation through the use of a suitability questionnaire. Restrictions on investing may preclude an IAR from choosing our models for their clients’ portfolios. Sponsor of the Personalized Managed Account Program GVCM sponsors the Personalized Managed Account Program (the “Program”), which includes Separately Managed Accounts (SMAs), Exchange Traded Funds (ETFs), Mutual Funds and discretionary asset management advised by GVCM and a selection of unrelated third-party asset managers and sub-advisors. The program is comprised of two different pricing schedules: Asset Based and Transaction Based. It should be noted that differences exist in both the product solutions available and the fees and expenses charged to the client dependent on the pricing schedule and custodian selected by the IAR. Strategies in the Program are managed to specific objectives rather than to the individual needs of clients. The IARs that monitor the accounts and utilize our services and that of the unrelated third-party asset managers match the suitability of the strategies to their clients’ personal financial situation through the use of a suitability questionnaire. Client restrictions on investing may preclude an IAR from choosing any of the Program models for their clients’ portfolios. Page 2  In the event that account values fall below the minimum account value needed to effectively execute trades in client accounts, the account may: 1) not trade until additional funds are added by the client; or 2) GVCM may choose to discontinue its advisory agreement with the client. IARs of GVCM who are also associates of Global View Capital Advisors LLC. (“GVCA”) may recommend the Program to suitable clients and act as the client’s Financial Advisor for the Program. GVCA is an affiliated company of GVCM. GVCA is a marketing company that provides distribution services designed by GVCM and other third party asset managers. More complete information about the Program may be found in the GVCM Personalized Managed Account Program Brochure (“Program Brochure”) which is available upon request. Low Cost Program GVCM will offer a low cost program that will include commission free ETF’s and MF’s. No strategies will be available, and the client has the option to build your own option from screened ETF’s. There is no account maximum for this service. Nationwide Advisory Solutions Monument Advisor Variable Annuity The strategies on the Nationwide Advisory Solutions Monument Advisor Variable Annuity platform are managed to specific objectives rather than to the individual needs of clients. The IARs that monitor the client accounts and utilize GVCM’s services match the suitability of the strategies to their clients’ personal financial situation through the use of a suitability questionnaire. Client restrictions on investing may preclude an IAR from choosing any of GVCM’s proprietary models for their clients’ portfolios. Employer-Sponsored Retirement Plans Schwab Personal Choice Retirement Account A PCRA is a self-directed brokerage account that resides within an employer- sponsored retirement plan. In addition to the choices typically offered by retirement plans, PCRA allows the participant to invest in a much wider range of investments. The strategies offered as part of the Schwab PCRAs are managed to specific objectives rather than to the individual needs of participants. The IARs that monitor the participant accounts and utilize GVCM’s services match the suitability of the strategies to their clients’ personal financial situation through the use of a suitability questionnaire. ETF’s and mutual funds are available and Client restrictions on investing may preclude an IAR from choosing any of GVCM’s proprietary models for their clients’ portfolios. American Trust/First Mercantile Trust GVCM is a sub-advisor to American Trust/First Mercantile Trust. The strategies offered in the American Trust/First Mercantile Trust employer- sponsored retirement plans are managed to specific objectives rather than to the individual needs of participants. Participants in the employer-sponsored retirement plan determine their risk tolerance and then may select and manage their own investments or rely upon the managed portfolio options available. Heartland Retirement Plan Services GVCM is a sub-advisor to Heartland Retirement Plan Services in employer- sponsored retirement plans administrated by Heartland Retirement Plan Services. The strategies offered in the Heartland Plan Services employer- sponsored retirement plans are managed to specific objectives rather than to the individual needs of participants. Participants in the employer-sponsored retirement plan determine their risk tolerance and then may select and manage their own investments or rely upon the managed portfolio options available. Sub-Advisor to Harness Investment Management GVCM is a sub-advisor to Harness Investment Management, a Canadian asset manager. GVCM manages available strategies to specific objectives rather than to the individual needs of clients. These strategies are available only in Canada. Page 3  Solicitors to Unaffiliated Third-Party Investment Advisers GVCM and its IARs may act as a solicitor and refer clients to third-party investment advisers that offer asset management services to clients. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • • • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Item 5 - Fees and Compensation GVCM is compensated for advisory services through advisory or financial planning fees charged to the client. Mutual fund companies, ETFs, variable life insurance, and variable annuities charge internally imbedded fees and expenses for their products. These fees and expenses are in addition to any advisory fees charged by GVCM. Complete details of these internally imbedded fees and expenses are explained in the prospectuses for each investment. Clients are strongly encouraged to read these explanations before investing any money. Clients should ask GVCM, or their IAR any questions that they have about fees and expenses. Mutual funds shares held in accounts at brokerage firms may pay internally embedded fees that are different from other class shares held directly at the mutual fund company. While clients may purchase shares of mutual funds directly from the mutual fund company without an advisory fee, those direct investments are not considered part of GVCM’s advisory relationship with the client. To wit, these investments would not be included in GVCM’s investment strategies, investment performance monitoring, or portfolio reallocations. Please be sure to read the section entitled “Item 12-Brokerage Practices” which follows later in this brochure. The client pays GVCM advisory fees in arrears of receiving services. Clients may terminate their advisory agreement within five (5) business days from the date the agreement is executed, without penalty, by providing written notice to GVCM. Should any party to the agreement terminate the agreement before the end of a billing period, any fees that GVCM has earned are immediately due and payable, where any unearned fees will be refunded on a pro-rata basis. Fees collected for a financial plan or annual plan review are not refundable after delivery of the plan and acceptance by the client. Broker-dealers and other financial institutions that hold client accounts are referred to as custodians (“custodian/broker- dealer”). The custodian/broker-dealer determines the values of the assets in the portfolio and provides the client with statements that show the amount paid for advisory services. The client should review and verify the calculation of the GVCM fees. The custodian/broker-dealer does not verify the accuracy of fee calculations. In addition to the advisory fee, the client may be required to pay other applicable charges such as: custodial fees, SEC fees, internal fees and expenses charged by mutual funds, ETFs, or variable annuity/variable life sub-accounts, and taxes on securities transactions. Cash can be used as a strategic holding for an indefinite period depending on market conditions and will be billed on as an asset class. Page 4  Flexible Plan Investments, Ltd. (FPI) Fees All fees are computed monthly in arrears at a rate equal to one twelfth of the annual fee percentage multiplied by the billable balance. Billable balance means the value of the assets in the investment account as of the last day of the relevant month. Fees will be paid from the account to GVCM by the custodian after written authorization from the client. Fees for the initial month are prorated based upon the number of calendar days in the calendar month that the agreement isin effect. Thereafter, the GVCM fee is calculated based upon the billable balance of the assets in the client’s account at the end of each calendar month. Fee Schedule Assets Under Management Up to $500,000 $500,001 - $999,999 $1,000,000 and Above Advisory Fee 1.00% 0.75% 0.50% Advisory fees are shared by GVCM and FPI. All fees are negotiable at GVCM’s sole discretion. Up to 20 basis points may be credited back to the account depending upon the use of the Quantified mutual funds that are sub-advised by FPI for the portfolios. Advisory fees noted in the above schedules do not include the fee paid to IARs. Annual fees paid to an IAR cannot exceed 1.60%. Accounts under $15,000 will be charged a non-refundable account set up fee in an amount lesser of 3% of the initial balance of the account or $350. The account set-up fee may be paid by check or from the client account after establishment of the account. Personalized Managed Account Program As part of its Personalized Managed Account Program, GVCM offers both Asset-Based and Transaction-Based product solutions. The minimum amount of assets required to be invested in each account will vary depending on the investment model, sub-advisor, strategy, mutual fund, ETF, custodian and/or pricing option selected. These minimum asset levels are set forth in the Program Brochure. Should the market value of an account fall below the stated required minimum due to withdrawals or market performance, the IAR or GVCM may require that either additional money be deposited to bring the account value up to the required minimum or that the account be closed. Client should be aware that certain contributions or withdrawals to an Individual Retirement Account (“IRA’) might have adverse tax consequences, which should be discussed with client’s independent tax advisor or legal professional. The wrap-fee the client pays for this program includes advisory, management, transaction or custodial fees for GVCM’s strategies and/or other third-party asset managers, mutual funds and ETFs in the Program. In addition to GVCM’s wrap fee, the client may be required to pay other charges such as internal fees and expenses charged by mutual funds (12b-1), ETFs, variable annuities, variable life insurance, IRA fees, special custodial services, and taxes on transactions in non-qualified brokerage accounts. Personalized Managed Account Program Asset-Based Fee Schedule Assets Under Management $15,000 and Above Advisory Fee 1.00% Program fees are computed on a monthly basis in arrears for services provided by GVCM and the IAR and other third party sub-advisors (the “Program Fee”). The advisory fee paid to the IAR is negotiable; the platform fee is not. The annual advisory fee paid to GVCM in the asset based fee schedule cannot exceed 1.0%; the annual fee paid to the IAR cannot exceed 1.4%. Total program cost cannot exceed 2.4%. Monthly program fees are calculated on the average daily balance of the account during the previous month, as determined by the custodian. The fee is calculated on the first day of the calendar month by multiplying the average daily balance of the account from the previous month by the annual total program fee, multiplied by the actual number of days in the month divided by the number of days in the year. The monthly program fee will be deducted from client’s account on or about the fifth business day after the commencement of each month. Accounts in the same household may be aggregated for the purposes of determining the applicable Program fee Page 5  rate. The program fee also covers fees charged by custodians except for accounts less than $15,000 or in the Transaction-Based Fee Program, where brokerage commissions and ticket charges may apply. Best efforts are made by GVCM to use commission free funds. The initial Program fee will be charged on the date the agreement is accepted by GVCM (the “Effective Date”). The initial Program fee will be based on the value of the assets in the account on the Effective Date. The period which this payment covers and for which the Program fee will be pro-rated will run from the Effective Date through the last day of the then current calendar month. The Program fee may be modified or changed by IAR upon 30 days advance written notice to client. The annual advisory fee paid to GVCM in the transaction based fee schedule cannot exceed the stated value; the annual fee paid to the IAR cannot exceed 1.4%. Total program cost cannot exceed 2.15%. Low Cost Program Fees There is a $2,000 account minimum, 0.4% program fee plus max 1.4% advisor fee, no maximum, ETF only at this time. No strategies available, only a build your own option from screened commission free ETF’s. Custodial Fees - Nationwide Advisory Solutions For its services as custodian, Nationwide Advisory Solutions charges a flat monthly insurance charge of $20 without regard to the size of account. It does not charge an upfront sales charge, surrender charges, commission paid on sale, or mortality costs. The beneficial owner of the variable annuity will be responsible for the fees of the underlying investments as a charge against the Net Asset Value (“NAV”). There is a $15,000 minimum required deposit. All custodial charges will be deducted from the investment account, as applicable, and retained by the custodian. All fees as stated above will be deducted from the investment account, as applicable, and retained by GVCM. GVCM does not give legal or tax advice and clients are urged to consult their tax advisor or legal professional. Custodial Fees-Schwab PCRA Custodians in the Schwab PCRA program acknowledge that they will carry out transactions as directed by the participant of the employer-sponsored retirement plan and/or investment adviser. For the execution and recordkeeping of these instructions, the custodian may be paid brokerage, custodian, transaction and annual fees which may be billed on a monthly basis or as a one-time transaction. Clients should be aware that they are allowed to deduct from their account program fees payable to the investment adviser and IAR. Mutual Funds may charge additional expenses, to include a management fee, distribution fee and other administrative expenses. Clients should read their plan documents and any fund prospectuses for additional information. American Trust/First Mercantile Trust GVCM provides strategies to American Trust/First Mercantile Trust for use on its retirement plan platform. American Trust has agreed to pay GVCM advisory fees between 40 and 75 basis points annually (which includes the cost of maintaining GVCM models at Mid-Atlantic Trust) applied to the assets invested in the models. GVCM does not charge additional fees to the participants or the retirement plan. Heartland Retirement Plan Services GVCM provides strategies to Heartland Retirement Plan Services (“Heartland”) for use on its retirement plan platform. Heartland has agreed to pay GVCM advisory fees of 40 to 75 basis points annually applied to the assets invested in the models. GVCM does not charge additional fees to the participants or the retirement plan. Page 6  Financial Planning GVCM offers resources designed to analyze and create a written evaluation for the implementation of a customized financial plan for clients. The IAR reviews the client’s present financial position including a net-worth statement, budget/cash flow analysis, risk assessment and income tax assessment. Financial goals, objectives, expectations and the degree to which the client is able to tolerate fluctuations in the stock market are also taken into consideration. Once the assessment is complete, the IAR will propose a detailed financial plan designed to fit the client’s personal needs and circumstances. Areas of financial planning advice include: Education, Retirement, Estate Planning, Investment Planning, Student Debt Planning, Insurance needs, Allocation of Qualified Plans and Business Planning. Clients will be charged an agreed upon rate not to exceed $350 per hour, plus out- of-pocket expenses for the initial plan consultation and annual review of the plan. Clients will be provided with an agreement that states the estimated number of hours to complete the plan or review. In the event that the client wishes to implement any product solutions with GVCM and what the IAR recommended in the plan or plan review, the fees for the initial plan or review will be refunded to the client in lieuof fees received for product sales. Solicitors to Unaffiliated Third-Party Investment Advisers GVCM and its IARs may be paid a portion of the fee charged and collected by unaffiliated third-party investment advisers in the form of solicitor fees or referral fees. GVCM’s fees are negotiated and specified in the Solicitor Agreement with each unaffiliated third-party investment adviser. A complete description of the third-party investment adviser’s services, fee schedules and account minimums will be disclosed in each unaffiliated third-party investment adviser’s Form ADV Part 2A, Disclosure Brochure. Please refer to “Item 10-Other Financial Industry Activities and Affiliations” for more information on conflicts of interests. Item 6 - Additional Fee Considerations It should be noted that all investments incur expenses which are paid from fund assets, including, without limitation, fees of the advisers, 12b-1, administrative, shareholder servicing fees, or certain other fees, all of which reduce the NAV of the investment’s shares on a continuing basis. All such fees and expenses are reflected in the value of the investment’s shares and are indirectly incurred by clients in addition to GVCM’s fees. Performance-Based Fees Performance-based fees are designed to give a portion of the returns of an investment to the investment adviser as a rewardfor positive performance. The fee is generally a percentage of the profits made on the investments. GVCM does not charge performance-based fees on any GVCM client accounts. Item 7 - Types of Clients Adviser provides investment advisory services to individuals, high-net-worth individuals, trusts, corporations, retirement plans, and other businesses. GVCM reserves the right to waive account minimums. Account Minimums GVCM, at its sole discretion, may accept clients with smaller portfolios or lower minimums based upon certain factors including: anticipated future earning capacity, anticipated future additional assets, account composition, related accounts, and pre-existing client relationships. GVCM may consider the portfolios of immediate family members to determine if the client portfolio meets the minimum size requirement. Certain third-party asset managers may have higher minimum account requirements which will be described in the account opening documentation. In the event that account values fall below the minimum account value needed to effectively execute trades in client accounts, the account may: 1) not trade until additional funds are added by the client; or 2) GVCM may choose to discontinue its advisory agreement with the client. Mutual Funds and ETFs are subject to various investment minimums not set by GVCM. Page 7  Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss GVCM uses technical and quantitative analysis in the selection of specific investments for the portfolios. Technical and quantitative analysis are methods of evaluating securities by analyzing statistics generated by market activity, such as past prices and volumes. Technical analysts do not attempt to measure a security’s intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. GVCM then employs momentum-based, relative strength and trend following analysis to further identify the specific securities selected and the weighting used to gain exposure to market leaders. To provide downside protection in a bear market, stop- loss limits allow for the assets to shift to money market or bond investments. All of these technical analysis signals are generated by AdvisorGuide, LLC, a majority-owned research-arm of GVCM. Advisor Guide’s research provides daily rankings and buy/sell alerts for over 14,000 mutual funds and ETFs using its proprietary algorithmic systems. Advisor Guide LLC also sells its research on a subscription basis. Investment Risk Considerations GVCM’s investment strategies may include long-term and short-term purchases. Frequent trading can affect investment performance vis-a-vis increased tax liabilities. Clients may place reasonable restrictions on the strategies to be employed in the portfolio and the types of investments to be held in the client portfolios. All investments involve risk. The primary risk for all investments is a risk of loss of principal or that the proceeds received from the sale of an investment will be less than the original funds used to purchase the same investment. The risk of loss of principal can be severe at times depending on the market environment and market events. Although GVCM attempts to design our portfolios to limit portfolio risk and volatility, the client should be prepared to assume a risk of loss of principal with any investment. Other risks that the client may experience and that may cause a risk of loss of principal include but are not limited to: • • Inflation Risk: The risk of loss of purchasing power resulting from rising prices over time. Interest Rate Risk: For fixed income investments, the risk that interest rates will rise which will result in declining prices. • Default Risk: The risk that an issuer/borrower will not makes its interest or principal payments as they come due. • Currency Risk: The risk that securities denominated in other currencies lose value as the value of the underlying currency declines. • Political Risk: Risk that government intervention, restrictions, or expropriation may result in a loss of principal. • Business Risk: Risk that a business will be unable to continue ongoing operations as a result of increased competition, mismanagement, or financial insolvency. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns; and, if these patterns can be identified, then a prediction can be made. The risk is that markets may not always follow patterns. Although GVCM manages client portfolios in a manner consistent with the client’s risk tolerances, GVCM cannot guarantee that efforts will be successful. The client should be prepared to bear the risk of loss. Below are some inherent risks that exist in almost any advisory account utilizing models. GVCM (Global View Capital Management) has identified these risks and GVCM notes while these risks are rare, they do exist and you the client should be aware of them. ASSET ALLOCATION RISK Asset allocation risk is the risk that a Client’s assets may be allocated to an asset class that underperforms other asset classes. For example, fixed-income securities may underperform equities. Accordingly, asset allocation risk will be influenced by the allocation among equities, fixed income, and money market funds. INVESTMENT AND MARKET RISK Recommendations are subject to investment risk, including the possible loss of the entire principal amount invested. A recommendation to invest in securities and other instruments may also involve market risk, which is the risk that the value of the investments may increase or decrease, sometimes rapidly and unpredictably. The current value of a security or other instrument may be worth less than the amount of the original investment, even after taking into account reinvestment of any distributions. MODEL RISK Where the management of an Advisory Account includes the use of various proprietary and third-party advised quantitative or Page 8  qualitative models (strategies), it should be expected that there may be deficiencies in the design or operation of these models, including shortcomings or failures of processes, people or systems. Investments selected using models may perform differently than expected as a result of the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, the speed that market conditions change and technical issues in the construction and implementation of the models (including, for example, data problems and/or software issues). The use of investment models, electronic trading, and software programs to calculate trades, in contrast to person-to-person manual trading, could be adversely impacted by software or hardware malfunction and other technological failures, power loss, software bugs, malicious code such as “worms,” viruses or system crashes or various other events or circumstances within or beyond the control of GVCM or their affiliates. Certain of these events or circumstances are difficult to detect. All model trading is processed on a “best efforts” basis dependent on availability of accurate data, correct and complete software calculations, and successful and timely trade delivery to custodians, among other factors. Execution of model trading signals might not be completed during the current market session due to these implementation factors, and/or must be executed in the next market session, if necessary. In some instances, account-level changes combined with model-level changes in the same market session can work at cross purposes, one serving to increase or decrease exposure to a specific security while the other moves the position in the opposite direction. These outcomes are inherent to managing investments through the model allocation approach. Moreover, the effectiveness of a model may diminish over time, including as a result of changes in the market and/or changes in the behavior of other market participants. Models may not be predictive of future price movements if their return mapping is based on historical data regarding particular asset classes, particularly if unusual or disruptive events cause market movements, the nature or size of which are inconsistent with the historical performance of individual markets and their relationship to one another or to other macroeconomic events. In addition, certain strategies can be dynamic and unpredictable, and a model used to estimate asset allocation may not yield an accurate estimate of the then current allocation. Models also rely heavily on data that is licensed from a variety of sources, and the functionality of the models depends, in part, on the accuracy of voluminous data inputs. Operation of a model may result in negative performance, including returns that deviate materially from historical performance, both actual and pro forma. Additionally, commonality of holdings across quantitative investment managers may amplify losses. There is no guarantee that the use of these models will result in effective investment decisions for an advisory account. TRADING RISK Model Managers, Advisors, and Fund Managers deliver strategies that call for the use of certain styles or manner of trading or trade orders. In substantially all cases, “Market” orders are used by model strategists. Market orders are executed at a price beyond the control of GVCM, or its affiliates. With all market orders, the execution price that will be achieved by the broker- dealer responsible for executing the order is not known at the time the order is delivered. In the case of model trade calculation, GVCM or its affiliates calculate the share quantity to be bought or sold to match position weights targeted by the strategist based on the most recently available market price for the security being traded. It is a certainty that the actual price at which the market order executes will differ from the price used by the system in the calculation of share quantities. This is particularly true in volatile market conditions where prices are moving rapidly. Therefore, GVCM and their affiliates bear no responsibility for differences in actual trade size versus target trade size resulting from a market price change occurring after the trade is calculated. Further, it should be understood that for strategists who direct the use of market-on-close (MOC) orders, any over-buys or over-sells cannot be corrected until the next trading session which could result in substantial corrections due to market volatility. Further, for strategists who employ the use of mutual funds in models, any adjustments to actual versus target weights due to price movement cannot be made until the next trading session’s closing NAV per share, which could be materially different from the previous day. In these instances, GVCM bears no financial responsibility for any requested or necessary adjustments to model target weights resulting from the execution price differing from the price used by GVCM to create the trade file. REBALANCING RISK The risk that an Advisory Account’s actual allocation is out of balance with the target allocation is born by the Account owner. Any rebalancing of such assets may be infrequent and limited by several factors and, even if achieved, may have an adverse effect on the performance of the Advisory Account’s assets. CYBERSECURITY RISK The risk of actual and attempted cyber-attacks, including denial-of-service attacks, and harm to technology infrastructure and data from misappropriation or corruption, and reputation harm. Due to our system’s interconnectivity with third-party vendors, central agents, broker-dealers, clearing houses and other financial institutions, GVCM, and thus indirectly the Advisory Accounts, could be adversely impacted if any of them is subject to a successful cyber-attack or other information security event. Although GVCM takes protective measures and endeavors to modify them as circumstances warrant, its computer systems, software and networks are vulnerable to unauthorized access, misuse, computer viruses or other malicious code and other events that could have a security impact or render GVCM, unable to transact business on behalf of Advisory Accounts. GVCM and/or its affiliates do not control such events, and thus, bear no financial responsibility for the outcome. Page 9  DATA RISK The risk that information from third-party data sources to which GVCM subscribes is incorrect. Central to everything the system does, from displaying content for advisors who evaluate client accounts, to the reporting of account activity and performance, to the calculation of trades, is data from third parties. The daily volume of this data, from transactions, prices, corporate actions, alerts, etc. that is brought into the system makes it impossible to monitor and detect any or all errors in such data. This risk is inherent to portfolio management and accounting systems. GVCM quickly addresses errors found or reported in the data, but does not provide assurance that any data consumed into its portfolio software or relied on in trading or reporting, is accurate. EXCHANGE TRADED FUND RISK The risk that ETFs fail to accurately track the market segment or index that underlies their investment objective. Moreover, ETFs are subject to the following risks that do not apply to conventional funds: (i) the market price of the ETF’s shares trade at a premium or a discount to their net asset value; (ii) an active trading market for an ETF’s shares are not developed or maintained; and (iii) there is no assurance that the requirements of the exchange necessary to maintain the listing of an ETF will continue to be met or remain unchanged. GVCM may, at times, purchases in Advisory Accounts leveraged and inverse ETFs where strategists believe it is warranted, based on the invested portfolio’s objective. These securities carry certain specific risks to investors. Leveraged ETF shares typically represent interest in a portfolio of securities that track an underlying benchmark or index and seek to deliver multiples of the performance of the index or benchmark. An inverse ETF seeks to deliver the opposite of the performance of the index or benchmark it tracks. Like traditional ETFs, some leveraged and inverse ETFs track broad indices, some are sector specific, and others are linked to commodities, currencies, or some other benchmark. To accomplish their objectives, leveraged and inverse ETFs pursue a range of investment strategies using swaps, futures contracts, and other derivative instruments. Most leveraged and inverse ETFs “reset” daily, meaning that they are designed to achieve their stated objectives daily. Their performance over longer periods of time, over weeks or months or years, can differ significantly from the performance (or inverse of the performance) of their underlying index or benchmark during the same period. This effect can be magnified in volatile markets and thus poses substantial risk for an investor. OPERATIONAL RISK Operational risk is the risk of loss arising from shortcomings or failures in internal processes or systems at GVCM or their affiliates, external events impacting those systems and human error. Operational risk can arise from many factors ranging from routine processing errors to potentially costly incidents such as major system failures. Some Advisory Accounts trade instruments on a very active, tactical basis, where operational risk is heightened due to the nature of such trading patterns and swings in market prices. TRADE RESTRICTION RISK The risk that temporary or permanent trading restrictions may be imposed on securities (including ADRs, ADSs, ETFs, US common stocks, exchange traded derivatives, or other securities) or options in a client’s account, or the risk that a client’s account itself is restricted from trading due to issues such as mail-holds, death of the account owner, or Reg-T violations. In such instances, trades might have to be canceled that cannot be allocated to the restricted account, securities might have to remain in an account despite the desire to sell them, and the account might otherwise be out of balance with the intended target allocations. All of these outcomes could have a significant cost to a client that are beyond the control of GVCM, or its affiliates. Item 9 - Disciplinary Information GVCM has not been the subject of any legal or disciplinary events that would be material to client evaluation of GVCM’s business or the integrity of GVCM’s management. Item 10 - Other Financial Industry Activities and Affiliations AdvisorGuide, LLC AdvisorGuide, LLC is an investment research firm founded by David Morton and now majority-owned by GVCM. The firm specializes in providing clear, specific, objective and timely market data to investment professionals. Mr. Morton (GVCM Portfolio Manager), collaborate with Dina Fliss (GVCM’s President, Chief Compliance Officer and Chief Investment Strategist), and Barry Arnold (GVCM’s Chief Investment Officer) collaborate in the research, development and management of GVCM’s multiple strategies. Page 10  For market research and professional services received from Mr. Morton and AdvisorGuide, GVCM pays AdvisorGuide, LLC a portion of any annual fees received for GVCM’s services as an investment adviser or sub-advisor. In December 2015, GVCM acquired a 51% ownership stake in AdvisorGuide, LLC (Currently a 60% ownership stake). Dina Fliss has final decision-making authority on any items related to AdvisorGuide, LLC. Castleview Partners, LLC. (Castleview) GVCM has contracted with Castleview, a provider of wealth management technology and advisory services, to provide administrative, operational and trading services in support of GVCM’s Personalized Managed Account Program. Castleview conducts due diligence of third party asset managers involved in the program, and also provides trading services for GVCM’s proprietary strategies and SMA accounts. Global View Capital Partners, LTD. Global View Capital Partners (“GVCP”) is the parent company of GVCM, GVCA, and GVCI. Dina Fliss, President, Chief Compliance Officer and Chief Investment Strategist of GVCM and Dean Fliss, President of GVCA are equal owners of GVCP. Global View Capital Insurance Services, LLC. Global View Capital Insurance, LLC. (“GVCI”) is an affiliated company of GVCM. Dina Fliss, President, Chief Compliance Officer and Chief Investment Strategist of GVCM, is an insurance agent of GVCI. Global View Capital Advisors, LLC. Global View Capital Advisors, LLC. (“GVCA”) is an affiliated company of GVCM. GVCA is a marketing company that provides distribution services for products and services designed by GVCM and other third-party asset managers. IARs of GVCM that distribute products and services under the name of GVCA have a conflict of interest when selling GVCM products and services because any sales of GVCM products and services may result in additional fees to GVCM. The IAR will receive only their customary share of fees or commissions and does not receive additional compensation as a result of recommending GVCM strategies. GVCM’s Supervisory Principals supervises the suitability of IAR new client business for GVCM. Purshe Kaplan Sterling Investments Purshe Kaplan Sterling Investments (“PKS”) is a broker-dealer and member of FINRA and SIPC. Some IARs of GVCM are also Registered Representatives (“RRs”) of PKS. This may pose a conflict of interest for GVCM’s IARs as they may make investment recommendations based upon which entity pays a higher fee or commission. Dean Fliss, President of GVCA, is a RR of PKS. Solicitors/Promotors to Unaffiliated Third-Party Investment Advisers GVCM and its IARs may act as a solicitor/promotor and refer clients to third-party investment advisers that offer asset management services to clients. As a result, GVCM and its IARs may be paid a portion of the fee charged and collected by the third-party investment adviser in the form of solicitor/promotor fees or referral fees. Each solicitation arrangement is performed pursuant to a written solicitation agreement. GVCM has utilized the following unaffiliated third- party investment advisers in limited circumstances: • AMP Wealth Management • Flexible Plan Investments • Howard Capital Management, Inc. • Hanlon Investment Management • The Pacific Financial Group • Portfolio Strategies, Inc. Clients are advised that GVCM and IARs may have a conflict of interest by making a referral to a third-party investment adviser that has agreed to pay a portion of its advisory fee to GVCM. Clients are advised that there may be other third-party investment advisers that may be suitable to the client that could be more or less costly. Page 11  Item 11 - Code of Ethics GVCM has adopted a Code of Ethics (the “Code”) for all supervised persons and employees of GVCM as governance for the conduct of its business and fiduciary duty to its clients. Certain conduct is singled out in the Code for prohibition. Other conduct may be prohibited from time to time as circumstances may warrant or as may be required to assure that the Code remains compliant with Rule 17j-1 of the Investment Company Act of 1940 and the Investment Advisers Act of 1940. All supervised persons and employees must acknowledge the terms of the Code annually, or as amended. GVCM will provide a copy of the Code to any client or prospective client upon written request. The Code includes GVCM’s policies and procedures developed to protect client interests in relation to the following: • The duty at all times to place client interests ahead of GVCM and respective IARs; • That all personal securities transactions of our supervised persons and employees be conducted in a manner consistent with the Code and avoid any actual or potential conflict of interest, or any abuse of a supervised persons or employee’s position of trust and responsibility • That supervised persons and employees may not take inappropriate advantage of their positions • That information concerning the identity of client security holdings and financial circumstances are confidential • That independence in the investment decision-making process is paramount. GVCM does not buy or sell securities that we also recommend to clients. GVCM’s supervised persons and employees are permitted to buy or sell the same securities for their personal and family accounts that are bought or sold for their client account(s). The personal securities transactions by supervised persons and employees may raise potential conflicts of interest when they trade in a security that is owned by the client or considered for purchase or sale for the client in one of GVCM’s strategies. GVCM has adopted policies and procedures that are intended to address these conflicts of interest. These policies and procedures require all GVCM supervised persons to: • The duty at all times to place client interests ahead of GVCM and respective IARs; • Act in the capacity of a fiduciary; that is, acting in the client’s best interest instead of the IARs best interest; • Prohibit favoring one client over another; • Provide for the review of transactions to discover and correct any same-day trades that result in a supervised person receiving a better price than a client. Item 12 - Brokerage Practices Flexible Plan Investments, Ltd. FPI uses Axos Advisor Services for the account broker- dealer/custodian. GVCM’s services have been customized to use the services of Axos Advisor Services through FPI’s investment platform. GVCM receives a portion of the advisory fee clients pay to FPI. All transactions and back office functions are performed or provided by FPI and Axos Advisor Services. Personalized Asset Management Program GVCM has contracted Castleview, a leading provider of wealth management technology and advisory services, to provide administrative, operational and trading services in support of GVCM’s Personalized Managed Account Program. Castleview conducts due diligence of third party asset managers involved in the program. Personalized Asset Management Program assets will be held by one of the following participating qualified custodians that clients select: Charles Schwab, Nationwide Advisory Solutions, American Trust, Fidelity and Axos. Our use of available custodians is based in part on our existing relationships or those of Castleview; the custodian’s financial strength; reputation; breadth of investment products; and, the cost and quality of custody and brokerage services provided to our clients. The determining factor in the selection of a particular custodian to execute transactions for the client account is not the lowest possible transaction cost, but whether they can provide what is in GVCM’s view the best qualitative execution for investment transactions for the client account. GVCM is independently-owned and operated and not affiliated with the custodian we recommend. In addition to brokerage and custody services, we may receive benefits from the custodians GVCM recommends, including access to investments generally available to institutional investors, research, software and educational opportunities. Page 12  Custodians may also make available or arrange for these types of services to be provided to GVCM by independent third parties. Custodians may discount or waive the fees it would otherwise charge for some of the services it makes available to GVCM. It may also pay all or a part of the fees of a third party providing these services to GVCM. GVCM receives economic benefits as a result of its relationship with custodians because GVCM does not have to produce or purchase the products and services listed above. These services are not contingent upon us committing any specific amount of business to the custodians in trading commissions. GVCM does not enter into soft-dollar arrangements with custodians or brokers. Because the amount of products or services GVCM receives may vary depending on the custodian GVCM recommends to be used by our clients and the amount of client assets in accounts at that custodian, GVCM may have a conflict of interest in making that recommendation. GVCM recommendation of specific custodians may be based in part on the economic benefit to GVCM and not solely on the nature, cost or quality of custody and brokerage services provided to the client. GVCM nonetheless, strives to act in the client’s best interests at all times. Commissions and other fees for transactions executed through the custodians recommended may be higher than commissions and other fees available if the client utilizes another custodian firm to execute transactions and maintain custody of client accounts. However, GVCM believes, that the overall level of services and support provided to our clients by our recommended custodians outweighs the benefit of possibly lower transactions cost which may be available under other brokerage arrangements. Many of the services described above may be used to benefit all or a substantial number of our accounts, including accounts not maintained through GVCM recommended custodians. GVCM does not attempt to allocate these benefits to specific clients. Directed Brokerage If clients participate in the Personalized Asset Management Program, the client may not direct GVCM to execute transactions away from the account custodian. Block Trading GVCM, though its TAMP-relationship with Castleview, does engage in “block trading.” Block trading is the purchase or sale of a security in a single transaction for the accounts of multiple clients. Executing a block trade is an advantage to client for three reasons: 1) transaction costs are shared equally across all participating clients; 2) the aggregate trade is executed at an average price and eliminates any conflicts in trading priorities; and 3) block trading allows the trading firm (i.e. Castleview) to “shop” the trade and get best execution. All trading via Castleview is considered block trading: GVCM initiates buy/sell orders by placing model changes on the Castleview platform; Castleview aggregates all client trades in the affected models; and lastly, Castleview the places those block trades with the trading desk at various custodians. Item 13 - Review of Accounts GVCM regularly monitors our models, as well as general conditions in the global stock and bond markets, and recommends changes and/or alternate investments or opportunities when GVCM believes it is appropriate to do so. GVCM strongly encourages the client to notify the IAR of any material changes in the overall financial condition or the client’s investment objectives or risk tolerance as these could have a material effect on the investment recommendations. GVCM’s IARs are required to conduct an annual review with clients. Dina Fliss (President, Chief Compliance Officer and Chief Investment Strategist of GVCM), Barry Arnold (GVCM’s Chief Investment Officer) and David Morton (GVCM’s Portfolio Manager) are responsible for conducting all model and or strategy reviews. While the client will generally meet with their IAR, GVCM may arrange for one or more other portfolio managers who have particular subject matter expertise to also meet with clients. The client will receive statements from the account custodian, and/or their variable annuity and/or life insurance carrier at least quarterly. These statements identify the current investment holdings, the cost of each investment holding, and respective current market values. If clients have any questions or concerns regarding activity contained in an account statement, they should contact their IAR. Page 13  Flexible Plan Investments, Ltd. Statements Clients will receive confirmations and quarterly statements from Axos Advisor Services for all of the transactions FPI effects for client Flexible Plan accounts. Clients have access to quarterly reports from FPI. Personalized Asset Management Program Statements Clients will receive confirmations and monthly statements from custodian(s) for all transactions GVCM or Castleview effects for Personalized Asset Management Program accounts. Copies of statements are available upon request from the IAR or directly from the respective custodian. Schwab PCRA, American Trust & Savings Bank Retirement Plan and HRS Statements Employer-sponsored retirement plan participants will receive statements from the custodian. Clients should contact the plan sponsor or consult plan documents for additional information. Item 14 - Client Referrals and Other Compensation GVCM receives clients primarily from IARs registered with GVCM and affiliated with GVCA. The maximum IAR fee for Personalized Asset Management Program is 1.4%. IARs of GVCM may act in their own interests by selecting that program or strategy that pays them the highest fee or commission. GVCM may enter into written agreements with certain unaffiliated investment advisers and other professionals (such as CPAs, attorneys, etc.) to compensate them for referring clients to us. GVCM will pay these individuals (referred to as “solicitors/promotors”) a percentage of the advisory fee that client pays GVCM if it is determined that the client became a GVCM client as a result of their direct or indirect efforts. The payments GVCM makes to any solicitor/promotor will not result in an increase in the amount of the advisory fee that the referred client will pay to GVCM. GVCM’s solicitation or referral arrangements will comply with applicable laws that govern: • The nature of the services provided; • The fees to be paid; • Disclosure of solicitor arrangements to clients; • Client consent, as required. Item 15 - Custody of Client Assets GVCM is custodian agnostic and uses multiple companies to custody client assets. The client assets will be held by a qualified custodian. GVCM does not have physical custody of client accounts but GVCM may be deemed to have custody when the client authorizes the firm to deduct fees directly from the clients account. The client will receive statements from the account custodian or variable annuity and life insurance carrier on at least a quarterly basis. The client should verify that the transactions in the account are consistent with the investment goals and the objectives for the account. GVCM also encourages clients to contact GVCM or the IAR with any questions or concerns regarding the account. Custody is also disclosed in Form ADV because GVCM has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, GVCMwill follow the safeguards specified by the SEC rather than undergo an annual audit. Page 14  Item 16 - Investment Discretion GVCM offers its advisory services on a discretionary basis. This means that GVCM does not need advance approval from the client to determine the type and amount of securities to be bought and sold for model portfolios. GVCM does not have the authority to withdraw funds from client accounts (other than to withdraw our advisory fees which may only be done with prior client written authorization). GVCM may only exercise discretion if the clients have provided that authority to us in writing. This authorization is typically included in the investment management agreement the client enters into with GVCM. The discretionary authority the client grants to GVCM does not provide GVCM the ability to choose the custodian through which transactions for the account will be executed or to negotiate brokerage fees or expenses. Additionally, GVCM’s discretionary authority does not provide GVCM the ability to withdraw funds from the account (other than to withdraw GVCM advisory fees which may only be done with client prior written authorization). GVCM will exercise discretion in a manner consistent with the stated investment objectives for client accounts. Typically, under third party investment management arrangements, the third-party investment manager exercises discretion in the management of client accounts. All securities transactions are selected and executed by such manager. GVCM does not manage or obtain discretionary authority over the assets in those accounts. The client may, however, grant GVCM discretionary authority to hire and fire such third party managers on their behalf. Item 17 - Voting Client Securities As a matter of firm policy and procedure, GVCM does not take any action or give any advice with respect to voting of proxies solicited by or with respect to the issuers of securities in which client accounts may be invested. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in their portfolios Certain third-party asset managers on the Personalized Asset Management Program platform may vote the proxies for the securities in the portfolios they manage. Item 18 - Financial Information Because GVCM does not require prepayment of client fees more than three months in advance, GVCM is not required to provide financial statements. GVCM does not have any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients. Further, GVCM has not been the subject of a bankruptcy proceeding. Additional Disclosure Past performance may not be indicative of future results. Different types of investments involve varying degrees of risk. Therefore, it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended and/or undertaken by GVCM), or any non- investment related services, will be profitable, equal any historical performance level(s), be suitable for client portfolios or individual situations, or prove successful. GVCM is neither a law firm nor an accounting firm, and no portion of its services should be construed as legal or accounting advice. Please remember that it remains the clients’ responsibility to advise GVCM in writing, if there are any changes in their personal/financial situation or investment objectives for the purpose of reviewing/evaluating/revising GVCM’s or respective IAR previous recommendations and/or services, or if the client would like to impose, add, or modify any reasonable restrictions to GVCM’s investment advisory services. GVCM utilizes research signals as guidance in determining a proprietary combination of technical, quantitative, and economic indicators to specific exchanged traded funds and mutual funds selected for the various investment programs offered to our client accounts. Buys and Sells may or may not occur on the exact date a signal is received. Trading restrictions may be imposed by investment families, exchanges, custodians, market conditions, or other factors outside of GVCM’s control that may result in the inability to trade all strategies affected on the day a buy or sell signal is generated. GVCM will utilize its best efforts and discretion to minimize the adverse effect of such restrictions. Page 15 

Version date: March 13, 2025 Form ADV-Part 2A Appendix 1 - Wrap Fee Brochure www.gvcmanagement.com N1423833 Stone Ridge Drive, Suite 350 Waukesha, WI 53188 262.650.1030 (Phone) 262.650.1085 (Fax) Introduction SEC File No. 801-72887 This wrap fee program brochure provides information about the qualifications and business practices of Global View Capital Management LLC. (“GVCM”). If you have any questions about the contents of this wrap fee program brochure, please contact GVCM’s Compliance Department at 262-650-1030 or via email at compliance@gvcaponline.com. The information in this wrap fee program brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. Additional information about GVCM also is available on the SEC’s website at www.adviserinfo.sec.gov. Item 2 - Material Changes GVCM’s last annual update was February 21, 2024. There are no material changes that have been made to this brochure since the last annual update. Item 3 - Table of Contents Item 4 - Services, Fees and Compensation Page 2 Item 5 - Account Requirements and Types of Clients Page 8 Item 6 - Portfolio Manager Selection and Evaluation Page 8 Item 7 - Client Information Provided to Portfolio Managers Page 9 Item 8 - Client Contact with Portfolio Managers Page 9 Item 9 - Additional Information Page 10 Page 1  Item 4 - Services, Fees and Compensation Overview GVCM is a corporation organized under Wisconsin state law. Dina Fliss founded the Waukesha County based investment adviser in 2011. The firm is a wholly- owned subsidiary of Global View Capital Partners, LTD. (“GVCP”), which is owned by Dina Fliss and Dean Fliss. GVCM is a SEC registered investment adviser. Registration as an investment adviser does not imply any level of skill or training. As of December 31, 2024, GVCM had $707,976,833 of discretionary assets under management. GVCM does not perform accounting, legal, tax, mortgage or other financial services, nor does it have direct or indirect custody of client assets. Investment Advisory Representatives (“IARs”) of GVCM may have properly disclosed outside business activities on their ADV Part 2B where they act in the capacity of an accountant, attorney, insurance agent, registered representative or mortgage broker, etc. You are encouraged to review your IARs 2B. The Custodians GVCM has selected and engaged the following custodians to securely handle custody of client assets and the processing of client transactions: • Charles Schwab 800-515-2157 1958 Summit Park Drive Ste. 400 Orlando, FL 32810 • Nationwide (formerly Jefferson National) 866-667-0564 10350 Ormsby Park Pl. Louisville, KY 40223 • Axos Clearing 402-384-6100 15950 West Dodge Road, Ste. 300 Omaha, NE 68118 The custodians have assumed responsibility for: (1) receipt and safekeeping of all cash received from clients and for the cash and securities of the clients’ investment accounts; (2) execution of all investment directions from the Sponsor; (3) maintenance of separate accounting records for each client’s investment account;(4) payment from each client’s investment account of the Program Fees due to the Sponsor; (5) preparation of monthly statements for each client’s investment account reflecting the record during the previous calendar month of: (a) all investment activity within the account; (b) all earnings or other distributions received on the investments and all additions or withdrawals made by the client; (c) all fees or other expenses disbursed from the account to the Sponsor, the solicitor or to the custodians; and (d) the value of the account at the beginning and at the end of the month; and (6) mailing to each Program client the monthly statement described in (5). A copy of the Sponsor’s agreement with the custodians is available upon written request. GVCM retains the right to appoint, terminate and replace any custodian for the Program. In any such case, GVCM shall select a replacement custodian that will provide at least the same level of services as were provided by the replaced custodian and at no increase in cost to Program clients. GVCM does not, directly or indirectly, have custody of Program clients’ funds. Platform Services GVCM, through its relationship with Castleview Partners, LLC (Castleview), will provide certain administrative and advisory services with respect to the Program (“Platform Services”). These services include: Page 2  • Selection and on-going monitoring of third party asset managers (the “Platform Managers”); • Make custodial and brokerage services available through the custodian; • Ensure custodian provides account statements to client no less than quarterly; • Administration of client accounts; • Calculation and billing of client fees; Sponsor of the Personalized Managed Account Program GVCM sponsors the Personalized Managed Account Program (the “Program”), which provides asset allocation strategies, ETF’s, mutual funds and discretionary asset management advised by GVCM and a selection of unrelated third party asset managers and sub-advisors. The program is comprised of two different pricing schedules: Asset Based and Transaction Based. It should be noted that differences exist in both the product solutions available, and the fees and expenses charged to the Client, depending upon pricing schedules and custodian selected by the IAR. Strategies in the Program are managed to specific objectives rather than to the individual needs of clients. GVCM IARs match the suitability of the investment strategies available in the Program, to the client’s person financial situation (attained through completion of a “suitability questionnaire.”) Client restrictions on investing may preclude an IAR from choosing any of the Program models for their clients’ portfolios. In the event that account values fall below the minimum account value needed to effectively execute trades in client accounts, the account may: 1) not trade until additional funds are added by the client; or 2) GVCM may choose to discontinue its advisory agreement with the client. IARs of GVCM who are also associates of Global View Capital Advisors. LLC. (“GVCA”) may recommend the Program to suitable clients and act as the client’s Financial Advisor for the Program. GVCA is an affiliated company of GVCM. GVCA is a marketing company that provides distribution services for products and services designed by GVCM and other third party asset managers. Participation The Program is open to individuals, trusts, estates, corporations, partnerships and other entities, and to pension and profit sharing plans (including 403(b) and individual retirement accounts). Application A Program Application must be executed and delivered to the Sponsor by the client. Methodology GVCM is a quantitative asset management firm that uses technical and quantitative analysis in the selection of specific investments for portfolios. Technical and quantitative analysis is a method of evaluating securities by analyzing statistics generated by market activity, such as past prices and volumes. Technical analysts do not attempt to measure a security’s intrinsic value, but instead use charts and other tools to identify patterns that can suggest future activity. The Program Portfolios Clients participating in the Program will allocate their Program Account assets among (1) third party asset managers (“Platform Managers”) which have been selected by GVCM, and (2) GVCM’s proprietary models and strategies. The IAR will assist the client in completing the Investment Management Profile Questionnaire and determining the investment objectives, risk tolerance, time horizon and any desired restrictions. The IAR will use the information provided by the client to prepare the Personalized Asset Management Account Proposal (“Proposal”), which will recommend an allocation tailored to the financial profile. The Proposal, when accepted by the client, will be incorporated into the Investment Policy Statement (“IPS”) and will guide the manner in which GVCM manages and/or allocates the Program Account. Clients grant full discretionary investment authority to GVCM to be exercised in a manner consistent with the client’s IPS. GVCM will manage the account on a discretionary basis. The scope of the discretionary authority that the client may grant to GVCM is limited to selecting specific investments for the account and deciding how to allocate the account assets among those investments. GVCM will determine if and when to buy, hold, or sell those investments. Once the client has granted discretionary authority to GVCM, it is effective until the client changes it or revokes it in writing. The client may impose any reasonable restrictions upon the manner in which GVCM manages the account. For example, the client may restrict the management of the account to certain types or sectors of investment products or investment strategies. However, any restrictions may prevent GVCM from efficiently managing the assets. The Firm manages wrap fee accounts and non- wrap fee accounts in the same manner. Page 3  Nationwide (formerly known as Jefferson National) - Monument Advisor Variable Annuity The strategies on the Nationwide Monument Advisor Variable Annuity platform are managed to specific objectives rather than to the individual needs of clients. The IARs that monitor the client accounts and utilize GVCM’s services match the suitability of the strategies to their clients’ personal financial situation through the use of a suitability questionnaire. Client restrictions on investing may preclude an IAR from choosing any of GVCM’s proprietary models for their clients’ portfolios. Employer-Sponsored Retirement Plans Schwab Personal Choice Retirement Account A PCRA is a self-directed brokerage account that resides within an employer- sponsored retirement plan. In addition to the choices typically offered by retirement plans, PCRA allows the participant to invest in a much wider range of investments. The strategies offered as part of the Schwab PCRAs are managed to specific objectives rather than to the individual needs of participants. The IARs that monitor the participant accounts and utilize GVCM’s services match the suitability of the strategies to their clients’ personal financial situation through the use of a suitability questionnaire. ETF’s and mutual funds are available and Client restrictions on investing may preclude an IAR from choosing any of GVCM’s proprietary models for their clients’ portfolios. Third Party Asset Managers In addition to the GVCM models and strategies, the client is offered access to investment models from additional asset managers that have developed their own proprietary strategies and portfolios across various style and asset classes. The goal of these additional asset managers is to provide broader diversification than provided by a single asset manager within an individual style category or asset class. The asset managers may provide investment advice to both individual and institutional clients. Each asset manager has been selected through a proprietary due diligence process offered through Castleview and/or GVCM. Collectively, the asset managers represent a wide range of styles and philosophies. By using several asset managers in a portfolio strategy, the IAR may assist the client in creating a diversified portfolio and help promote stable investment performance over time. GVCM will periodically add new asset managers to the Personalized Managed Account Program, and have discretion to remove any asset manager that the management team deems to have not met expectations. Investment Risk Considerations GVCM’s investment strategies may include long-term and short-term purchases. Frequent trading can affect investment performance vis-a-vis increased tax liabilities. Clients may place reasonable restrictions on the strategies to be employed in the portfolio and the types of investments to be held in the client portfolios. All investments involve risk. The primary risk for all investments is a risk of loss of principal or that the proceeds received from the sale of an investment will be less than the original funds used to purchase the same investment. The risk of loss of principal can be severe at times depending on the market environment and market events. Although GVCM attempts to design our portfolios to limit portfolio risk and volatility, the client should be prepared to assume a risk of loss of principal with any investment. Other risks that the client may experience and that may cause a risk of loss of principal include but are not limited to: • • Inflation Risk: The risk of loss of purchasing power resulting from rising prices over time. Interest Rate Risk: For fixed income investments, the risk that interest rates will rise which will result in declining prices. • Default Risk: The risk that an issuer/borrower will not makes its interest or principal payments as they come due. Page 4  • Currency Risk: The risk that securities denominated in other currencies lose value as the value of the underlying currency declines. • Political Risk: Risk that government intervention, restrictions, or expropriation may result in a loss of principal. • Business Risk: Risk that a business will be unable to continue ongoing operations as a result of increased competition, mismanagement, or financial insolvency. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns; and, if these patterns can be identified, then a prediction can be made. The risk is that markets may not always follow patterns. Although GVCM manages client portfolios in a manner consistent with the client’s risk tolerances, GVCM cannot guarantee that efforts will be successful. The client should be prepared to bear the risk of loss. Termination The client, IAR or GVCM may terminate the agreement by providing written notification to all parties. A pro-rata portion of the Program Fee, (pre)paid by client, will be refunded to client based on the number of days left in the month following receipt of the notice of termination by any of the parties noted above. GVCM requires an advance written notice from either the client or the client’s representative, of at least 10 business days in advance of termination in order to process any available refund. If GVCM does not receive this notice in advance and in writing, GVCM will not guarantee client’s account will be credited and refunded a pro-rata share for the billing period. Such termination, however, will not affect the liabilities or obligations of the parties under the investment management agreement arising from transactions initiated prior to such termination, including payment of outstanding fees and the provisions regarding arbitration set forth below, which shall survive any expiration or termination of the investment management agreement. Upon termination of the investment management agreement, neither IAR nor GVCM shall be under any obligation whatsoever to recommend any action with regard to the securities or other investments in the client’s account. GVCM retains the right, however, to complete any transactions pending as of the termination date and to retain assets in the client’s account sufficient to effect such completion. Upon termination, it shall be client’s exclusive responsibility to issue written instructions regarding any assets held in the client’s account. Financial Planning GVCM offers resources designed to analyze and create a written evaluation for the implementation of a customized financial plan for clients. The IAR reviews the client’s present financial position including a net- worth statement, budget/cash flow analysis, risk assessment and income tax assessment. Financial goals, objectives, expectations and the degree to which the client is able to tolerate fluctuations in the stock market are also taken into consideration. Once the assessment is complete, your IAR will proposes a detailed financial plan designed to fit client personal needs and circumstances. Areas of financial planning advice include: Education, Retirement, Estate Planning, Investment Planning, Insurance needs, Allocation of Qualified Plans and Business Planning. Clients will be charged an agreed upon rate not to exceed $350 per hour, plus out- of- pocket expenses for the initial plan consultation and annual review of the plan. Clients will be provided with an agreement that states the estimated number of hours to complete the plan or review. In the event that the client wishes to implement any product solutions with GVCM and what the IAR recommended in the plan or plan review, the fees for the initial plan or review will be refunded to the client in lieu of fees received for managed accounts. Solicitors/Promotors to Unaffiliated Third Party Investment Advisers GVCM and its IARs may be paid a portion of the fee charged and collected by unaffiliated third party investment advisers in the form of solicitor/promotor fees or referral fees. GVCM’s fees are negotiated and specified in the Solicitor/Promotor Agreement with each unaffiliated third party investment adviser. A complete description of the third party investment adviser’s services, fee schedules and account minimums will be disclosed in each unaffiliated third party investment adviser’s Form ADV Part 2A, Disclosure Brochure. Please refer to “Item 10-Other Financial Industry Activities and Affiliations” for more information on conflicts of interests. Page 5  Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries 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. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: Avoid misleading statements about conflicts of interest, fees, and investments; Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • • • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Fees and Compensation Fees are paid monthly in arrears. The monthly Program Fees are calculated on the first day of each calendar month. Monthly Program Fees are calculated on the average daily balance of the account during the previous month, as determined by the account custodian. The first billing will take place on the date the account is initially funded. If there are any additions, withdrawals, new accounts added to the household or accounts removed from the household, the billing calculation will be applied pro-rata on those specific actions in addition to the monthly billing. The fee is calculated by multiplying the average daily balance of the account from the previous month by the annual fee multiplied by the actual number of days in the month divided by the number of days in the year. The monthly Program fee will be deducted from client’s account on or about the fifth business day after the commencement of each month. In the event GVCM commences management of the assets after the first day of a calendar month or in the event the investment management agreement is terminated prior to the last day of the calendar month, the Program fee for such month shall be calculated proportionately with respect to the number of days the account was managed. Program Fees may be negotiated and may differ from client to client based upon a number of factors. Moreover, Program Fees may vary as a result of the application of prior fee schedules depending upon a client’s program inception date. In addition, different fee schedules for the Program may apply to clients who also participate in our other programs. Program Fees cover investment management services provided by GVCM, investment planning, asset allocation, manager review, evaluation and presentation, mutual fund review, performance measurement and reporting, execution of transactions, and other account-related services provided by us. GVCM requires that the client, in writing, authorizes the Firm to direct the custodian/broker- dealer to pay GVCM’s investment advisory fees directly to GVCM by charging the account. This authorization is set forth in the investment management agreement and will execute the participation in the Program. The custodian/broker-dealer will provide the client with account statements that show the amount of the advisory fees paid directly to GVCM. The custodian does not verify the accuracy of GVCM’s fee calculations so clients should review their statements carefully. The maximum fees allowed under the Program are presented below: Personalized Managed Account Program Asset-Based Fee Schedule Assets Under Management $15,000 and Above Program Fee 1.00% ETF and Mutual Fund Series at Charles Schwab Program Fees are computed on a monthly basis in arrears for services provided by GVCM and the IAR and other third party sub- advisors (the “Program Fee”). The advisory fee paid to the IAR is negotiable; the program fee is not. Page 6  The annual program fee paid to GVCM in the above schedule cannot exceed 1.0%; the annual advisory fee paid to the IAR cannot exceed 1.4%. Annual total of IAR advisory fee plus program fee cost cannot exceed 2.4%. Monthly Program Fees are calculated on the average daily balance of the account during the previous month, as determined by the custodian. The fee is calculated on the first day of the calendar month by multiplying the average daily balance of the account from the previous month by the annual total program fee, multiplied by the actual number of days in the month divided by the number of days in the year. The monthly program fee will be deducted from client’s account on or about the fifth business day after the commencement of each month. Accounts in the same household may be aggregated for the purposes of determining the applicable Program fee rate. The program fee also covers fees charged by custodians except for accounts less than $15,000 or in the Transaction-Based Fee Program, where brokerage commissions and ticket charges may apply, however GVCM attempts to utilize NTF (No Transaction Fee) funds for these accounts. The initial Program fee will be charged on the date the agreement is accepted by GVCM (the “Effective Date”). The initial Program fee will be based on the value of the assets in the account on the Effective Date. The period which this payment covers and for which the Program fee will be pro-rated will run from the Effective Date through the last day of the then current calendar month. The Program fee may be modified or changed by IAR upon 30 days advance written notice to client. Custodial Fees – Nationwide formerly Jefferson National For its services as custodian, Nationwide charges a flat monthly insurance charge of $20 without regard to the size of account. It does not charge an upfront sales charge, surrender charges, commission paid on sale, or mortality costs. The beneficial owner of the variable annuity will be responsible for the fees of the underlying investments as a charge against the Net Asset Value (“NAV”). All custodial charges will be deducted from the investment account, as applicable, and retained by the custodian. All fees as stated above will be deducted from the investment account, as applicable, and retained by GVCM. Custodial Fees-Schwab PCRA Custodians in the Schwab PCRA program acknowledge that they will carry out transactions as directed by the participant of the employer-sponsored retirement plan and/or investment adviser. For the execution and recordkeeping of these instructions, the custodian may be paid brokerage, custodian, transaction and annual fees with may be billed on a monthly basis or as a one-time transaction. Clients should be aware that they may have deducted from their account Program Fees payable to the investment adviser and IAR. Mutual Funds may charge additional expenses to include a management fee, distribution fee and other administrative expenses. Clients should read their plan documents and any fund prospectus’ for additional information. Performance-Based Fees Performance-based fees are designed to give a portion of the returns of an investment to the investment adviser as a reward for positive performance. The fee is generally a percentage of the profits made on the investments. GVCM does not charge performance-based fees on any GVCM client accounts. General Fee Disclosures This wrap fee program may cost the client more or less than purchasing these services separately, depending on the amount of trading activity in the account, the value of services that are provided to the client under the Program, and other factors. Therefore, the IAR may have a financial incentive to recommend the wrap fee program over other programs or services. Generally, the wrap programs may result in higher overall costs to the client in accounts that experience little trading activity. Our fees may be higher or lower than the fees charged by other advisers for similar services. The amount of this compensation may be more or less than the amount the Financial Advisor would receive if the client participated in other programs or paid separately for the Program services. However, the client cannot participate in the GTAC Models or receive the direct investment management services of GVCM outside of the Program. In addition to our fee, certain additional charges may be assessed. These fees are not assessed by or paid to GVCM, and may include: Internal fees and expenses charged by mutual funds or ETFs; • Page 7  • Maintenance and termination fees for IRAs, certain retirement and qualified accounts; and • Other fees and taxes on brokerage accounts and securities transactions. Mutual fund companies, ETFs, and variable annuity issuers charge internal fees and expenses for their products. These fees and expenses are in addition to any advisory fees charged by us. Complete details of these internal fees and expenses are explained in the prospectuses for each investment. The client is strongly encouraged to read these documents before making or authorizing any investments. The IAR will be available to answer any questions about fees and expenses. Cash can be used as a strategic holding for an indefinite period depending on market conditions and will be billed on as an asset class. Item 5 - Account Requirements and Types of Clients Adviser provides investment advisory services to individuals, high-net-worth individuals, mutual funds, trusts, corporations and other businesses. GVCM reserves the right to waive account minimums. GVCM is requiring new accounts to have a Margin agreement on file. GVCM is not trading securities on margin. GVCM is using margin for settlement purposes only, to ensure in fast moving markets that GVCM can efficiently and effectively trade Client accounts without having to wait for settlement. If you have questions please reach out to your Investment Adviser Representative who you opened your account with. Account Minimums GVCM, at its sole discretion, may accept clients with smaller portfolios or lower minimums based upon certain factors including: anticipated future earning capacity, anticipated future additional assets, account composition, related accounts, and pre-existing client relationships. GVCM may consider the portfolios of immediate family members to determine if the client portfolio meets the minimum size requirement. Certain third party asset managers may have higher minimum account requirements which will be described in the account opening documentation. In the event that account values fall below the minimum account value needed to effectively execute trades in client accounts, the account may: 1) not trade until additional funds are added by the client; or 2) GVCM may choose to discontinue its advisory agreement with the client. Item 6 - Portfolio Manager Selection and Evaluation GVCM has contracted Castleview Partners, LLC. (Castleview), a leading provider of wealth management technology and advisory services, to provide administrative, operational and trading services in support of GVCM’s Personalized Managed Account Program. Castleview conducts due diligence of third party asset managers involved in the program, and also provides trading services for GVCM’s SMA Accounts. Personalized Asset Management Program assets will be held by one of the following participating qualified custodians that clients select: Charles Schwab, Jefferson National, Fidelity and Axos. Our use of available custodians is based in part on our existing relationships or those of Castleview; the custodian’s financial strength; reputation; breadth of investment products; and, the cost and quality of custody and brokerage services provided to our clients. The determining factor in the selection of a particular custodian to execute transactions for the client account is not the lowest possible transaction cost, but whether they can provide what is in GVCM’s view the best qualitative execution for investment transactions for the client account. GVCM is independently-owned and operated and not affiliated with any custodian. In addition to brokerage and custody services, the Firm may receive benefits from the custodians, including access to investments generally available to institutional investors; research, software and educational opportunities. Custodians may also make available or arrange for these types of services to be provided to GVCM by independent third parties. Custodians may discount or waive the fees it would otherwise charge for services rendered. The custodian may also pay all or a part of the fees of a third party providing these services to GVCM. Page 8  GVCM receives no economic benefits as a result of its relationship with custodians because GVCM does not have to produce or purchase the products and services listed above. These services are not contingent upon us committing any specific amount of business to the custodians in trading commissions. GVCM does not enter into soft-dollar arrangements with custodians or brokers. Because the amount of products or services GVCM receives may vary depending on the custodian recommended to the client and the amount of client assets in accounts at said custodian, GVCM may have a conflict of interest in making that recommendation. GVCM nonetheless, strives to act in the client’s best interests at all times. The custodians do not charge separately for holding GVCM client accounts, but may be compensated by clients through other transaction-related fees associated with the securities transactions they execute for the client’s account. Commissions and other fees for transactions executed through the custodians recommended may be higher than commissions and other fees available if the client utilizes another custodian firm to execute transactions and maintain custody of client accounts. However, GVCM believes, that the overall level of services and support provided to our clients by our recommended custodians outweighs the benefit of possibly lower transactions cost which may be available under other brokerage arrangements. Many of the services described above may be used to benefit all or a substantial number of our accounts, including accounts not maintained through GVCM recommended custodians. GVCM does not attempt to allocate these benefits to specific clients. Directed Brokerage If clients participate in the Personalized Asset Management Program, the client may not direct GVCM to execute transactions away from the account custodian. Block Trading GVCM, though its TAMP-relationship with Castleview, does engage in “block trading.” Block trading is the purchase or sale of a security in a single transaction for the accounts of multiple clients. Executing a block trade is an advantage to client for three reasons: 1) transaction costs are shared equally across all participating clients; 2) the aggregate trade is executed at an average price and eliminates any conflicts in trading priorities; and 3) block trading allows the trading firm (i.e. Castleview) to “shop” the trade and get best execution. All trading via Castleview is considered block trading: GVCM initiates buy/sell orders by placing model changes on the Castleview platform; Castleview aggregates all client trades in the affected models; and lastly, Castleview the places those block trades with the trading desk at various custodians. Item 7 - Client Information Provided to Portfolio Managers The client authorizes the IAR to provide information to GVCM about the investment goals and objectives, risk tolerance, time horizon, liquidity needs and other financial information that will help determine suitability investment strategies for the account. This information is provided through: • Personalized Asset Management Questionnaire and Proposal; • Custodian account opening documentation and paperwork; and • Product or service vendors related to Program account(s). It is important for the client to contact the IAR to update any changes in the financial circumstances, objectives, or goals. GVCM’s IARs are required to conduct an annual review with their clients. Item 8 - Client Contact with Portfolio Managers The IAR is expected to generally be available to take client calls on advisory- related matters, and to meet with the client no less than annually to review the Program Account and update the information. However, the IAR is not required to be available for unscheduled or unannounced visits or calls. The clients are encouraged to contact the IAR with respect to any changes in the financial information that may affect the management of the account. GVCM regularly monitors models, as well as general conditions in the global stock and bond markets, and recommends Page 9  changes and/or alternate investments or opportunities when GVCM believes it is appropriate to do so. GVCM strongly encourages the client to notify the IAR of any material changes in the overall financial condition or the client’s investment objectives or risk tolerance as these could have a material effect on the investment recommendations. While the client will generally meet with their IAR, GVCM may arrange for one or more other portfolio managers who have particular subject matter expertise to also meet with clients. The client will receive statements from the account custodian, and/or their variable annuity and/or life insurance carrier at least quarterly. These statements identify the current investment holdings, the cost of each investment holding, andrespective current market values. If clients have any questions or concerns regarding activity contained in an account statement, they should contact their IAR. Item 9 - Additional Information Disciplinary Information GVCM has not been the subject of any legal or disciplinary events that would be material to client evaluation of GVCM’s business or the integrity of GVCM’s management. Voting Client Securities As a matter of firm policy and procedure, GVCM does not take any action or give any advice with respect to voting of proxies solicited by or with respect to the issuers of securities in which client accounts may be invested. Clients retain the responsibility for receiving and voting proxies for any and all securities maintained in their portfolios Certain third party asset managers on the Personalized Asset Management Program platform may vote the proxies for the securities in the portfolios they manage. Other Financial Industry Activities and Affiliations AdvisorGuide, LLC AdvisorGuide, LLC is an investment research firm founded by David Morton and majority owned by GVCM. The firm specializes in providing clear, specific, objective and timely market data to investment professionals. Mr. Morton, Dina Fliss and Barry are responsible for research, development and management of GVCM’s multiple strategies. For market research and professional services received from Mr. Morton and AdvisorGuide, LLC. GVCM pays AdvisorGuide, LLC a portion of any annual fees received for GVCM’s services as an investment adviser or sub-advisor. In December 2015, GVCM acquired a 51% ownership stake in AdvisorGuide LLC (with a current 60% ownership stake). Dina Fliss has final decision-making authority on any items related to AdvisorGuide, LLC. Castleview Partners, LLC. GVCM has contracted with Castleview Partners LLC. (Castleview), a provider of wealth management technology and advisory services, to provide administrative, operational and trading services in support of GVCM’s Personalized Managed Account Program. Castleview conducts due diligence of third party asset managers involved in the program, and also provides trading services for GVCM’s proprietary strategies and SMA accounts. In partnership with GVCM, Castleview launched its “turnkey asset management program” (TAMP) on July 1, 2018. Global View Capital Insurance Services, LLC. Global View Capital Insurance Services, LLC. (“GVCI”) is an affiliated company of GVCM. Dina Fliss, President, Chief Compliance Officer and Chief Investment Strategist of GVCM, is an insurance agent and 50% owner of GVCI. Global View Capital Advisors, LLC. Global View Capital Advisors, LLC. (“GVCA”) is an affiliated company of GVCM. GVCA is a marketing company that provides distribution services for products and services designed by GVCM and other third party asset managers. Dina Fliss, President, Chief Compliance Officer and Chief Investment Strategist of GVCM and Dean Fliss, President of GVCA, are equal owners of GVCA. IARs of GVCM that distribute products and services under the name of GVCA have a conflict of interest when selling GVCM products and services because any sales of GVCM products and services may result in additional fees to GVCM. Page 10  The IAR will receive only their customary share of fees or commissions and does not receive additional compensation. Global View Capital Partners, LTD. Global View Capital Partners (“GVCP”) is the parent company of GVCM. Dina Fliss, President, Chief Compliance Officer, and Chief Investment Strategist of GVCM and Dean Fliss, President of GVCA are equal owners of GVCP, GVCM, GVCI and GVCA. Purshe Kaplan Sterling Investments Purshe Kaplan Sterling Investments (“PKS”) is a broker-dealer and member of FINRA and SIPC. Some IARs of GVCM are also Registered Representatives (“RRs”) of PKS. This may pose a conflict of interest for GVCM’s IARs as they may make investment recommendations based upon which entity pays a higher fee or commission. Dean Fliss, President of GVCA, is a RR of PKS. Solicitors/Promotors to Unaffiliated Third Party Investment Advisers GVCM and its IARs may act as a solicitor/promotor and refer clients to third-party investment advisers that offer asset management services to clients. As a result, GVCM and its IARs may be paid a portion of the fee charged and collected by the third party investment adviser in the form of solicitor/promotor fee or referral fees. Each solicitation arrangement is performed pursuant to a written solicitation agreement. GVCM has utilized the following unaffiliated third party investment advisers in limited circumstances: • AMP Wealth Management • Flexible Plan Investments • Hanlon Investment Management • Howard Capital Management, Inc. • Portfolio Strategies, Inc. • The Pacific Financial Group Clients are advised that GVCM and IARs may have a conflict of interest by making a referral to a third party investment adviser that has agreed to pay a portion of its advisory fee to GVCM. Clients are advised that there may be other third party investment advisers that may be suitable to the client that could be more or less costly. Review of Accounts GVCM regularly monitors its models, as well as general conditions in the global stock and bond markets, and recommends changes and/or alternate investments or opportunities when GVCM believes it is appropriate to do so. GVCM strongly encourages the client to notify the IAR of any material changes in the overall financial condition or the client’s investment objectives or risk tolerance as these could have a material effect on the investment recommendations. GVCM’s Branch Managers, who report to the Chief Compliance Officer, supervise the suitability of IAR new client business for GVCM. GVCM’s IARs are required to conduct an annual review with clients. While the client will generally meet with their IAR, GVCM may arrange for one or more other portfolio managers who have particular subject matter expertise to also meet with clients. The client will receive statements from the account custodian, and/or their variable annuity and/or life insurance carrier at least quarterly. These statements identify the current investment holdings, the cost of each investment holding, and respective current market values. If clients have any questions or concerns regarding activity contained in an account statement, they should contact their IAR. Client Referrals and Other Compensation GVCM receives clients primarily from IARs registered with GVCM and affiliated with GVCA. IARs of GVCM that distribute products and services under the name of GVCA have a conflict of interest when selling GVCM products and services because any sales of GVCM products and services may result in additional fees to GVCM. The IARs will receive only their customary share of fees or commissions and do not receive additional compensation as a result of recommending GVCM strategies. Page 11  The maximum IAR fee for Personalized Asset Management Program is 1.4%. IARs of GVCM may act in their own interests by selecting that program or strategy that pays them the highest fee. GVCM may enter into written agreements with certain unaffiliated investment advisers and other professionals (such as CPAs, attorneys, etc.) to compensate them for referring clients to us. GVCM will pay these individuals (referred to as “solicitors/promotors”) a percentage of the advisory fee that client pays GVCM if it is determined that the client became a GVCM client as a result of their direct or indirect efforts. The payments GVC makes to any solicitor/promotor will not result in an increase in the amount of the advisory fee that the referred client will pay to GVCM. GVCM’s solicitation or referral arrangements will comply with applicable laws that govern: • The nature of the services provided; • The fees to be paid; • Disclosure of the solicitor/promotor arrangements to clients; and client consent, as required. Because GVCM does not require prepayment of client fees more than three months in advance, GVCM is not required to provide financial statements. GVCM does not have any financial condition that is reasonably likely to impair its ability to meet its contractual commitments to clients. Further, GVCM has not been the subject of a bankruptcy proceeding. Additional Disclosure Past performance may not be indicative of future results. Different types of investments involve varying degrees of risk. Therefore, it should not be assumed that future performance of any specific investment or investment strategy (including the investments and/or investment strategies recommended and/or undertaken by GVCM), or any non- investment related services, will be profitable, equal any historical performance level(s), be suitable for client portfolios or individual situations, or prove successful. GVCM is neither a law firm nor an accounting firm, and no portion of its services should be construed as legal or accounting advice. Please remember that it remains the clients’ responsibility to advise GVCM in writing, if there are any changes in their personal/financial situation or investment objectives for the purpose of reviewing/evaluating/revising GVCM’s or respective IAR previous recommendations and/or services, or if the client would like to impose, add, or modify any reasonable restrictions to GVCM’s investment advisory services. GVCM utilizes research signals as guidance in determining a proprietary combination of technical, quantitative, and economic indicators to specific exchanged traded funds and mutual funds selected for the various investment programs offered to our client accounts. Buys and Sells may or may not occur on the exact date a signal is received. Trading restrictions may be imposed by investment families, exchanges, custodians, market conditions, or other factors outside of GVCM’s control that may result in the inability to trade all strategies affected on the day a buy or sell signal is generated. GVCM will utilize its best efforts and discretion to minimize the adverse effect of such restrictions. Page 12