BIECHELE ROYCE ADVISORS

BRA provides sub-advisory services to other registered investment advisers (RIAs), tailoring the scope of services to meet each RIA's specific needs. These services typically include investment portfolio analysis, proposal development and review, client meeting support, and answering questions about BRA's methods and approach. Additionally, BRA offers support services to help RIAs manage and develop their businesses, including educational events, distribution platforms, compliance consulting, and access to various providers. BRA continuously monitors the underlying securities within sub-advisory accounts, considering the stated investment objectives and guidelines provided by the client's investment adviser. However, it is the responsibility of the other investment adviser to inform BRA of any updates required to the portfolio based on changes in client needs or circumstances. BRA does not send account statements or provide reports to other investment advisors or their clients.

**Paragraph 1:** Biechele Royce Advisors employs an active management approach with a value focus to construct diversified, multi-asset class portfolios. They believe this strategy provides the best opportunity for clients to achieve their financial goals while managing risk in overvalued markets. The firm tactically adjusts asset class weightings based on their evaluation of value characteristics. **Paragraph 2:** For clients in the accumulation stage, equity investments are favored for long-term growth, supplemented by a small fixed income component for diversification. As clients approach retirement and enter the preservation stage, the portfolio gradually transitions to include more income-generating components, such as fixed income and hedged investments, to enhance diversification and reduce risk.

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