Firm Description and Types of Advisory Services
Finaccess Advisors is a registered investment advisor formed in 2009 in the state of Delaware and registered to conduct business in the state of Florida. Finaccess Advisors maintains its primary office in Miami, Florida.
Principal Owners
Finaccess Advisors is primarily owned by Grupo Finaccess, S.A.P.I. de C.V. Carlos Fernandez Gonzalez’ interest in Grupo Finaccess S.A.P.I. de C.V. represents more than 25 percent of the voting shares.
Types of Advisory Services
Finaccess Advisors primarily offers wealth management and investment advisory services.

On more than an occasion, Finaccess Advisors furnishes advice to clients on matters not involving securities, such as financial planning matters, retirement planning, trust services that often include estate planning and educational services. Finaccess Advisors provides personalized confidential financial planning, investment management, financial advisory and wealth management services to individuals, corporations, and trusts worldwide. Advice is provided through consultation with the client and may include: determination of financial objectives, identification of financial problems, cash flow management, review of insurance needs, investment management, retirement planning, estate planning and educational services.

Investment advice is an integral part of financial planning. In addition, Finaccess Advisors advises clients regarding cash flow, retirement planning and estate planning.

Finaccess Advisors also serves as the investment adviser to several Funds, structured as open-end investment companies incorporated in Luxembourg and Mexico. Finaccess Advisors provides investment advice and recommendations to the Funds’ investment manager in relation to the Funds in accordance to the Investment Advisory Agreement (“IAA”). Specifically, Finaccess Advisors proposes and identifies and evaluates a portfolio of investments which may be appropriate for the Funds, analyzes the progress of investments, as well as analyzing all actions that it considers appropriate in order to carry out the investment guidelines. The investment manager may, at its sole discretion, follow the Adviser’s advice and recommendations or elect not to utilize such information. This arrangement represents a conflict of interest since it provides a different economic incentive for Finaccess Advisors to recommend investments in the Funds. Finances Advisors may recommend that a non-fund client invest in one or more Funds, which Finaccess Advisors does not act as a custodian of client assets. P a g e | 5 Finaccess Advisors, through its Investment Committee, is responsible for recommending investments based on the client’s investment planning objectives and risk tolerance.
Investment Advisory Agreement (“IAA”)
Finaccess Advisors provides advisory and other services to clients pursuant and outlined in its IAA. Most clients choose to have Finaccess Advisors assist them in managing their assets in order to obtain ongoing in-depth advice and life planning. All aspects of the client’s financial affairs are reviewed by Finaccess Advisors, including for individuals and their dependent children. Realistic and measurable goals are set based on consultations between Finaccess Advisors and each client and objectives to reach those goals are defined. As a client’s goals and objectives change over time, Finaccess Advisors makes non-discretionary investment recommendations to the client concerning its investments and methods for implementing the recommendations.

The scope of services covered in the IAA may include: cash flow management; review of insurance needs; investment management (including performance reporting); education planning; retirement planning; estate planning, as well as the implementation of recommendations within each area. Finaccess Advisors does not participate in any wrap fee programs. The scope of the services covered in the IAA include solely investment advice and recommendations to the Funds in accordance with the terms of the agreement.
Wealth Management Services
Finaccess Advisors provides Wealth Management Services that include: budgeting and expense management, real estate management, estate planning, review of insurance needs, coordination of tax advisors, bookkeeping and recordkeeping, access to private banking and private trusts services, and support as well as assisting in the monitoring and generation of reports and governance services.
Tailored Relationships
Finaccess Advisors’ advisory services are individually tailored to the specific needs, goals and objectives of each client. Clients may impose restrictions on investing in certain securities or types of securities.
Client Assets
As of December 31, 2018, Finaccess Advisors managed approximately $4,185,905,500 in assets on a non-discretionary basis. Finaccess Advisors does not manage any assets on a discretionary basis. P a g e | 6 please register to get more info

Compensation
Finaccess Advisors seeks to establish fees and compensation structure with its clients consistent with its expertise, customized services continued obligations of ensuring such fees are fair and reasonable to its customers. As such Finaccess Advisors has established both fee/compensation structure based upon assets managed for “Non-Fund Clients” and compensation from “Funds”.

 Compensation from Non-Fund Clients

Finaccess Advisors receives compensation from its clients indirectly by receiving an agreed upon portion of the fees paid by the client to custodians referred to the client by Finaccess Advisors. Those fees are based on a percentage of the average value of investable assets under management. The fees to be paid to Finaccess Advisors are established in a Referral Agreement between Finaccess Advisors and the custodian. Information about this arrangement and related compensation is provided to each client by Finaccess prior to the client’s engagement of the custodian or discretionary adviser.

Services fees are debited directly by the authorized custodian and are based on a percentage of the average value of investable assets under management. Finaccess receives an agreed upon custodian paid fee equal to a percent of the sum of all fees charged by the custodian to the Finaccess Advisors client or received by the custodian for services provided to the Finaccess Advisors client.

 Compensation from Funds

Finaccess Advisors receives compensation from the Funds for advisory services to the Funds according to the terms of the IAA. The client investing in the Funds will indirectly pay its pro rata portion of the Funds’ management or advisory fee to Finaccess Advisors to the extent assets in the client’s account are invested in the Funds.
Calculation and Payment
The custodian calculates the amount it owes Finaccess Advisors under the Referral Agreement and remits payment to Finaccess Advisors within thirty (30) days from the last day of the previous calendar quarter. Referral fees may be prorated for each capital contribution and withdrawal made during the applicable calendar quarter. Accounts initiated or terminated during a calendar quarter will be charged a prorated fee. Clients’ assets invested in the Funds will be excluded from this calculation as any fees related to the Funds is charged directly to the investment manager. For its advisory services to the Funds, the advisory fee is equal to a percentage of the net asset value of each Fund to which Finaccess Advisors provides advisory services, and is payable P a g e | 7 quarterly in arrears after the end of the relevant quarter. The advisory fee accrues on each valuation day, in proportion to the net asset value of each class of shares of the Fund as of such valuation day. The Fund calculates the amount owed to Finaccess Advisors pursuant to the terms outlined in the IAA.
Payment of Wealth Management Services
Finaccess Advisors charges an annual fixed fee for Wealth Management Services. Finaccess Advisors will invoice the customer in advance on a quarterly basis.
Termination of IAA Non Fund Clients
Either party may terminate the IAA (i) upon 60 days’ notice to the other party or (ii) immediately upon notice to the other party in the event of a breach by the defaulting party of a material obligation under the IAA. At termination, Investment Advisory Service and Family Office Service fees will be billed on a pro rata basis for the portion of the quarter completed.
Termination of IAA Fund Clients
Either party may terminate the IAA, for any reason or for no reason, by providing to the other party not less than three months’ prior written notice, or (ii) immediately upon written notice to the other party in the event of liquidation, winding up, gross negligence, breach a material term under the IAA, and agreement or composition with any of its creditors. At termination, the Funds will pay Finaccess Advisors for all advisory services due up to the date of such termination.

Other Compensation
Neither Finaccess Advisors nor any of its supervised persons (employees) accept compensation for the sale of securities or other investment products.
General Information on Compensation and Other Fees
Finaccess Advisors’ fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which are incurred by the client. In addition, Finaccess’ fees do not include investment advisory and other similar management fees charged by advisers to mutual funds and exchange-traded funds in which a client may invest. Clients may incur certain charges imposed by custodians, brokers, third party investment advisers and other third parties such as fees charged by managers, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. P a g e | 8 All fees paid to Finaccess Advisors for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds to their shareholders, except as they related to Investment Advisory Fees paid by funds to which Finaccess is an Advisor. In instances where Finaccess serves as an Advisor to offshore funds, Finaccess will receive compensation from the Funds and will not charge any fees directly to clients who invested in these particular funds. Mutual funds fees and expenses are described in each fund’s or sub account’s prospectus. These fees will generally include a management fee, other expenses, and a possible distribution fee. If the fund also imposes sales charges, a client may pay an initial or deferred sales charge.

A client could invest in a mutual fund or sub-account directly, without the services of Finaccess Advisors. In that case, the client would not receive the services provided by Finaccess Advisors which are designed, among other things, to assist the client in determining which mutual funds or sub-accounts are most appropriate to each client’s financial condition and objectives. Accordingly, the client should review both the fees charged by the funds/sub-accounts and the fees charged by Finaccess Advisors to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Clients should note that similar advisory services may (or may not) be available from other registered investment advisers for similar, lower or higher fees. P a g e | 9 please register to get more info

Performance-Based Compensation
Neither Finaccess Advisors nor any of its supervised persons (employees) receives or is entitled to receive performance-based compensation (fees based on a share of capital gains on or capital appreciation of the assets of a client) from clients. P a g e | 1 0 please register to get more info

Types of Clients
As described in Item 3, Finaccess Advisors provides investment advisory services to individuals, high net worth individuals, corporations, trusts, and SICAV and Mexican Investment Funds. Client relationships vary in scope and length of service.
Account Minimums
Finaccess Advisors does not require a minimum dollar value of assets under management or account minimum. P a g e | 1 1 please register to get more info

Methods of Analysis
Finaccess Advisors may employ the following security analysis methods: fundamental analysis; charting/technical analysis; and cyclical analysis.

Finaccess Advisors uses the following methods of analysis in formulating its investment advice and/or managing client assets:

 Fundamental Analysis. Finaccess Advisors attempts to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell).

Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock.  Charting/Technical Analysis. The terms “charting” and “technical” analysis are generally used synonymously and therefore, for the purpose of this document, the term, “technical analysis” will be used. Finaccess Advisor analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement.

Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly-managed or financially unsound company may underperform regardless of market movement.  Cyclical Analysis. In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security.
Investment Strategies
The investment strategy for a specific client is based upon the objectives stated by the client during consultations. The client may change these objectives at any time. Other strategies may include long-term purchases, short-term purchases and trading. P a g e | 1 2
Risk of Loss
While it is the intention of Adviser to implement strategies which are designed to minimize potential losses suffered by its client, there can be no assurance that such strategies will be successful. The following is a discussion of typical risks for Adviser’s clients, but it does not purport to be a complete explanation of the risks involved with Adviser’s investment strategies.

 Interest-rate Risk: Fluctuations in interest rates may cause investment prices to fluctuate. For example, when interest rates rise, yields on existing bonds become less attractive, causing their market values to decline.  Market Risk: The price of a security, bond, or mutual fund may drop in reaction to tangible and intangible events and conditions. This type of risk is caused by external factors independent of a security’s particular underlying circumstances. For example, political, economic and social conditions may trigger market events.  Inflation Risk: When any type of inflation is present, a dollar today will not buy as much as a dollar next year, because purchasing power is eroding at the rate of inflation.  Currency Risk: Overseas investments are subject to fluctuations in the value of the dollar against the currency of the investment’s originating country. This is also referred to as exchange rate risk.  Reinvestment Risk: This is the risk that future proceeds from investments may have to be reinvested at a potentially lower rate of return (i.e. interest rate). This primarily relates to fixed income securities.  Business Risk: These risks are associated with a particular industry or a particular company within an industry. For example, oil-drilling companies depend on finding oil and then refining it, a lengthy process, before they can generate a profit. They carry a higher risk of profitability than an electric company, which generates its income from a steady stream of customers who buy electricity no matter what the economic environment is like.  Liquidity Risk: Liquidity is the ability to readily convert an investment into cash. Generally, assets are more liquid if many traders are interested in a standardized product. For example, Treasury Bills are highly liquid, while real estate properties are not.  Financial Risk: Excessive borrowing to finance a business’ operations increases the risk of profitability, because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value.  Issuer-Specific Changes: Changes in the financial condition of an issuer or counterparty, changes in specific economic or political conditions that affect a particular type of security or issuer, and changes in general economic or political conditions can increase the risk of default by an issuer or counterparty, which can affect a security’s or instrument’s value. The value of securities of smaller, less well-known P a g e | 1 3 issuers can be more volatile than that of larger issuers. Smaller issuers can have more limited product lines, markets, or financial resources.  Equity Securities: The value of equity securities fluctuates in response to issuer, political, market, and economic developments. Fluctuations can be dramatic over the short term as well as long term, and different parts of the market and different types of equity securities can react differently to these developments. For example, large cap stocks can react differently from small cap stocks, and “growth” stocks can react differently from “value” stocks. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer can impact the market as a whole. Terrorism and related geo-political risks have led, and may in the future lead, to increased short-term market volatility and may have adverse long- term effects on world economies and markets generally.  Fixed-Income and Debt Securities: Investment in fixed-income and debt securities such as bonds, notes and asset-backed securities, subject a client’s portfolios to the risk that the value of these securities overall will decline because of rising interest rates. Similarly, portfolios that hold such securities are subject to the risk that the portfolio’s income will decline because of falling interest rates. Investments in these types of securities will also be subject to the credit risk created when a debt issuer fails to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that debt to decline. Lastly, investments in debt securities will also subject the investments to the risk that the securities may fluctuate more in price, and are less liquid than higher-rated securities because issuers of such lower-rated debt securities are not as strong financially, and are more likely to encounter financial difficulties and be more vulnerable to adverse changes in the economy.  Non-U.S. Securities: Foreign securities, foreign currencies, and securities issued by U.S. entities with substantial foreign operations can involve additional risks relating to political, economic, or regulatory conditions in foreign countries. These risks include fluctuations in foreign currencies; withholding or other taxes; trading, settlement, custodial, and other operational risks; and the less stringent investor protection and disclosure standards of some foreign markets. All of these factors can make foreign investments, especially those in emerging markets, more volatile and potentially less liquid than U.S. investments. In addition, foreign markets can perform differently from the U.S. market. P a g e | 1 4 please register to get more info

Registered Investment Advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of an adviser or the integrity of the Adviser’s management. The Adviser has no information applicable to this Item at this time. P a g e | 1 5 please register to get more info

Financial Industry Activities
Finaccess Advisors is not registered as a broker-dealer, and none of its management persons are registered representatives of a broker-dealer. Neither Finaccess Advisors nor any of its management persons is registered as (or associated with) a futures commissions merchant, commodity pool operator, or a commodity trading advisor.
Financial Industry Affiliations
Finaccess Advisors is owned by Grupo Finaccess, S.A.P.I. de C.V. Finaccess Mexico, S.A. de C.V., Sociedad Operadora de Sociedades de Inversion “Finaccess Mexico” is a private company founded in 2000 and is primarily owned by Grupo Finaccess S.A.P.I. de C.V., a company formed by a group of private investors. Finaccess Mexico was incorporated and exists under the laws of the United Mexican States and licensed by the Comisión Nacional Bancaria y de Valores (“CNBV”) in Mexico to operate, manage, and distribute mutual funds, with management fees ranging from 1 to 160 basis points. As a member of CNBV, Finaccess Mexico is examined by its primary regulator on a periodic (biennial) basis. Finaccess Mexico and Finaccess Advisors do not share any supervised persons or physical location however are under common control. Potential conflicts of interest are disclosed to each client. Finaccess Advisors refers its clients to various discretionary investment advisers and receives compensation from those advisers for such referrals. This practice by Finaccess Advisors may create a material conflict of interest due to incentive to recommend certain advisers over those with which Finaccess Advisors does not have referral arrangements. Finaccess Advisors addresses conflicts of interest derived from this practice by disclosing to client its referral arrangements and related compensation prior to the client’s engagement of a discretionary adviser recommended by Finaccess Advisors. Certain indirect owners of Finaccess Advisors maintain board member and other associations with companies utilized by the Adviser for custody and investment purposes. Additionally, such owners (who are also clients of the Adviser) along with other clients maintain security positions in companies where indirect owners of Finaccess maintain board member associations. Finaccess notes, this board member association creates a disclosable conflict with certain aspects of the Adviser’s business arrangements and customers. Finaccess does not factor such board member associations in determining custody or other service arrangements utilized by the Adviser and reviews these operational structures, parties and investment decisions in its Investment and Audit Committees to continuously assess objectivity and independence. P a g e | 1 6 please register to get more info

Personal Trading
Code of Ethics
Employees of Finaccess Advisors are subject to a Code of Ethics and Statement for Insider Trading. The Code describes Advisers’ high standard of business conduct, and fiduciary duty to its clients. The Code’s key provisions include:

 Statement of General Principles;  Policy on and reporting of Personal Securities Transactions;  A prohibition on Insider Trading;  Restrictions on the acceptance of significant gifts;  Procedures to detect and deter misconduct and violations; and  Requirement to maintain confidentiality of client information.

Daniel Diaz, Chief Compliance Officer reviews all employee trades at least on a quarterly basis. Finaccess Advisors’ employees must acknowledge the terms of the Code of Ethics at least annually. Any individual not in compliance with the Code of Ethics may be subject to termination. Clients and prospective clients can obtain a copy of Finaccess Advisors’ Code of Ethics by contacting Daniel Diaz at (305) 377-1112.
Participation or Interest in Client Transactions – Personal Securities Transactions
Finaccess Advisors and its employees may buy or sell securities identical to those recommended to clients for their personal accounts. The Code of Ethics, described above, is designed to assure that the personal securities transactions, activities and interests of the employees of Finaccess Advisors will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities, primarily mutual funds, have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of Finaccess Advisors’ clients. In addition, the Code requires pre- clearance of many transactions. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and designed to reasonably prevent conflicts of interest between Finaccess Advisors and its clients.
Participation or Interest in Client Transactions – Financial Interest and Principal/Agency
Cross
Finaccess Advisors and its employees do not recommend to clients, or buy or sell for client accounts, securities in which they have a material financial interest. P a g e | 1 7 The Adviser does not affect any principal or agency cross securities transactions for client accounts. Finaccess Advisors will also not cross trades between client accounts. P a g e | 1 8 please register to get more info

Research and Other Soft Dollar Benefits
Finaccess Advisors provides non-discretionary advisory services and does not select brokers to execute client transactions or receive formal soft dollar benefits in connection with client securities transactions.
Brokerage for Client Referrals
Finaccess Advisors does not receive client referrals from other broker-dealers or investment advisors.
Best Execution
To the extent it has the discretion to select brokers to execute securities transactions, Finaccess Advisors seeks to obtain best execution of such transactions. The Adviser may consider the quality and reliability of brokerage services, as well as research and investment information and other services provided by brokers and dealers. Factors considered by Finaccess Advisors in selecting brokers and dealers may include the following: price, the broker's or dealer's facilities, reliability and financial responsibility; the ability of the broker or dealer to effect securities transactions, particularly with regard to such aspects as complexity of the trade, timing, order size and execution of orders; and the research and other services provided by that broker or dealer to Finaccess Advisors that are expected to enhance our general portfolio manager capabilities, notwithstanding that a client may not be the direct or exclusive beneficiary of such services. Commission rates, being a component of price, are one factor considered together with other factors. Accordingly, Finaccess Advisors in its discretion, may cause a client to pay a commission for effecting a transaction that may be in excess of the amount another broker would have charged for effecting that same transaction and this may be done where we have determined in good faith that the commission is reasonable in relation to the value of the brokerage and/or research services provided by the broker or dealer to our client(s). The commissions paid by Finaccess Advisors’ clients shall comply with Finaccess Advisors’ duty to obtain “best execution.” However, a client may pay a commission that is higher than another qualified broker-dealer might charge to effect the same transaction where Finaccess Advisors determines, in good faith, that the commission is reasonable in relation to the value of the brokerage and research services received. In seeking best execution, the determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealers service, including among others, the value of research provided, execution capability, commission rates, and responsiveness. Consistent with the foregoing, while Finaccess Advisors will seek competitive rates, it may not necessarily obtain the lowest possible commission rates for client transactions.
Trade Aggregation
Finaccess Advisors does not aggregate or block trades. P a g e | 1 9 please register to get more info

Reviews
The Investment Committee of Finaccess Advisors reviews accounts on a periodic basis, typically on a monthly basis, or when market conditions dictate or at any time upon request of the client. Finaccess Advisors’ Investment Committee is responsible for recommending investments based on a client’s investment planning objectives and risk tolerance Other conditions that may trigger a review are changes in market, political or economic conditions, tax laws, new investment information, and changes in a client's own situation. Account reviewers are members of Adviser's Investment Committee. They are instructed to consider the client's current security positions and the likelihood that the performance of each security will contribute to the investment objectives of the client.
Reporting
Clients receive consolidated reports from the Adviser on a periodic basis, but no less than on an annual basis. P a g e | 2 0 please register to get more info

Other Compensation
Finaccess Advisors refers its clients to various discretionary investment advisers or Investment Funds and receives compensation from those advisers for such referrals. This practice by Finaccess Advisors may create a material conflict of interest due to incentive to recommend certain advisers over those with which Finaccess Advisors does not have referral arrangements. Finaccess Advisors addresses conflicts of interest derived from this practice by disclosing to client its referral arrangements and related compensation prior to the client’s engagement of a discretionary adviser recommended by Finaccess Advisors. P a g e | 2 1 please register to get more info

Custody – Fee Debiting
Client assets are maintained at qualified custodians selected by the client. The custodian is advised in writing of the limitation of Finaccess Advisors’ access to the account. The custodian sends a periodic account statement to the client reflecting amounts disbursed from the account.
Custody – Account Statements
As described above, clients receive periodic statements from the broker-dealer, bank or other qualified custodian that holds and maintains client assets. At the discretion of the client, Finaccess Advisors is provided with copies of statements or given password protected online access to statements. Finaccess also utilizes account aggregation software to access the daily activity and performance of many of its clients. The availability of a client’s daily activity and performance is dependent upon the client’s custodian and the availability of a data feed to the account aggregation entity utilized by Finaccess Advisors. Clients are urged to carefully review statements and other reports received from the custodian with those provided by Finaccess Advisors. Finaccess Advisors reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. P a g e | 2 2 please register to get more info

Finaccess Advisors provides investment advisory services on a non-discretionary basis only. P a g e | 2 3 please register to get more info

Finaccess Advisors does not have any authority to vote proxies on behalf of clients. Clients retain the responsibility for voting proxies for securities maintained in their portfolios; clients receive these proxies directly from either custodians or transfer agents. If requested, Finaccess Advisors may provide advice to clients regarding proxy votes. Clients may contact Daniel Diaz at (305) 377-1112 for information about proxy voting policies. P a g e | 2 4 please register to get more info

Registered investment advisers are required in this Item 18 to provide you with certain financial information or disclosures about the Adviser’s financial condition. The Adviser does not require prepayment of any fees, has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients, and has not been the subject of a bankruptcy proceeding. please register to get more info