Form ADV Part 2B Individual Disclosure Brochure. Alyssa Rakovich AIF

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This brochure supplement provides information about Alyssa Rakovich that supplements the NAMCOA- Naples Asset Management Co., LLC brochure. You should have received a copy of that brochure. Please contact Alyssa Rakovich if you did not receive the NAMCOA - Naples Asset Management Co., LLC s brochure or if you have any questions about the contents of this supplement. Additional information about Alyssa Rakovich is also available on the SEC s website at www.adviserinfo.sec.gov. Form ADV Part 2B Individual Disclosure Brochure for Alyssa Rakovich AIF Personal CRD Number: 3003477 Investment Adviser Representative NAMCOA - Naples Asset Management Co., LLC 999 Vanderbilt Beach Road, Suite 200 Naples, FL 34108 Office: 239.593.5525 Ext. 119 Cell: 941.724.1208 Email: arakovich@namcoa.com Website: www.namcoa.com 1 P age

Item 2: Educational Background and Business Experience Name: Alyssa Rakovich Born: 1973 Educational Background and Professional Designations: BA, College of Charleston, Charleston, SC ETA Sigma Phi Latin and Ancient Greek Honor Society Strategic Operations of International Business Management University of Durham, Hatfield College, Durham England Post-Secondary Education Vanderbilt University, Financial Planning University of Pennsylvania, Wharton Women s Management Forum Examinations & Licenses: General Securities Sales Supervisor Options Module Examination Series 9 General Securities Sales Supervisor General Module Examination Series 10 General Securities Representative Examination Series 7 Uniform Securities Agent State Law Examination Series 63 Uniform Investment Adviser Law Examination Series 65 Life, Annuity, Long-Term Care and Health Insurance Licenses: GA and PA Current Professional Designations: AIF November 8, 2018 Alyssa Rakovich has been awarded the Accredited Investment Fiduciary (AIF ) designation from the Center for Fiduciary Studies (the Center), the standards-setting body for fi360. The AIF designation signifies specialized knowledge of fiduciary responsibility and the ability to implement policies and procedures that meet a defined standard of care. The designation is the culmination of a rigorous training program, which includes a comprehensive, closed-book final examination under the supervision of a proctor, and agreement to abide by the Code of Ethics and Conduct Standards. On an ongoing basis, 2 P age

completion of continuing education and adherence to the Code of Ethics and Conduct Standards are required to maintain the AIF and PPC designations. Based near Pittsburgh, Pa., fi360 is the first full-time training and research facility for fiduciaries and conducts training programs throughout the United States and abroad. The Center for Fiduciary Studies confers the AIF designation as well as the (AIF ) designation. About fi360 fi360 helps its investment advisory clients gather, grow, and protect client assets through better investment and decision-making. Since 1999, fi360 has been providing innovative solutions to financial services providers, including its AIF and PPC training programs, the fi360 Toolkit software, and fi360 Fiduciary Score. Their vision is to be the leading provider of services that raise the level of professionalism in investment management. The Center for Fiduciary Studies The Center for Fiduciary Studies is the standards-setting body for Fi360 and is supported by a team of experienced investment practitioners, attorneys, educators, and other professionals. The Center for Fiduciary Studies develops and maintains the Prudent Practices defined in our handbooks and awards the Accredited Investment Fiduciary (AIF ) professional designation. In addition, the Center is responsible for overseeing the body of knowledge that forms the basis for its curriculum, examinations, and certifying qualifications. Business Background: 9/2018 - Present Naples Asset Management Company, LLC Investment Adviser Representative 2/2016 9/2018 Advisory Group Equity Services LTD. Registered Representative 1/1998 10/2015 Morgan Stanley Registered Representative Associations: 3/2011- Present US Committee for UN Women 3/2011- Present Through Women s Eyes 2/2001- Present Canter Thoroughbred Rescue 1/1991 Present Charleston Area Therapeutic Riding 3 P age

Item 3: Disciplinary Information In 2015 Alyssa was terminated from Morgan Stanley due to a claim bought against her and Morgan Stanley by FINRA whereby FINRA accused Alyssa of engaging in outside business activity while under the employ of Morgan Stanley without seeking or receiving prior approval from her Member Firm Morgan Stanley. In 2017 Alyssa consented to being sanctioned by FINRA without admitting or denying their findings that she engaged in outside business activity while under the employ of Morgan Stanley without seeking or receiving prior approval from her Member Firm Morgan Stanley. Alyssa was given a civil and administrative penalty of $5,000 and suspended from Investment Advisory Service provisioning for 30 days. This matter was restricted to FINRA and did not involve an SEC violation. In 2018 a claimant, MSSB, did allege that Alyssa failed to properly supervise certain staff under her oversight at Morgan Stanley relative to certain specific trading activities undertaken by certain Morgan Stanley employees who operated within the firm segment she oversaw. No findings have as yet resulted as Alyssa has challenged the claim given that the trading activities in question occurred subsequent to her leaving Morgan Stanley. Alyssa Rakovich, through her legal counsel is seeking to have this matter permanently expunged from her record. Alyssa was not a named party in the Statement of Claim and she categorically denies the allegation that she failed to supervise the broker during the brief period that she was the Branch Office Manager in 2011-2012. Item 4: Other Business Activities Alyssa Rakovich is a licensed insurance agent. From time to time, she will offer clients advice or products from this activity. Clients should be aware that these services pay a commission and involve a possible conflict of interest, as commissionable products can conflict with the fiduciary duties of a registered investment adviser. Naples Asset Management Co., LLC always acts in the best interest of the client; including in the sale of commissionable products to advisory clients. Clients are in no way required to implement the plan through any 4 P age

representative of Naples Asset Management Co., LLC in their capacity as a licensed insurance agent. Below are current business activities outside the scope of Naples Asset Management Company, LLC that Alyssa Rakovich is involved: INY LLC 1201 Orange St Ste 600 Wilmington, DE 19801, Position: Consultant, 10-31- 2016 to present. Business/Activity: Provide various business consulting and training for financial advisors, approximately 2 hours a month consulting, non-investment related. Verified Capital, LLC. 620 Catherine Foster Lane, St Johns, FL 32259 to present. Position: 50% shareholder and Consultant. 4-24-2018 to present Privately Held Business/Activity: Verifi is a fin tech digital payment system with proprietary security proponents to ensure the safety and protect the privacy of the consumer with data transfer. Approximately 2 hours a month consulting, non-investment related. AutoRive MotorClub, Inc. 1835 Newport Blvd. A109 PMB 529 Costa Mesa, CA 92627, 6-1-2018 to present. Position: 9% Owner and Consultant Privately Held Business/Activity: AutoRive is an auto subscription company. Approximately 10 hours a month consulting, non-investment related. Mims Motor Corporation, Inc. 6867 Speedway Blvd, Las Vegas, Nevada 9-1-2018 to present. Position: Consultant. Business/Activity: Mims is the first minority owned electric auto manufacturer. Approximately 4 hours a month consulting, noninvestment related. Blockchain Industries Inc. 730 Arizona Ave., Suite 220, Santa Monica, California 90401, 9-15-18 to present. Position: Consultant. Business/Activity: Business development, Place what does the business do? Approximately 4 hours a month consulting, noninvestment related. Item 5: Additional Compensation Alyssa Rakovich may from time to time receive referral fees from Verifi Capital for referring merchant vendors, who utilize their payment processing services. Alyssa may receive referral fees for referring AutoRive subscribers. Alyssa may receive future compensation from Mims Motor Corporation for consulting with them on white labeling their own captive financing. Alyssa may receive equity and compensation for referring potential clients to Blockchain Industries. Alyssa s main economic benefit is from Naples Asset Management Co., LLC in 5 P age

exchange for providing clients advisory services through Naples Asset Management Co., LLC. Item 6: Supervision As a representative of Naples Asset Management Co., LLC, Alyssa Rakovich is supervised by Paul McIntyre, the firm's Chief Compliance Officer. Paul McIntyre is responsible for ensuring that Alyssa Rakovich adheres to all required regulations regarding the activities of an Investment Adviser Representative, as well as all policies and procedures outlined in the firm s Code of Ethics and compliance manual. The phone number for Paul McIntyre is (239) 287-3789. 6 P age