bustamanteco adv part 2 - 20160222

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ITEM 1 COVER PAGE FORM ADV PART 2: FIRM BROCHURE Bustamante & Co. LLC 2/22/16 Bustamante & Co. LLC 11225 N. 28th Drive, # B216 Phoenix, AZ 85029 4806485773 www.bustamanteco.com This brochure provides information about the qualifications and business practices of Bustamante & Co. LLC. If you have any questions about the contents of this brochure, please contact us at 4806485773. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about Bustamante & Co. LLC also is available on the SEC's website at www.adviserinfo.sec.gov. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training. 1

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Page 1: Bustamanteco Adv Part 2 - 20160222

ITEM 1 COVER PAGE

FORM ADV PART 2: FIRM BROCHURE

Bustamante & Co. LLC 2/22/16 Bustamante & Co. LLC 11225 N. 28th Drive, # B­216 Phoenix, AZ 85029 480­648­5773 www.bustamanteco.com This brochure provides information about the qualifications and business practices of Bustamante & Co. LLC. If you have any questions about the contents of this brochure, please contact us at 480­648­5773. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (the “SEC”) or by any state securities authority. Additional information about Bustamante & Co. LLC also is available on the SEC's website at www.adviserinfo.sec.gov. Registration with the SEC or with any state securities authority does not imply a certain level of skill or training.

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ITEM 2 MATERIAL CHANGES Item 4­ Advisory Business. Since Bustamante & Co’s last amendment on 1/6/2016 we have suspended all services related to the consultation and sales of annuities and insurance products. Also, Bustamante & Co. will no longer offer paid workshops or seminars for clients and prospective clients. Bustamante & Co. main lines of business will be financial planning and investment supervisory services to high net worth families and business professionals on a wrap fee basis (See. Item 4­Wrap Fee Programs). Bustamante & Co has moved our principal office to 11225 N. 28th Dr. Phoenix, AZ 85029 # B­216 The firm may at any time update this document and either send a copy of its updated brochure or provide a summary of material changes to its brochure and an offer to send an electronic or hard copy form of the updated brochure. Clients are also able to download this brochure from the SEC’s Website: www.adviserinfo.sec.gov or may contact our firm at 480­648­5773 to request a copy at any time.

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ITEM 2 TABLE OF CONTENTS ITEM 1 COVER PAGE__________________________________________________________1 ITEM 2 MATERIAL CHANGES___________________________________________________2 ITEM 3 TABLE OF CONTENTS__________________________________________________3 ITEM 4 ADVISORY BUSINESS_________________________________________________4­5 ITEM 5 FEES AND COMPENSATION____________________________________________6­8 ITEM 6 PERFORMANCE BASED FEES AND SIDE­BY­SIDE

MANAGEMENT_________________________________________________________9 ITEM 7 TYPES OF CLIENTS____________________________________________________10 ITEM 8 METHODS OF ANALYSIS, INVESTMENTS STRATEGIES AND

RISK OF LOSS______________________________________________________11­15 ITEM 9 DISCIPLINARY INFORMATION___________________________________________16 ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND

AFFILIATIONS_________________________________________________________17 ITEM 11 CODE OF ETHICS, PARTICIPATION IN CLIENT TRANSACTIONS

AND PERSONAL TRADING___________________________________________18­19 ITEM 12 BROKERAGE PRACTICES____________________________________________20­21 ITEM 13 REVIEW OF ACCOUNTS_________________________________________________22 ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION_________________________23 ITEM 15 CUSTODY_____________________________________________________________24 ITEM 16 INVESTMENT DISCRETION______________________________________________25 ITEM 17 VOTING CLIENT SECURITIES____________________________________________26 ITEM 18 FINANCIAL INFORMATION_______________________________________________27 ITEM 19 REQUIREMENTS FOR STATE REGISTERED

ADVISORS____________________________________________________________28 FORM ADV PART 2B­BROCHURE SUPPLEMENT________________________________________28

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ITEM 4 ADVISORY BUSINESS Bustamante & Co. LLC (“Registrant”, “Bustamante & Co.”, “we”, or “Adviser”) is a Arizona limited liability company established in 2016. Registrant's principal owner is Steven D. Bustamante. Registrant is registered as an investment adviser within the state of Arizona. Bustamante & Co. and its associates may register or meet certain exemptions to registration and/or licensing in other jurisdictions in which we conduct investment advisory business. Bustamante & Co. provides discretionary investment advisory and financial planning services to a variety of high net worth individuals and families. Through our investment strategies (each a “motif” and collectively, the “motifs”) we manage four portfolios that are characterized as conservative to aggressive in allocation. Bustamante & Co. also provides modular planning for clients such as retirement planning, risk management, estate planning, and related consultative services. We pursue an event driven, value­oriented strategy that spans across a broad range of industries, geographies and asset classes within our portfolios. Bustamante & Co. periodically rebalances and adjusts the “motifs” based on manager's discretion while maintaining proper risk allocation on the client's behalf. During or prior to client's first meeting Bustamante & Co., clients will be provided current Form ADV Part 2 advisory brochure 2 that includes a statement with regard to our privacy policy. We will also ensure that we disclose any material conflicts of interest that could be reasonably expected to impair the rendering of unbiased and objective advice. Should clients wish to engage Bustamante & Co. LLC for its advisory services, we must first enter into a written agreement (our client services agreement).Thereafter, discussion and analysis will be conducted to determine clients financial needs, goals, holdings, etc. It is important that the information and/or financial statements clients provide are accurate. We may, but is not obligated to, verify the information clients have provided, which will then be used in the investment advisory process. Depending on the scope of the engagement, clients may be asked to provide current copies of the following documents early in the process:

Wills, codicils and trusts Divorce decree Insurance Policies Mortgage information Financial data that may include tax returns, W­2s or 1099s and/or pay stubs Information on retirement plans and benefits provided by clients employers Stock options employer plans Employment or other business agreements clients may have in place Statements reflecting current investments in retirement and non­retirement accounts Credit card balances and interest rates

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Broad‐Based v. Modular Financial Planning A broad‐based plan is an endeavor that requires detail, therefore, certain variables can affect the cost involved in the development of the plan: the quality of client's records, complexity and number of current investments, diversity of insurance products and employee benefits clients currently hold, size of the potential estate, and special needs of the client or their dependents, among others. While certain broad‐based plans may require 10 or more hours to complete, complex plans may require more than 20 hours. Alternatively, we may concentrate on reviewing only a specific area (modular planning), such as college funding, a portfolio allocation, divorce planning issue, or evaluating the sufficiency of clients retirement plan. Note that when these services focus only on certain areas of client's interest or need, client’s overall situation or needs may not be fully addressed due to limitations clients may have established. In all instances involving our financial planning and investment consultation services, our clients retain full discretion over all implementation decisions and are free to accept or reject any recommendation we make. Whether we have created a broad‐based or modular plan, we will present client’s with a summary of our recommendations, guide clients in the implementation of some or all of them per client’s decision, as well as offer you periodic reviews thereafter (see Item 13). Investment Account Restrictions As stated in client's IPS or similar document, we will account for any reasonable restrictions client’s may require for the management of client's investment account(s). We want to note that it will remain client's responsibility to promptly notify us if there is any change in their financial situation and/or investment objectives for the purpose of our reviewing, evaluating or revising previous account restrictions or firm investment recommendations. Wrap Fee Programs Our firm acts as a sponsor and serves as a portfolio manager in the investment program involving wrapped fee program. Client Assets Under Management As of February 1, 2016 our reportable assets under management has been $0 under discretionary agreements.

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ITEM 5 FEES Bustamante & Co. LLC, typically receives an annual wrap fee of 4% on assets under management which is broken down into three “tranches”. Bustamante & Co. does not assess its wrap fees on ending quarterly balances, we assess our fees on a fixed starting AUM when client hires Bustamante & Co. Unlike other firms who have a higher or lower AUM fee for differing investment amounts client's place with them, Bustamante & Co. wrap fee is 4% regardless of investment amount. Bustamante & Co. incorporates a model of breaking our 4% wrap fee into tranches where “tranche 2” and “tranche 3” are NOT paid out to Bustamante & Co. unless we meet certain “metrics”. For example, a client with an account value of $250,000 when starting with Bustamante & Co. will have the following tranche wrap fee assessed. Tranche 1­ 0.060% (60 basis points)($1500) which is paid up­front (30 day­refund policy) by the client to incorporate data discovery, comprehensive risk assessment for portfolio selection, and deliverance and implementation of client's financial plan. Tranche 2­ 1.40% (140 basis points)($3500) which is only paid out to Bustamante & Co if the following “triggers” are “activated” between the client and Bustamante & Co.

Trigger 1: A 4m anniversary ending on the last day of the fourth month has taken place since client have engaged advisory services with Bustamante & Co. This will be classified as the date client has signed the advisory agreement with Bustamante & Co.

Trigger 2: Client has had at least 1 comprehensive review with Bustamante & Co and has listened in

on at least 1 end of month conference call.

Trigger 3: Client’s portfolio whether in a conservative allocation, aggressive allocation, or a blend of the 4 “motif portfolios” based on their IPS statement is within the “comparative band” NET of tranche 2’s 140 basis point wrap fee.

Tranche 2 only gets paid out to Bustamante & Co if the following three “triggers” above are “activated”. If for example four months pass and clients portfolio performance net of “tranche 2” fee is not within the “comparative band” Bustamante & Co. does not get “tranche 2” fee. If a full year goes by and the following triggers for “tranche 2”, don’t “activate”, Bustamante & Co. will not assess “tranche 2” or “Tranche 3” fee to the client. Client has the option to “lock in” potential gains that may occur within the “comparative band” and moved into a money market portfolio or other low risk investments such as treasuries, munis, and/or money market investments. If client elects to take this option, “Tranche 3” will not be assessed to the client at any point throughout the year. Bustamante & Co. will still provide financial planning for the client and won’t be assessed a “tranche 3” fee for continued services.

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Tranche 3­ 2% (200 basis points)($5000) which is only paid out to Bustamante & Co if the following “triggers” are “activated” between the client and Bustamante & Co.

Trigger 1: Tranche 2 fee has been paid out from client to Bustamante & Co.

Trigger 2: Client has completed a modular slide set out by Bustamante & Co. for the client's overall financial plan

Trigger 3: Client has had at least 1 comprehensive review with Bustamante & Co and has listened in

on at least 1 end of month conference call since Tranche 2 was paid out to Bustamante & Co.

Trigger 4: Client’s portfolio whether in a conservative allocation, aggressive allocation, or a blend of the 4 “motif portfolios” based on their IPS statement has reached the “optimal band” NET of “tranche 3” 200 basis point wrap fee.

“Tranche 3” only gets paid out to Bustamante & Co if the following four “triggers” above are “activated”. If for example client reaches the anniversary date (date of client signing advisory agreement) and tranche 3 “triggers” are not “activated”, Bustamante & Co. does not get paid out “tranche 3”. If 3 of the 4 triggers are “activated” on behalf of the client before the anniversary date, Bustamante & Co. does not get paid out “tranche 3” wrap fee. If clients portfolio reaches the “optimal band” net of tranche 3 fees, Bustamante & Co. will in conjunction with the client’s written approval allocate the portfolio to a money market and/or tax efficient portfolio until the anniversary date (date client signed advisory agreement). Once the anniversary date arrives, client’s assets will be redeployed into the “motifs” based around their risk tolerance and liquidity needs once more. COMPARATIVE & OPTIMAL BANDS Comparative band and optimal band is a term relating to tracking current returns in a client’s portfolio to that of a comparative index(i.e. SPY or AGG). Optimal band refers to the high end of the comparative band where returns are generally higher than the average for a certain investment allocation. When selecting portfolios based on client’s risk tolerance, comparative indexes will be used to determine proper performance and optimal bands which will adjust accordingly based on the underlying comparative index. TRANCHE “RESET” Bustamante & Co. resets the Wrap fee program every anniversary date (when client signed advisory agreement) back to 60bps, 140bps, 200bps based on the ending balance of the last day of the month of clients anniversary date. As mentioned above Bustamante & Co. incorporates a AUM model where we believe we should only get paid by clients if we perform for them in areas of financial planning and investment management. Bustamante & Co. fee structure is a wrap fee which is broken down into “tranches”, which should not be confused with a “performance fee” where firms charge clients a fixed or variable fee for interest or capital gains generated for beating a certain index which is usually a separate fee from their AUM or management fee.

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FIRM EXPENSES Bustamante & Co. bears the costs directly related to its ongoing existence and investment process. Costs that will be born by Bustamante & Co. and not our clients will be as follows but not limited to: Investment and Trading

trade support services including, but not limited to, pre­ and post­trade support software and related support services

Trading commissions and or other transactional costs between Bustamante & Co and Motif Investing and Interactive Brokers on behalf of the clients accounts

Research (including periodicals, publications, data base services and data processing that are directly related to research activities on behalf of the investment management Bustamante & Co. performs.

Risk analysis and risk reporting by third parties and risk­related and consulting services Other brokerage commissions or services.

Legal and Compliance

Legal fees and related expenses incurred in connection with Bustamante & Co. LLC’s investment supervisory services.

Organizational and Operational

Insurance (other than fire and theft insurance.) Third­party valuation services, accounting, auditing and tax preparation. Interest costs and taxes; and custodian and transfer agency services

The portfolio manager Steven Bustamante is responsible for, and not Bustamante & Co. clients shall not pay, travel expenses. In addition, for the avoidance of doubt, Bustamante & Co. is responsible for its own overhead expenses, including salaries, benefits, rent, information technology (other than described in the previous paragraph), bonuses and other overhead.

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ITEM 6 PERFORMANCE­BASED FEES AND SIDE­BY­SIDE MANAGEMENT Bustamante & Co. advisory fees will not be based on a share of capital gains or capital appreciation (growth) of any portion of managed funds, also known as performance‐based fees. Performance‐based compensation creates an incentive for a firm or their representatives to recommend an investment that may carry a higher degree of risk to a client. Our fees will not be based on side‐by‐side management, which refers to a firm simultaneously managing accounts that do pay performance‐based fees (such as a hedge fund) and those that do not; this type of arrangement, and the conflict of interest it may pose, does not conform to our firm’s practices

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ITEM 7 TYPES OF CLIENTS We provide investment management and financial planning to high net worth individuals. For our investment supervisory services, a minimum investment of $250,000 is generally required. Details can be found in our wrap free supplementary brochure.

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ITEM 8 METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS We identify opportunities using a combination of top­down asset allocation decisions and a bottom­up, value­oriented approach to single security analysis. We seek dislocations in certain areas of the capital markets or in the pricing of a particular security. We supplement single security analysis with an approach to portfolio construction that includes sizing each investment based on upside/downside calculations, all with a view towards appropriately positioning and managing overall exposures across specific asset classes, sectors and geographies. The resulting portfolios from conservative to aggressive expresses our client’s overall tolerance for risks given macroeconomic and market conditions, and reflects considerations of overall portfolio hedging. We make investments globally – in both developed and emerging markets – in all sectors, and in equity, credit, commodity, currency, option and other instruments utilizing etfs, equities, options, and bonds. Bustamante & Co. does not affect transactions in futures, forex, private equity, private placements, and or other investments that may cause high risk for clients overall financial goals. Bustamante & Co only affects transactions on behalf of clients portfolios in publicly traded equities, exchange traded funds, money market securities, bonds, and options. We also as a firm don’t perform indexing. Our strategies are built around alpha dominant driven models to potentially outperform underlying indexes from conservative to aggressive allocations on behalf of clients portfolios. For the more aggressive portfolios we favor “event­driven” situations, in which we believe that a catalyst, either intrinsic or extrinsic, will unlock value or alter the lens through which the greater market values a particular investment. We attempt to apply this “event” framework to each of our single security investments with some flexibility, and this approach informs the timing and risk of each investments Bustamante & Co. LLC makes asset allocation decisions based on these and other factors. We will discuss with clients how, in our best judgment, to meet clients objectives while at the same time seeking a prudent level of risk exposure. Business Risks Overall Investment Risk. All securities investments risk the loss of capital. The securities to be purchased and traded could be speculative in nature, and the markets in which we transact will be highly competitive. Changes in general domestic and international economic and political conditions, including fluctuations in interest rates, the availability of credit, recession and other factors may adversely affect the investments. The investment techniques and strategies we employ in an effort to meet our investment objectives on behalf of our clients will stay within the proper allocation based on their IPS statements. There can be no assurance our techniques and strategies will be successful, or that they will not incur losses, which could be meaningful. Accordingly, any investment or portfolio will be executed on the client's behalf only after Bustamante & Co. has performed proper due diligence in relation to the client's liquidity situation, tolerance for risks, and investment goals.

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Fixed Income Securities Generally. We may invest in fixed income securities. Investment in these securities may offer opportunities for income and capital appreciation, and may also be used for temporary defensive purposes and to maintain liquidity. Fixed income securities are obligations of the issuer to make payments of principal and/or interest on future dates, and include, among other securities: bank debt, bonds, notes, and debentures issued by corporations; debt securities issued or guaranteed by the U.S. government or one of its agencies or instrumentalities or by a non­U.S. government or one of its agencies or instrumentalities; municipal securities; and mortgage­backed and other asset­backed securities. These securities may pay fixed, variable, or floating rates of interest, and may include zero coupon obligations. Fixed income securities are subject to the risk of the issuer’s or a guarantor’s inability to meet principal and interest payments on its obligations (i.e., credit risk) and are subject to price volatility due to factors such as interest rate sensitivity, market perception of the creditworthiness of the issuer, general market liquidity (i.e., market risk), government interference, economic news, and investor sentiment. Our fixed income investments may be subject to early redemption features, refinancing options, pre­payment options or similar provisions which, in each case, could result in the issuer repaying the principal on an obligation earlier than expected. This may happen when there is a decline in interest rates, or when a borrower’s performance allows the refinancing of certain classes of debt with lower cost debt. To the extent such early prepayments increase, they may have a material adverse effect on our investment objectives and the profits on capital invested in fixed income investments. As with other investments we make, there may not be a liquid market for any of the debt instruments in which we invest, which may limit our ability to sell these debt instruments or to obtain the desired price. We may attempt to take advantage of undervalued fixed income securities or relative mispricings in disrupted credit markets. The identification of attractive investment opportunities in disrupted credit markets is difficult and involves a significant degree of uncertainty. During periods of “credit squeezes” or “flights to quality,” the market for fixed income investments can become substantially reduced.. High Yield Securities. We may invest in “high yield” debt and preferred securities which are rated in the lower rating categories by the various credit rating agencies (or in comparable nonrated securities). Securities in the lower rating categories are subject to greater risk of loss of principal and interest than higher­rated securities and are generally considered to be predominantly speculative with respect to the issuer’s capacity to pay interest and repay principal. They are also generally considered to be subject to greater risk than securities with higher ratings in the case of deterioration of general economic conditions. Because investors generally perceive that there are greater risks associated with lower­rated securities, the yields and prices of such securities may tend to fluctuate more than those of higher­rated securities. The market for lower rated securities is thinner and less active than that for higher­rated securities, which can adversely affect the prices at which these securities can be sold. In addition, adverse publicity and investor perceptions about lower rated securities, whether or not based on fundamental analysis, may be a contributing factor in a decrease in the value and liquidity of such lower­rated securities. Corporate Bonds. We may invest in corporate bonds. Corporate bonds are subject to the risk of the issuer’s inability to meet principal and interest payments on the obligation and may also be subject to price volatility due to such factors as interest rate sensitivity, market perception of the creditworthiness of the issuer and general market liquidity. When interest rates decline, the value of the corporate bonds can be expected to rise, and when interest rates rise, the value of those securities can be expected to decline. Bonds with longer maturities tend to be more sensitive to interest rate movements than those with shorter maturities. Many such bonds are unsecured, which makes them less likely to be fully repaid in the event of a bankruptcy.

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Investing in Emerging Markets and Foreign Securities. Our investing in foreign securities may involve heightened risks in comparison to the risks of investing in domestic securities, including unfavorable changes in currency rates and exchange control regulations, reduced and less reliable information about issuers and markets, less stringent accounting standards, illiquidity of securities and markets, higher brokerage commissions, transfer taxes and custody fees, local economic or political instability and greater market risk in general. In particular, investing in securities of issuers located in emerging market countries involves additional risks, such as exposure to economic structures that are generally less diverse and mature than, and to political systems that can be expected to have less stability than, those of developed countries. Other characteristics of emerging market countries that may affect investment in their markets include certain national policies that may restrict investment by foreigners in issuers or industries deemed sensitive to relevant national interests and the absence of developed legal structures governing private and foreign investments and private property. The typically small size of the markets for securities of issuers located in emerging markets and the possibility of a low or nonexistent volume of trading in those securities may also result in a lack of liquidity and in price volatility of those securities. In addition, dividend and interest payments from and capital gains in respect of certain foreign securities may be subject to foreign taxes that may or may not be reclaimable. QDI Ratios. While many ETFs and index mutual funds are known for their potential tax‐efficiency and higher “qualified dividend income” (QDI) percentages, there are asset classes within these investment vehicles or holding periods within that may not benefit. Shorter holding periods, as well as commodities and currencies (that may be part of an ETF portfolio), may be considered “non‐qualified” under certain tax code provisions. We consider a holding’s QDI when tax‐efficiency is an important aspect of the client’s portfolio. Risks Of Special Techniques Derivative Instruments in General. We may use various derivative instruments, including options which may be volatile and speculative. Certain positions may be subject to wide and sudden fluctuations in market value. Derivatives used for hedging purposes may not correlate perfectly with the underlying investment sought to be hedged. Derivative instruments may not be liquid in all circumstances, so that in volatile markets we may not be able to close out a position without incurring a loss. Trading in derivative instruments may permit us to incur additional leverage, which may magnify our gains and losses and could cause our clients net asset value to be subject to wider fluctuations than would otherwise be the case. While derivatives used for hedging purposes can reduce or eliminate losses, such use can also reduce or eliminate gains. When we use derivatives as an investment vehicle to gain market exposure, rather than for hedging purposes, any loss on the derivative investment will not be offset by gains on another hedged investment. We are therefore directly exposed to the risks of that derivative. Derivatives may not be available upon acceptable terms. As a result, we may be unable to use derivatives for hedging or other purposes. Short Sales. We may engage in short selling of any of the instruments we trade. In selling short, we bear the risk of an increase in the value of the instrument sold short above the price at which it was sold. Such an increase could lead to a substantial (theoretically unlimited) loss, as the market price of instruments sold short may increase indefinitely. Under certain market conditions, we might have difficulty purchasing instruments to meet our short sale delivery obligations (such as to complete a dealer buy­in of the underlying instrument). We might also have to sell instruments to raise the capital necessary to meet our short sale margin call obligations at a time when fundamental investment considerations would not favor closing out such short position. Use of short­selling in our role as an engaged investor may also give rise to litigation

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and other expenses. Short­selling activities are subject to restrictions imposed by U.S. and non­U.S. securities laws and the various securities exchanges. Limitations on short selling have been imposed on an emergency basis in the past during market disruptions. Short Selling may be subject to further regulatory restrictions in the future, including reporting requirements on short­selling, which may prevent us from successfully implementing our investment strategies involving short­selling. Options. Both the purchasing and selling of call and put options entail risks. Although an option buyer’s risk is limited to the amount of the original investment for the purchase of the option, an investment in an option may be subject to greater fluctuation than an investment in the underlying securities. In theory, an uncovered call writer’s loss is potentially unlimited, but in practice the loss is limited by the term of existence of the call. The risk for a writer of a put option is that the price of the underlying security may fall below the exercise price. Options also involve counterparty risk. However, we generally intend to limit our trading in option contracts to standardized options which trade on recognized exchanges. We believe that these options provide greater liquidity and involve less counterparty risk than customized options for which a clearinghouse does not exist. Exchange Traded Funds (ETFs). We may invest in shares of ETFs, including for hedging purposes. As an investor in ETFs, we will bear its ratable share of various fees, allocations and expenses of the ETF, all of which are embedded in the net asset value of the ETF. ETFs represent shares of ownership in either funds or unit investment trusts that hold portfolios of common stocks, bonds or other instruments, which are designed to generally correspond to the price and yield performance of an underlying index. A primary risk factor relating to ETFs is that the general level of stock or bond prices may decline, thus affecting the value of an equity or fixed income ETF, respectively. An ETF may also be adversely affected by the performance of the specific sector or group of industries on which it is based. Moreover, although ETFs are designed to provide investment results that generally correspond to the price and yield performance of their underlying indices, ETFs may not be able to exactly replicate the performance of the indices because of their expenses and other factors Interest Rates. We may be adversely affected by changes in interest rates. Interest rates are determined by factors of supply and demand in the international money markets and can be influenced by macroeconomic factors, speculation and other forms of government intervention. Turnover. A substantial portion clients capital may be invested on the basis of short­term market considerations. The portfolio turnover rate of those investments may be significant, potentially involving substantial brokerage commissions and fees which Bustamante & Co. pays for on our wrap program. Client’s don’t bear any costs related to brokerage or other transactions related to investing and/or trading. Market Risks and Lack of Liquidity. The success of our investment program depends to a great extent upon our ability to assess correctly the future course of price movements of stocks and bonds. There can be no assurance that we will accurately predict such movements. In addition, certain of the securities in which we invest, from time to time, may have limited liquidity. During periods of stress in the markets, prices for securities with less liquidity typically suffer significantly more than more liquid, exchange­traded equities. This lack of liquidity, together with a failure to accurately predict market movements, may adversely affect the market value of our investments from time to time.

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Operational Risks Dependence on Steven D. Bustamante and Adviser. All investment decisions are made under the general supervision of Steven D. Bustamante; Accounts’ investors have no right or power to take part in the management of the accounts. As a result, the success of the Accounts depends largely upon the abilities of Mr. Bustamante, and no assurance can be given that a suitable replacement could be found for him in the event of his death, disability or withdrawal from Bustamante & Co. In the event Mr. Bustamante is no longer actively engaged in formulating the investment philosophy of Bustamante & Co., whether by death, disability, withdrawal as managing member of the firm or otherwise, the Accounts’ investors will be entitled to special notice where they have the option to move to another investment advisory firm. Execution Risks and Adviser Error. The execution of the trading and investment strategies we employ can often require rapid execution of trades, high volume of trades, complex trades, difficult to execute trades, use of negotiated terms with counterparties such as in the use of derivatives and the execution of trades involving less common or novel instruments. In each case, we seek best execution in settling and clearing such trades. However, in light of the high volumes and complexity involved, some slippage, errors and miscommunications with brokers and counterparties are inevitable and may result in losses. Such losses may be caused by the brokers and counterparties or by us or by a combination of the broker or counterparty and us. We may, but are not required to, attempt to recover losses from brokers or counterparties. We are not liable for losses caused by brokers or counterparties, other than in the case of fraud, bad faith, willful misconduct or gross negligence on our part. To the fullest extent permitted by law (including the U.S. Federal securities laws), we will not be liable for trade errors except for acts that constitute bad faith or fraud, willful misconduct or gross negligence. Location and Infrastructure. Most of the key operations of our firm are located in one building in Phoenix AZ. Loss of the building and/or key personnel, whether through fire, terrorist action, earthquake or some other catastrophic event, could adversely affect our operations and the investment returns of the Accounts. A serious impairment to the infrastructure of the building such as extended loss of power or a prolonged restriction of physical access to the building by governmental authorities also could adversely affect our operations and investment returns of the accounts. We have contracted for offsite data back­up and recovery and have a disaster recovery plan for offsite operation, but the risk of disruption of operations remains. Similar risks may apply to the brokers, and dealers and other custodians of the Accounts’ assets.

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ITEM 9 DISCIPLINARY INFORMATION Neither the firm nor its management has been involved in a material criminal or civil action in a domestic, foreign or military jurisdiction, an administrative enforcement action, or self‐regulatory organization proceeding that would reflect poorly upon our offering advisory business or its integrity.

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ITEM 10 OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Firm policies require associated persons to conduct business activities in a manner that avoids conflicts of interest between the firm and its clients, or that may be contrary to law. Bustamante & Co. will provide disclosure to each client prior to and throughout the term of an engagement regarding any conflicts of interest which might reasonably compromise its impartiality or independence. Neither the firm, management, nor its associates, are registered or have an application pending to register as a Financial Industry Regulatory Authority (FINRA) or National Futures Association (NFA) introducing broker/dealer, or as a futures commission merchant, commodity pool operator, commodity trading advisor, or an associated person of the foregoing entities. Material Relationships Maintained by this Advisory Business and Conflicts of Interest Neither the firm nor its management is or has a material relationship with any of the following types of entities:

Municipal securities dealer, or government securities dealer or broker banking or thrift institution lawyer or law firm accountant or accounting firm real estate broker or dealer insurance company or agency pension consultant issuer of a security sponsor or syndicator of limited partnerships investment company or other pooled investment vehicle (including a mutual fund, closed­end

investment company, UIT, private investment company or “hedge fund”, and offshore fund). Upon clients request, clients may be provided a referral to various professionals, such as an accountant, attorney or insurance representative. While these referrals are based on our best information, we do not guarantee the quality or adequacy of the work provided by these referred professionals. We do not have an agreement with or receive fees from these professionals for these informal referrals. Any fees charged by these other entities for their services are completely separate from fees charged by our firm.

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ITEM 11 CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING We have adopted a code of ethics (“Code of Ethics”) which is designed to foster compliance with the applicable federal statutes and regulatory requirements, prevent circumstances that may lead to or give the appearance of conflicts of interest with clients, insider trading or unethical business conduct as well as promote a culture of high ethical standards. Among other things, the Code of Ethics governs personal securities trading by Bustamante & Co. Generally, no employee of Bustamante & Co. may personally trade or own any security (with the exception of certain securities such as U.S. government obligations, cash equivalents, money market funds, open­end mutual funds, unit investment trust, investment grade corporate bonds, investment grade preferred securities, limited mortgage bonds, master limited partnerships, private investments, etc. (“Exempt Security” or “Exempt Transaction”)) if the transaction is the opposite of what we recommend for clients.. For some of the Exempt Securities or Exempt Transactions, Employees must pre­clear any trades. In limited exception situations (primarily due to economic hardship), employees may trade in other securities but only subject to compliance pre­approval. The Code of Ethics also requires employees to do the following: 1) to report personal transactions on a quarterly basis,to clients and/or regulators upon request. 2) to file annual personal account disclosures and report securities holdings; and 3) to certify their compliance with the Code of Ethics on an annual basis. Code of Ethics Description The firm holds itself to a fiduciary standard, which means we will act in the utmost good faith, performing in a manner believed to be in the best interest of our clients. Bustamante & Co.periodically reviews and amends its Code of Ethics to ensure that it remains current, and requires firm personnel to annual attest to their understanding of and adherence to the firm’s Code of Ethics. A copy of the firm’s Code of Ethics is made available to any client or prospective client upon request. The firm does not disclose non‐public personal information about our customers to anyone, except in the following circumstances:

When required to provide services our clients have requested When our customers have specifically authorized us to do so; When required during the course of a firm assessment (i.e., independent audit); or When permitted or required by law (i.e., periodic regulatory examination).

Within the firm, access to customer information is restricted to personnel that need to know that information. All access persons and service providers understand that everything handled in firm offices are confidential and they are instructed to not discuss customer information with someone else that may request information about an account unless they are specifically authorized in writing by the customer to do so. This includes, for example, providing information about a spouse’s IRA account or to adult children about parents’ accounts, etc. To ensure security and confidentiality, the firm maintains physical, electronic, and procedural safeguards to protect the privacy of customer information. The firm will provide you with its privacy policy on an annual basis per federal law and at any time, in advance, if firm privacy policies are expected to change.

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Investment Recommendations Involving a Material Financial Interest and Conflicts of Interest Neither the firm nor an associate is authorized to recommend to a client, or effect a transaction for a client, involving any security in which the firm or a “related person” (e.g., associate, an immediate family member, etc.) has a material financial interest, such as in the capacity as a board member, underwriter or advisor to an issuer of securities, etc. An associate is prohibited from borrowing from or lending to a client unless the client is an approved financial institution. We want to note that you are under no obligation to act on a recommendation from our firm and, if you elect to do so, you are under no obligation to complete them through our firm or a service provider whom we may recommend.

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ITEM 12 BROKERAGE PRACTICES Bustamante & Co. does not maintain physical custody of client’s assets (see Item 15). Client’s accounts must be maintained by a qualified custodian, such as a broker/dealer, bank or trust company. Bustamante & Co. is not a custodian nor is there an affiliate that is a custodian. When we are engaged to provide investment consultation services, we may recommend the service provider with whom clients assets are currently maintained.When clients engage our firm to provide its investment supervisory services, we request clients use the institutional services division of Interactive Brokers. (“IB”), and, Motif Investing FINRA and SIPC members,and an SEC‐ registered broker/dealers. Our firm is independently owned and operated; it is not legally affiliated with either Interactive Brokers or Motif Investing.While we recommend that clients work with Interactive Brokers and Motif Investing as their custodian, client’s will decide whether to do so and will open an account with them by entering into an account agreement directly with them. We do not technically open the account for client’s, although we assist client’s in doing so. If clients do not wish to place assets with Interactive Brokers and Motif Investing as the custodian of record, we are unable to manage client accounts under our investment supervisory services engagement and another service (e.g., our investment consultation engagement) would be necessary. Interactive Brokers and Motif Investing offers independent investment advisors various services which include custody of client assets, trade execution, clearance and settlement, etc. Our firm may receive certain benefits from Interactive Brokers and Motif Investing through participation in its independent advisor support program (please refer to Item 14 for further details). We periodically conduct an assessment of any service provider we recommend which generally involves a review of their range and quality of services, reasonableness of fees, among other items, and in comparison to their industry peers. Best Execution “Best execution” means the most favorable terms for a transaction based on all relevant factors, including those listed in the paragraph titled Factors Used to Select Broker‐Dealers for Client Transactions and within Item 14. The firm receives a benefit because it does not have to produce or pay for certain types of research, products or services, and the firm may have an incentive to select or recommend a broker/dealer based on its own interests in receiving the research or other products or services, rather than its client's’ interest in receiving most favorable execution. Trade Error Policy Client account transactions may be effected on occasion in a manner that differs from what was intended for the account. We review any trade errors that we discover, on a case­by­case basis, and decide what corrective steps to take, if any, after reviewing the error. Trade errors are often borne by the Accounts. Directed Brokerage A managed account client may direct us to utilize a particular broker­dealer to execute some or all transactions for the client’s account. In such circumstances, the managed account client is responsible for negotiating the terms and arrangements for the account with that broker­dealer. We will not seek better execution services or prices from other broker­dealers or be able to aggregate the managed account client's transactions, for execution through other brokers­dealers, with orders for the”MOTIFS” or the other managed account we manage. As a result, we may not obtain best execution on behalf of such

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directing managed account client, who may pay materially disparate commissions, greater spreads or other transaction costs, or receive less favorable net prices on transactions for the account than would otherwise be the case. We seek to allocate investment opportunities among Clients in the fairest possible way taking into account Clients’ best interests and investment objectives/restrictions. We will follow procedures to help ensure that allocations do not reflect a practice of favoring or discriminating against any Client or group of Clients. Account performance is never a factor in trade allocations.

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ITEM 13 REVIEW OF ACCOUNTS Position Reviews: We perform various daily, weekly, monthly and quarterly reviews of all Accounts. Our portfolio manager conducts reviews on a regular basis for, among others things, exposures, trade allocations, execution and commissions paid on security transactions, performance comparisons, investment objectives, guidelines and restrictions. Financial Planning Reviews: For those clients who have engaged our firm for ongoing planning services, we will schedule reviews with clients in advance. It will be client's responsibility to initiate a review if client’s agreement does not involve continuous financial planning support, and these reviews are recommended on at least on a quarterly basis whenever practical. Reviews will be conducted by Mr. Bustamante and normally involve analysis and possible revision of client’s previous financial plan or investment allocation. A copy of revised plans or asset allocation reports will be provided to the client upon request. Unless provided for in client engagement agreement (e.g., ongoing support), financial planning and investment consultation services reviews are conducted under a new or amended agreement and will be assessed at our current wrap fee.

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ITEM 14 CLIENT REFERRALS AND OTHER COMPENSATION We may receive certain economic benefits from broker­dealers and prime brokers which we conduct business with that might not be received otherwise. These benefits may include: access to an electronic communication network for order entry and account information; proprietary research; and participation in sponsored research and capital introduction conferences. While these services are generally provided at no additional cost, we may select certain broker­dealers due to receipt of such services. We understand that the benefits received through these relationships generally do not depend upon the amount of transactions directed to or the amount of assets custodied. We compensate certain third parties that refer certain clients to us. Compensation is based upon assets brought to the firm and paid a fixed one time fee. We do not charge any portion of the compensation paid to the third parties to clients.

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ITEM 15 CUSTODY Client assets will be maintained by an unaffiliated, qualified custodian, such as a bank, broker/dealer (e.g., Interactive Brokers, Motif Investing),or transfer agent. Client assets are not held by our firm or any associate or our firm. In keeping with this policy involving our client funds or securities, Bustamante & Co.

We prohibit any associate from having authority to directly withdraw securities or cash assets from a client account. Although we may be deemed to have “constructive custody” of client’s assets since we may request the withdrawal of advisory fees from an account, we will only do so through the engagement of a qualified custodian maintaining client’s account assets, via client’s prior written approval, and following our written invoice;

Does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our firm;

Will not authorize an associate to have knowledge of a client’s account access information (i.e.,

online 401(k), brokerage or bank accounts) if such access would allow physical control over account assets.

Clients will be provided with transaction confirmations and summary account statements sent directly to them by their custodian of record.Typically statements are provided on at least a quarterly basis or as transactions occur within their account. Bustamante & Co. will not create an account statement for a client or serve as the sole recipient of an account statement. Should clients receive periodic reports from our firm that includes investment performance information, clients are urged to carefully review and compare their account statements that they have received directly from your custodian of record with any report from our firm.

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ITEM 16 INVESTMENT DISCRETION Consistent with our clients tolerance for risk, liquidity need, and investment goals, Bustamante & Co. provides investment advisory services to our clients on a discretionary basis in a manner consistent with each account’s investment objectives and restrictions, as set forth in the governing agreements and documents. In providing discretionary investment advisory services, we generally supervise and manage the account’s portfolio and make investment decisions, without consulting clients. Client’s however are able to view their portfolio holdings through motif investing and Interactive Brokers client “login portal”. If clients require their accounts be managed in a non‐discretionary manner, client’s prior approval must be made for each transaction with regard to the investment and reinvestment of account assets, or for our firm to give instructions to the custodian maintaining client’s account (i.e., wire instructions, etc.). Please note that in light of the requirement for client’s pre‐approval client’s must make yourself available and keep us updated on your contact information so that instructions can be efficiently effected on client’s behalf. Also note that in certain situations it may be difficult to manage clients accounts under a non‐discretionary agreement (i.e., you are a frequent traveler, have unique portfolio management requirements, etc.). Therefore, we retain the right to either refuse or terminate a non‐discretionary account. ITEM 17

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VOTING CLIENT SECURITIES We do not vote proxies on client’s behalf nor do we offer guidance on how to vote proxies. Clients will maintain exclusive responsibility for directing the manner in which proxies solicited by issuers of securities that are beneficially owned by client’s shall be voted, as well as making all other elections relative to mergers, acquisitions, tender offers or other events pertaining to client’s holdings. We will have no power, authority, responsibility, or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. Client’s may receive proxies or other similar solicitations sent directly from client’s selected custodian or transfer agent. Should our firm receive a duplicate copy, it will generally not be forwarded, nor any other correspondence relating to the voting of your securities, class action litigation, or other corporate actions. ITEM 18

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FINANCIAL INFORMATION Balance Sheet Advisory fee withdrawals must be done through a qualified intermediary (e.g., custodian of record), per your prior written agreement, and following client’s receipt of our written notice ‐‐ termed “constructive custody.” Our engagements require that we collect advance fees from clients of $1500 or more for our advisory services that we will perform six months or more into the future. Neither Bustamante & Co. Nor, Mr. Bustamantes serves as general partner for a partnership or trustee for a trust in which the firm’s advisory clients are either partners of the partnership or beneficiaries of the trust. Due to the nature of our firm’s services and operational practices, an audited balance sheet is not required nor included in this brochure. Financial Conditions Reasonably Likely to Impair Advisory Firm's Ability to Meet Commitments to Clients The firm and its management do not have a financial condition likely to impair our ability to meet commitments to our clients. Bankruptcy Petitions during the Past 10 Years The firm and its management have never been the subject of a bankruptcy petition. ITEM 19

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REQUIREMENTS FOR STATE REGISTERED ADVISERS Please refer to the accompanying Form ADV Part 2B for further information involving firm principal executive and management personnel. Form ADV Part 2B­ Brochure Supplement (Advisory Personnel)

This brochure provides information about Mr. Steven Bustamante, the firm's principal executive, and supplements the Bustamante & Co. LLC advisory brochure referenced in the preceding pages. If you have any questions about the contents of this supplement, please contact Mr. Bustamante by telephone at (480) 320­3478. Additional information about Mr. Bustamante and Bustamante & Co. LLC is available on the SEC's website at www.advisersinfo.sec.gov.

Item 1­ Firm Information Bustamante & Co. LLC 11225 N. 28th Dr. Phoenix, AZ 85029 #B­216 www.bustamanteco.com Item 2­ Educational Background and Business Experience Regulatory guidance requires the firm to disclose relevant post­secondary education and professional training for each principal executive and associate of the firm, as well as their business experience for at least the most recent five years. Principal Executive Officers and Management Persons Managing Member/Founder/Chief Compliance Officer (Supervisor)/Investment Advisor Representative Steven Bustamante Year of Birth: 1988 CRD Number: 5554271

Educational Background and Business Experience Educational Background

General Securities Representative Examination/FINRA Series 7 Uniform Combined State Law Examination/NASAA Series 66 AZ Dept of Insurance Life & Health Examination #1042850

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Business Experience Bustamante & Co. LLC (11/2015­present) Scottsdale, AZ Managing Member/Founder/Chief Compliance Officer/Investment Advisor Representative Steven Bustamante­Self Employed (11/2014­11/2015) Trading, Financial Markets Phoenix, AZ Robotic Trading Advisors LLC (06/2014­11/2014) Scottsdale, AZ Financial Advisor Merrill Lynch (06/2013­05/2014) Chandler, AZ Financial Advisor

MB Trading Futures (05/2011­11/2012) Scottsdale, AZ Foreign Exchange Trading Desk CurrencyARC (12/2008­03/2013) Phoenix, AZ Founder, Managing Member Foreign Exchange Investment Research to Private Investors and Mid­Sized Hedge Funds Item 3­ Disciplinary Information Registered investment advisors are required to disclose certain material facts regarding any criminal, civil, legal or industry/professional association disciplinary event that would be material to client's evaluation of each officer or supervised person providing investment advice. No reportable information is applicable to this section for Mr. Bustamante or his firm. Item 4­ Other Business Activities Mr. Bustamante is not registered, nor has an application pending to register, as a registered representative of a broker/dealer or associated person of a futures commission merchant, commodity pool operator, or commodity trading advisor. Therefore, he does not receive commissions, bonuses or other compensation based on the sale of securities, including that as a registered representative of a broker/dealer or the distribution or service (“trail”) fees from the sale of mutual funds and exchange traded funds. Mr. Bustamante also serves as a freelance writer and editor involving financial articles. These activities represent five percent or less of his time and are not conducted during traditional market hours, nor are they believed to present a conflict of interest between his role with the firm and its clients.

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Item 5­ Additional Compensation Mr. Bustamante is not compensated for advisory services involving performance­based fees. In addition, firm policy does not allow associated persons to accept or receive additional economic benefit, such as sales awards or other prizes, for providing advisory services to firm clients. Item 6­ Supervision Mr. Bustamante serves in multiple capacities for Bustamante & Co. LLC; Managing Member, Founder, Chief Compliance Officer, and investment advisor representative. It is recognized there is an inability to segregate certain firm duties which may potentially create conflicts of interest; however, policies and procedures are employed to ensure appropriate recordkeeping and oversight. Questions relative to the firm, its services or this Form ADV Part 2 may be made to the attention of Mr. Bustamante at (480) 648­5773. Additional information about the firm, other advisory firms, or an associated investment advisor representative, including Mr. Bustamante, is available on the internet at www.adviserinfo.sec.gov. A search of this site for firms may be accomplished by firm name or a unique firm identifier, known as an IARD number. The IARD number for Bustamante & Co. LLC is 282054. You may search for Mr. Bustamante by name or his industry reference number (“CRD #”), which is 5554271 The business and disciplinary history, if any, of an investment advisory firm and its representatives may also be obtained by calling the Arizona Corporate Commission Securities Division (602) 542­4242.

Item 7­ Requirements for State­Registered Advisers There have been neither awards nor sanctions or other matters where Mr. Bustamante has been found liable in a self­regulatory or administrative proceeding. Mr. Bustamante and his firm has not been the subject of a bankruptcy petition.

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