Form ADV Part II Vision Investment Advisors, LLC March 9, …

1 1 Vision Investment Advisors, LLC 120 Long Ridge Road 3 North Stamford, CT 06902 203-388-2700 March 25, 2020 This Brochure provides information about the qualifications and business practices of Vision Investment Advisors, LLC. If you have any questions about the contents of this Brochure, please contact us at 203-388-2700. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Vision Investment Advisors, LLC also is available on the SEC s website at References herein to Vision Investment Advisors, LLC as a registered Investment adviser or any reference to being registered does not imply a certain level of skill or training.

2 2 Item 2 Material Changes This Item 2 only discusses specific material changes that are made to the Brochure and provides clients with a summary of such changes since the last brochure on August 27, 2019. Mr. John Karafa, the Anti-Money Laundering Compliance Officer was appointed to be the Chief Compliance Officer on July 18, 2019 and listed on the ADV part 1A Schedule A.. 3 Item 3 - Table of Contents Item 1 Cover Page 1 Item 2. Material Changes 2 Item 3. Table of Contents 3 Item 4.

3 Advisory Business 4 Item 5. Fees and Compensation 13 Item 6. Performance-Based Fees and Side-by-Side Management 16 Item 7. Types of Clients 17 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss 17 Item 9. Disciplinary Information 21 Item 10. Other Financial Industry Activities and Affiliations 21 Item 11. Code of Ethics 23 Item 12. Brokerage Practices 24 Item 13. Review of Accounts 25 Item 14. Client Referrals and Other Compensation 25 Item 15.

4 Custody 25 Item 16. Investment Discretion 25 Item 17. Voting Client Securities 26 Item 18. Financial Information 26 Appendix 1 27 4 Item 4 Advisory Business A. VIA ( VIA ) is an SEC-registered Investment advisor under the Multi-State registration category as stated in the ADV part 1A Item 2A(10). VIA has been in the Investment advisory business since September 2000. Mr. Howard Rothman and Boshnack Family LLC are principal owners controlling 25% or more of the entity and are listed in the ADV part 1A Schedule A.

5 The principal owners are not a publicly held companies and their ownership is not through subsidiaries. B. VIA provides general Investment advisory services for clients on a discretionary and non-discretionary basis. VIA may recommend a third-party Investment advisor to manage all or a portion of a client's account or an independent Commodity Trading advisor ("CTA") to manage all or a portion of a client's account in managed futures. Individual accounts are managed directly by a specifically named VIA Investment advisor .

6 Investment advice is not limited and includes many different types of investments. C. Accounts managed by a VIA Investment advisor Representative ( IAR ) are tailored to meet the needs of the client by determining those needs through ongoing discussions regarding risk tolerance, Investment goals, personal economic facts, personal demographic facts, and other personal preferences of the client. The accounts are managed based on the following clients stated Investment objectives: (1) preservation of capital, (2) income, (3) capital appreciation, and (4) speculation.

7 Client accounts may be managed independently by an IAR, invested on one of VIA proprietary portfolios as described below or invested in a combination of disciplines. IARs may recommend another Investment advisor or a commodity trading advisor to manage all or a portion of the assets in the accounts. Clients are also free to impose reasonable restrictions upon investing in certain securities or types of securities. D. VIA no longer offers wrap fee programs but the program is maintained for existing accounts. Information regarding the wrap fee program is described in a separate ADV part 2A Wrap Fee Program document.

8 As of December 31, 2019, there are 44 legacy wrap fee accounts with $46, 919,965 in assets under management. VIA receives a portion of the wrap fee for its services. E. As of December 31, 2019, VIA has total assets of $84,489,073 in total assets under management. Discretionary assets total $80,907,337 and non-discretionary assets total $3,581,736. Investment Portfolios - Non-Wrap Fee Programs VIA provides discretionary advisory services on a non-wrap fee basis in the Equity, Balanced, Dividend, Fixed Income and Total Portfolios as well as the Stock Put Writing Program and the Stock Put Credit- Spread Option Program to individuals and institutional investors.

9 These Investment methodologies have been developed by Mr. Howard Rothman, VIA s Chief Executive 5 Officer. Mr. Rothman makes the ultimate Investment selections and recommendations and monitors each client account that receives discretionary Investment advice. A VIA client may establish an account in one or more of VIA s Investment portfolios, each of which consists of accounts with similar Investment objectives, portfolio construction, market exposure and risk tolerance. Each client's portfolio is managed specifically for that client based upon the client's individual goals, objectives, restrictions and current market conditions.

10 A client may request, subject to VIA s approval, to place limited and reasonable restrictions on the specific securities or types of securities that are purchased for their account. VIA may also provide discretionary advisory services not based on any of the portfolios described below. For trade implementation, each VIA client opens a brokerage account with either Vision Financial Markets, LLC ( VFM ), Vision Brokerage Services LLC ( VBS ) or a third-party brokerage firm. All trades are executed in that brokerage account and client assets are held in custody with that brokerage firm s custodian.