APPROACH CAPITAL LLC

Approach Capital LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Approach Capital LLC. If you have any questions about the contents of this brochure, please contact us at (480) 993-9733 or by email at: greg@approachcp.com. 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 Approach Capital LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Approach Capital LLC’s CRD number is: 291807. 2975 East Robin Lane Gilbert, AZ 85296 (480) 993-9733 greg@approachcp.com Registration does not imply a certain level of skill or training. Version Date: 04/28/2026 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Approach Capital LLC on 01/21/2026, are described below. Material changes relate to Approach Capital LLC’s policies, practices or conflicts of interest. • • Approach Capital LLC is transitioning to registration with the United States Securities and Exchange Commission from its prior registration at the state level. • Approach Capital, LLC updated its Brokerage Practices to include Vantage Self Directed Retirement Plans (Item 12) • Approach Capital, LLC has updated its Portfolio Management Fees (Item 5 ii  Item 3: Table of Contents Item 1: Cover Page……………………………………………………………………………………………………………………………………..i Item 2: Material Changes .......................................................................................................................... ii Item 3: Table of Contents .......................................................................................................................... 3 Item 4: Advisory Business ........................................................................................................................ 4 A. Description of the Advisory Firm ................................................................................................... 4 B. Types of Advisory Services .............................................................................................................. 4 C. Client Tailored Services and Client Imposed Restrictions .......................................................... 5 D. Wrap Fee Programs .......................................................................................................................... 5 E. Assets Under Management .............................................................................................................. 5 Item 5: Fees and Compensation ............................................................................................................... 5 A. Fee Schedule ...................................................................................................................................... 5 B. Payment of Fees ................................................................................................................................. 6 C. Client Responsibility For Third Party Fees .................................................................................... 6 D. Prepayment of Fees ........................................................................................................................... 6 E. Outside Compensation For the Sale of Securities to Clients ....................................................... 7 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................... 7 Item 7: Types of Clients ............................................................................................................................. 7 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .................................................. 7 A. Methods of Analysis and Investment Strategies ..................................................................... 7 B. Material Risks Involved .............................................................................................................. 8 C. Risks of Specific Securities Utilized .......................................................................................... 8 Item 9: Disciplinary Information ........................................................................................................... 10 A. Criminal or Civil Actions ......................................................................................................... 10 B. Administrative Proceedings..................................................................................................... 10 C. Self-regulatory Organization (SRO) Proceedings ................................................................. 10 Item 10: Other Financial Industry Activities and Affiliations ........................................................... 10 A. Registration as a Broker/Dealer or Broker/Dealer Representative ................................... 10 iii  B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor ............................................................................................................. 10 Registration Relationships Material to this Advisory Business and Possible Conflicts of C. Interests ................................................................................................................................................. 10 D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections ................................................................................................................................... 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading . 11 A. Code of Ethics ............................................................................................................................ 11 B. Recommendations Involving Material Financial Interests .................................................. 11 C. Investing Personal Money in the Same Securities as Clients .............................................. 11 D. Trading Securities At/Around the Same Time as Clients’ Securities ................................ 11 Item 12: Brokerage Practices ................................................................................................................... 12 A. Factors Used to Select Custodians and/or Broker/Dealers ................................................ 12 1. Research and Other Soft-Dollar Benefits ............................................................................ 12 2. Brokerage for Client Referrals .............................................................................................. 12 3. Clients Directing Which Broker/Dealer/Custodian to Use ............................................ 12 B. Aggregating (Block) Trading for Multiple Client Accounts ................................................ 13 Item 13: Review of Accounts .................................................................................................................. 13 A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews ................. 13 B. Factors That Will Trigger a Non-Periodic Review of Client Accounts .............................. 13 C. Content and Frequency of Regular Reports Provided to Clients ....................................... 13 Item 14: Client Referrals and Other Compensation ............................................................................ 13 Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes A. Sales Awards or Other Prizes) ........................................................................................................... 13 B. Compensation to Non – Advisory Personnel for Client Referrals ..................................... 14 Item 15: Custody ...................................................................................................................................... 15 Item 16: Investment Discretion .............................................................................................................. 15 Item 17: Voting Client Securities (Proxy Voting) ................................................................................. 15 Item 18: Financial Information ............................................................................................................... 16 A. Balance Sheet .............................................................................................................................. 16 Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual B. Commitments to Clients ..................................................................................................................... 16 2  C. Bankruptcy Petitions in Previous Ten Years ......................................................................... 16 3  Item 4: Advisory Business A. Description of the Advisory Firm Approach Capital LLC (hereinafter “Approach Capital”) is a Limited Liability Company organized in the State of Arizona. The firm was formed in December 2017, and the principal owner is Gregory D Stott. B. Types of Advisory Services Portfolio Management Services Approach Capital offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Approach Capital creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring Approach Capital evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Approach Capital will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Approach Capital seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Approach Capital’s economic, investment or other financial interests. To meet its fiduciary obligations, Approach Capital attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Approach Capital’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is Approach Capital’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent among its clients on a fair and equitable basis over time. Services Limited to Specific Types of Investments Approach Capital generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, 4  commodities and non-U.S. securities. Approach Capital may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Approach Capital offers the same suite of services to all of its clients. However, specific client investment strategies and their implementation are dependent upon the client Investment Policy Statement which outlines each client’s current situation (income, tax levels, and risk tolerance levels). Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent Approach Capital from properly servicing the client account, or if the restrictions would require Approach Capital to deviate from its standard suite of services, Approach Capital reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program wherein the investor pays one stated fee that includes management fees, transaction costs, fund expenses, and any other administrative fees. Approach Capital does not participate in any wrap fee programs. E. Assets Under Management Approach Capital has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 100,000,000.00 $ 0.00 December 2025 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $10,000 – $1,000,000 1.50% 0.75% $1,000,001– $3,000,000 $3,000,001+ 0.65% 5  Fee Example: For an account valued at $1,500,000, the annual fee is $11,250.00 (1,500,000 × 0.0075), which results in a monthly charge of $937.50. This is calculated by dividing the annual total by 12 months: $11,250.00 / 12 = $937.50. For assets that are directly invested with private investment funds or held away from Schwab for which Approach Capital manages, Approach Capital will be compensated on the basis of assets invested at a minimum flat fee of 1% and as reported by the manager. Approach Capital uses the value of the account as of the last business day of the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Lower fees for comparable services may be available from other sources. The final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Clients may terminate the agreement without penalty for a full refund of Approach Capital's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract by giving Approach Capital written notice. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a monthly basis. Fees are paid in advance. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e., custodian fees, commissions, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by Approach Capital. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees Approach Capital collects fees in advance. Refunds for fees paid in advance will be returned within fourteen days to the client via check, or return deposit back into the client’s account. For all asset based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee by 365.) 6  E. Outside Compensation For the Sale of Securities to Clients Neither Approach Capital nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management Approach Capital does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7: Types of Clients Approach Capital generally provides advisory services to the following types of clients: ❖ ❖ Individuals High-Net-Worth Individuals There is an account minimum of $10,000, which may be waived by Approach Capital in its discretion. Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis Approach Capital’s methods of analysis include Modern portfolio theory. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Investment Strategies Approach Capital uses long-term trading. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 7  B. Material Risks Involved Methods of Analysis Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. 8  Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. 9  Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither Approach Capital nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither Approach Capital nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Gregory Don Stott is Director of Toy Storage LLC, boat and RV storage facility. Gregory Don Stott is Member of Magic Closet LLC, a manufacturer and distributor of an outdoor family yard game. From time to time, he may offer clients advice or products from those activities and clients should be aware that these services may involve a conflict of interest. Approach Capital 10  LLC always acts in the best interest of the client and clients always have the right to decide whether or not to utilize the services of any representative of Approach Capital LLC in such individual’s outside capacities. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections Approach Capital does not utilize nor select third-party investment advisers. All assets are managed by Approach Capital management. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Approach Capital has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. Approach Capital's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests Approach Capital does not recommend that clients buy or sell any security in which a related person to Approach Capital or Approach Capital has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of Approach Capital may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of Approach Capital to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. Approach Capital will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities Please see Item 11.C above. 11  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on Approach Capital’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and Approach Capital may also consider the market expertise and research access provided by the broker-dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in Approach Capital's research efforts. Approach Capital will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. Approach Capital recommends Schwab Institutional, a division of Charles Schwab & Co., Inc., Vantage Self Directed Retirement Plans and Fidelity Brokerage Services LLC. 1. Research and Other Soft-Dollar Benefits While Approach Capital has no formal soft dollars program in which soft dollars are used to pay for third party services, Approach Capital may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). Approach Capital may enter into soft- dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and Approach Capital does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. Approach Capital benefits by not having to produce or pay for the research, products or services, and Approach Capital will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that Approach Capital’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals Approach Capital receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 3. Clients Directing Which Broker/Dealer/Custodian to Use Approach Capital may permit clients to direct it to execute transactions through a specified broker-dealer. If a client directs brokerage, then the client will be required to 12  acknowledge in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to Approach Capital to select brokers; this direction may result in higher commissions, which may result in a disparity between free and directed accounts; and trades for the client and other directed accounts may be executed after trades for free accounts, which may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts Approach Capital does not aggregate or bunch the securities to be purchased or sold for multiple clients. This may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for Approach Capital's advisory services provided on an ongoing basis are reviewed at least Quarterly by Gregory D Stott, portfolio manager, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at Approach Capital are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of Approach Capital's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Approach Capital will also provide at least quarterly a separate written statement to the client. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) 13  With respect to Schwab, Approach Capital receives access to Schwab’s institutional trading and custody services, which are typically not available to Schwab retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Schwab Advisor Services. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For Approach Capital client accounts maintained in its custody, Schwab generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab or that settle into Schwab accounts. Schwab also makes available to Approach Capital other products and services that benefit Approach Capital but may not benefit its clients’ accounts. These benefits may include national, regional or Approach Capital specific educational events organized and/or sponsored by Schwab Advisor Services. Other potential benefits may include occasional business entertainment of personnel of Approach Capital by Schwab Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist Approach Capital in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of Approach Capital’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of Approach Capital’s accounts. Schwab Advisor Services also makes available to Approach Capital other services intended to help Approach Capital manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to Approach Capital by independent third parties. Schwab Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to Approach Capital. Approach Capital is independently owned and operated and not affiliated with Schwab. B. Compensation to Non – Advisory Personnel for Client Referrals Approach Capital does not directly or indirectly compensate any person who is not advisory personnel for client referrals. 14  Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, Approach Capital will be deemed to have limited custody of client's assets. Because client fees will be withdrawn directly from client accounts, in states that require it, Approach Capital will: (A) Possess written authorization from the client to deduct advisory fees from an account held by a qualified custodian. (B) Send the qualified custodian written notice of the amount of the fee to be deducted from the client’s account and verify that the qualified custodian sends invoices to the client. (C) Send the client a written invoice itemizing the fee upon or prior to fee deduction, including the formula used to calculate the fee, the time period covered by the fee and the amount of assets under management on which the fee was based. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Clients are urged to compare the account statements they received from custodian with those they received from Approach Capital. Item 16: Investment Discretion Approach Capital provides discretionary investment advisory services to clients. Clients may, but typically do not, impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, Approach Capital generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. Item 17: Voting Client Securities (Proxy Voting) Approach Capital acknowledges its fiduciary obligation to vote proxies on behalf of those clients that have delegated to it, or for which it is deemed to have, proxy voting authority. Approach Capital will vote proxies on behalf of a client solely in the best interest of the relevant client and has established general guidelines for voting proxies. Approach Capital may also abstain from voting if, based on factors such as expense or difficulty of exercise, it determines that a client’s interests are better served by abstaining. Further, because proxy proposals and individual company facts and circumstances may vary, Approach Capital may vote in a manner that is contrary to the general guidelines if it believes that doing so would be in a client’s best interest to do so. If a proxy proposal presents a conflict of interest between Approach Capital and a client, 15  then Approach Capital will disclose the conflict of interest to the client prior to the proxy vote and, if participating in the vote, will vote in accordance with the client's wishes. Clients may obtain a complete copy of the proxy voting policies and procedures by contacting Approach Capital in writing and requesting such information. Each client may also request, by contacting Approach Capital in writing, information concerning the manner in which proxy votes have been cast with respect to portfolio securities held by the relevant client during the prior annual period. Clients may direct Approach Capital to vote proxies for particular solicitations by contacting Approach Capital prior to the voting deadline to discuss and select the option that best suits the clients investment needs. Item 18: Financial Information A. Balance Sheet Approach Capital neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither Approach Capital nor its management has any financial condition that is likely to reasonably impair Approach Capital’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years Approach Capital has not been the subject of a bankruptcy petition in the last ten years. 16