ATTESSA CAPITAL LLC

Attessa Capital LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Attessa Capital LLC. If you have any questions about the contents of this brochure, please contact us at (520) 979-8586 or by email at: dkornberg@attessacapital.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. is also available on the SEC’s website at information about Attessa Capital LLC Additional www.adviserinfo.sec.gov. Attessa Capital LLC’s CRD number is: 306827. 3060 N Swan Rd Tucson, AZ 85712 (520) 600-3064 team@attessacapital.com https://www.attessacapital.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 07/17/2025 i  Item 2: Material Changes The material changes in this brochure from the last annual updating amendment of Attessa Capital LLC on 03/27/2025, are described below. Material changes relate to Attessa Capital LLC’s policies, practices or conflicts of interest. • Attesa Capital LLC has updated its Assets Under Management (Item 4.E) • Attesa Capital LLC has disclosed compensation received for advisory services provided on certain insurance products. (Item 5.E) • Matthew Harrison is no longer associated with another investment adviser. (Item 10.C) ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ............................................................................................................................................................................................................................................... 2 Item 3: Table of Contents ............................................................................................................................................................................................................................................... 3 Item 4: Advisory Business ............................................................................................................................................................................................................................................. 4 Item 5: Fees and Compensation ................................................................................................................................................................................................................................... 6 Item 6: Performance-Based Fees and Side-By-Side Management .................................................................................................................................................................. 8 Item 7: Types of Clients .................................................................................................................................................................................................................................................. 8 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .............................................................................................................................................................. 9 Item 9: Disciplinary Information ............................................................................................................................................................................................................................... 12 Item 10: Other Financial Industry Activities and Affiliations ......................................................................................................................................................................... 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ....................................................................................................... 14 Item 12: Brokerage Practices ..................................................................................................................................................................................................................................... 15 Item 13: Review of Accounts ...................................................................................................................................................................................................................................... 16 Item 14: Client Referrals and Other Compensation ............................................................................................................................................................................................ 16 Item 15: Custody ............................................................................................................................................................................................................................................................. 18 Item 16: Investment Discretion ................................................................................................................................................................................................................................. 18 Item 17: Voting Client Securities (Proxy Voting) ................................................................................................................................................................................................ 18 Item 18: Financial Information .................................................................................................................................................................................................................................. 19 iii  Item 4: Advisory Business A. Description of the Advisory Firm Attessa Capital LLC is a Limited Liability Company organized in the State of Arizona. Attessa Capital LLC was formed in November 2019 and has been in business since January 2020. The direct owners are ASB Capital LLC (wholly owned by Alec Scott Berens), DWK Capital LLC (wholly owned by David William Kornberg), MWH Investments LLC (wholly owned by Matthew William Harrison), and James Andrew Good. B. Types of Advisory Services Portfolio Management Services Attessa Capital LLC offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. Attessa Capital LLC 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 Attessa Capital LLC evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. Attessa Capital LLC 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. Attessa Capital LLC seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of Attessa Capital LLC’s economic, investment or other financial interests. To meet its fiduciary obligations, Attessa Capital LLC attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, Attessa Capital LLC’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 Attessa Capital LLC’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. Upon request, Attessa Capital LLC will create a financial plan free of charge in relation to investment advisory services. 4  Financial Planning Financial plans and financial planning may include, but are not limited to: investment planning; life insurance; tax concerns; retirement planning; education planning; and debt/credit planning. Attessa Capital LLC offers financial planning services to clients free of charge. Newsletters Attessa Capital LLC sends out a weekly email titled, “weekly thoughts.” There are no investment recommendations contained in the email and no subscription is required. It is offered to clients free of charge. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Services Limited to Specific Types of Investments Attessa Capital LLC generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds and non-U.S. securities. Attessa Capital LLC may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions Attessa Capital LLC 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 5  (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 Attessa Capital LLC from properly servicing the client account, or if the restrictions would require Attessa Capital LLC to deviate from its standard suite of services, Attessa Capital LLC reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. Attessa Capital LLC does not participate in wrap fee programs. E. Assets Under Management Attessa Capital LLC has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $318,110,389 .00 $ 0 .00 July 2025 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees All Assets 1.00% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period, adjusted for contributions and withdrawals. These fees are non- negotiable and the final fee schedule will be memorialized in the client’s advisory agreement. In certain circumstances, Attessa Capital LLC may negotiate or reduce this fee. These fees are determined by the relationship and the level of work the client is requesting. Clients may terminate the agreement without penalty for a full refund of Attessa Capital LLC's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. 6  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. There are two different methods by which fees are taken: 1. Paid in advance, on a quarterly basis 2. Paid in arrears, on a monthly basis The client’s signed Investment Advisor Agreement will specify which fee method is applicable for that client. Payment of Financial Planning Fees Attessa Capital LLC offers financial planning services to clients free of charge. Payment of Newsletter Fees A weekly email is sent to clients free of charge. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by Attessa Capital LLC. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees Attessa Capital LLC collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and 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 rate by 365.) E. Outside Compensation For the Sale of Securities to Clients Neither Attessa Capital LLC 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. 7  Attessa Capital has an arrangement with a private fund sponsor-manager, Citizen Mint Advisors LLC, that provides Attessa Capital with a portion of the management fee and carried interest that is attributable to investors who invest in the private fund through Attessa Capital. For advisory clients who invest in the private fund, Attessa Capital will waive the portion of its advisory fee based on the value of the client’s assets invested in the private fund to offset any potential of duplicative fees (as those assets will be charged a management fee in the private fund). Attessa Capital does not waive any advisory fees for any amount of carried interest that may be paid by investors in the private fund. Attessa Capital may provide investment advice on clients’ investment options within certain insurance products and receive compensation through the insurance products for these advisory services. Item 6: Performance-Based Fees and Side-By-Side Management Attessa Capital LLC 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. As discussed above in Item 5.E., Attessa Capital has the right to receive a portion of the carried interest that is attributable to investors who invest in the relevant private fund through Attessa Capital. Advisory clients who are charged the management fee and carried interest in the private fund could pay more in total fees than advisory clients who do not invest in the private fund. Attessa Capital’s portion of the carried interest is a form of a performance-based fee, which can provide for increased compensation, and therefore this can create an inherent conflict of interest to recommend investments in the relevant private fund. This conflict of interest is mitigated by limiting access to the relevant private fund to only clients where such an investment is suitable and the client eligible. Item 7: Types of Clients Attessa Capital LLC generally provides advisory services to the following types of clients: ❖ ❖ Individuals High-Net-Worth Individuals There is no account minimum for any of Attessa Capital LLC’s services. 8  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis Attessa Capital LLC’s methods of analysis include Cyclical analysis, Fundamental analysis, Quantitative analysis and Technical analysis. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies Attessa Capital LLC uses long term trading, short term trading, short sales and margin transactions. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. 9  Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies Attessa Capital LLC's use of short sales and margin transactions generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those 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. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized Attessa Capital LLC's use of short sales and margin transactions generally holds greater risk of capital loss. 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 10  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. 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. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance 11  policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. 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. Private funds (including Private Equity) are suitable only for accredited investors or qualified purchasers who understand the risks and can bear the loss of their investment. Investing in private funds involves substantial risks, including the potential for loss of your entire investment. Private fund investments are inherently illiquid with limited or no transferability or redemption rights until fund liquidation. There is no secondary market for these investments. Private funds provide limited access to information about investments, operations, and performance. Certain investments in private funds are not publicly traded and therefore valued using methodologies that may be inherently subjective and may not reflect the actual realizable value of the investments. Private equity funds often invest in a concentrated portfolio of companies or industries, increasing exposure to specific risks. This lack of diversification may result in greater volatility and risk of loss. Investments in certain private funds may involve capital commitments over time through capital calls issued by the fund, and failure to meet these obligations may result in penalties, forfeiture of rights, or dilution of your ownership interest. Private funds typically charge significant fees, including annual management fees (e.g., 1.5%-2% of committed or invested capital) and performance fees or carried interest (e.g., 20% of profits above a defined hurdle rate). These fees can reduce an investor’s net investment returns. Private funds are affected by general market and economic conditions. There is no assurance that a fund’s investment strategy will be successful. Private funds are typically structured as limited partnerships and may involve complex tax structures, obligations, and reporting. Investors are responsible for understanding and complying with all applicable tax laws. 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. 12  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 Attessa Capital LLC 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 Attessa Capital LLC 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 David William Kornberg is an accountant and from time to time, may offer clients advice from those activities and clients should be aware that these services may involve a conflict of interest. Attessa Capital LLC always acts in the best interest of the client and clients are in no way required to utilize the services of any representative of Attessa Capital LLC in connection with such individual’s activities outside of Attessa Capital LLC. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections Attessa Capital LLC does not utilize nor select third-party investment advisers. As discussed previously, Attessa Capital has an arrangement with a private fund sponsor-manager, Citizen Mint Advisors LLC, that provides for shared management rights and compensation. Attessa Capital will participate jointly in discussions concerning the management, operations and direction of the private fund, but will not have the ultimate authority over the private fund or be responsible for its day-to-day operations. Attessa Capital will oversee the private fund sponsor-manager as part of its analysis and oversight of the private fund as an investment for advisory clients. 13  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Attessa Capital LLC 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. Attessa Capital LLC's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests Attessa Capital LLC does not recommend that clients buy or sell any security in which a related person to Attessa Capital LLC or Attessa Capital LLC has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of Attessa Capital LLC may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of Attessa Capital LLC 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. Attessa Capital LLC 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. As discussed above in Item 10.D., Attessa Capital’s shared management rights and compensation in the private fund may include co-investment ownership interest in the private fund. Attessa Capital’s direct or indirect ownership interest in the private fund is an inherent conflict of interest to recommend investments in the relevant private fund. This conflict of interest is mitigated by limiting access to the relevant private fund to only clients where such an investment is suitable and the client eligible, as well as waiving management fees as discussed under Item 5.E., above. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of Attessa Capital LLC may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of Attessa Capital LLC to buy or sell securities before or after 14  recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, Attessa Capital LLC will never engage in trading that operates to the client’s disadvantage if representatives of Attessa Capital LLC buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers Custodians/broker-dealers will be recommended based on Attessa Capital LLC’s duty to seek “best execution,” which is the obligation to seek to execute securities transactions for a client on terms that are the most favorable to the client under the circumstances. Attessa Capital LLC may not achieve most favorable execution for client transactions and may cost clients more money if clients direct brokerage. The client will not necessarily pay the lowest commission or commission equivalent, and Attessa Capital LLC may also consider the market expertise and research access provided by the payment of commissions, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers to aid in the research efforts of Attessa Capital LLC. Attessa Capital LLC will never charge a premium or commission on transactions beyond the actual cost imposed by the broker- dealer/custodian. Attessa Capital LLC require client to use Charles Schwab & Co., Inc. Advisor Services 1. Research and Other Soft-Dollar Benefits Attessa Capital LLC does not receive products or services other than execution (“soft dollar benefits”) from a broker-dealer or third-party for generating commissions but does receive additional economic benefits described in Item 14. 2. Brokerage for Client Referrals Attessa Capital LLC 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 Attessa Capital LLC will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If Attessa Capital LLC buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a 15  single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, Attessa Capital LLC would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. Attessa Capital LLC would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Attessa Capital LLC will divide up amongst accounts in equitable way delivering average cost amongst all the accounts. Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for Attessa Capital LLC's advisory services provided on an ongoing basis are reviewed at least monthly by David Kornberg, Managing Member, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at Attessa Capital LLC 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 Attessa Capital LLC'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. 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) Charles Schwab & Co., Inc. Advisor Services provides Attessa Capital LLC with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services 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 16  adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes 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 Attessa Capital LLC client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services 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 Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to Attessa Capital LLC other products and services that benefit Attessa Capital LLC but may not benefit its clients’ accounts. These benefits may include national, regional or Attessa Capital LLC specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of Attessa Capital LLC by Charles Schwab & Co., Inc. 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 Attessa Capital LLC 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 Attessa Capital LLC’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 Attessa Capital LLC’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to Attessa Capital LLC other services intended to help Attessa Capital LLC 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, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to Attessa Capital LLC by independent third parties. Charles Schwab & Co., Inc. 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 Attessa Capital LLC. Attessa Capital LLC is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. B. Compensation to Non – Advisory Personnel for Client Referrals Attessa Capital LLC engages independent solicitors to provide client referrals. If a client is referred to us by a solicitor, this practice is disclosed to the client in writing by the solicitor and Attessa Capital LLC pays the solicitor out of its own funds—specifically, Attessa 17  Capital LLC generally pays the solicitor a portion of the advisory fees earned for managing the capital of the client or investor that was referred. The use of solicitors is strictly regulated under applicable federal and state law. Attessa Capital LLC’s policy is to fully comply with the requirements of Rule 206(4)-3, under the Investment Advisers Act of 1940, as amended, and similar state rules, as applicable. Attessa Capital LLC may receive client referrals from third parties. These third parties are independent of and unaffiliated with Attessa Capital LLC and there is no employee relationship between them. The third parties do not supervise Attessa Capital LLC and have no responsibility for Attessa Capital LLC’s management of client portfolios or Attessa Capital LLC’s other advice or services. Attessa Capital LLC pays these third parties an on-going fee for each successful client referral. This fee is usually a percentage of the advisory fee that the client pays to Attessa Capital LLC (“Solicitation Fee”). Attessa Capital LLC will not charge clients referred through third parties any fees or costs higher than its standard fee schedule offered to its clients. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, Attessa Capital LLC will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive account statements from the custodian and should carefully review those statements. Item 16: Investment Discretion Attessa Capital LLC provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, Attessa Capital LLC 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. Clients may, but typically do not, impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Item 17: Voting Client Securities (Proxy Voting) Attessa Capital LLC will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. 18  Item 18: Financial Information A. Balance Sheet Attessa Capital LLC 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 In light of the COVID-19 coronavirus and historic decline in market values, Attessa Capital LLC has elected to participate in the CARES Act’s Paycheck Protection Program (“PPP”) to strengthen its balance sheet. Attessa Capital LLC intends to use this loan predominantly to continue payroll for the firm and may ultimately seek loan forgiveness per the terms of the PPP. Due to this and other measures taken internally, Attessa Capital LLC has been able to operate and continue serving its clients. C. Bankruptcy Petitions in Previous Ten Years Attessa Capital LLC has not been the subject of a bankruptcy petition in the last ten years. 19