AZA CAPITAL MANAGEMENT

ITEM 1 – COVER PAGE Part 2A of Form ADV Firm Brochure March 18, 2026 AZA Capital Management 141 W. Jackson Blvd., Ste. 3332 Chicago, IL 60604 www.azacapital.com We appreciate your interest in our firm. This brochure provides information about the qualifications and business practices of AZA Capital Management (“Adviser” or “AZA” or “we”). If you have any questions about the contents of this brochure, please contact us by phone at 312-429-0880 or by email at www.azacapital.com/contact. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (“SEC”) or by any state securities authority. information about AZA Capital Management is available on the SEC’s website at Additional www.adviserinfo.sec.gov. AZA Capital Management is registered as an investment adviser with the SEC. Our registration as an investment adviser does not imply any level of skill or training. We welcome the opportunity to talk with you in more detail about our firm and your specific investment goals. Filed 3/18/2026 1 of 19 AZA CapitalManagement  AZA Capital Management Part 2A of Form ADV ITEM 2 – MATERIAL CHANGES No material changes were made to this brochure since the last annual update filed March 31, 2025. When applicable we will deliver a summary of material changes to existing clients within 120 days of the close of AZA’s fiscal year. Clients wishing to receive a full copy of the current brochure may request one at no charge by contacting us by phone at 312-429-0880 or by email at www.azacapital.com/contact. Filed 3/18/2026 2 of 19  AZA Capital Management Part 2A of Form ADV ITEM 3 – TABLE OF CONTENTS ITEM 1 – COVER PAGE ................................................................................................................................... 1 ITEM 2 – MATERIAL CHANGES ...................................................................................................................... 2 ITEM 3 – TABLE OF CONTENTS ...................................................................................................................... 3 ITEM 4 – ADVISORY BUSINESS ...................................................................................................................... 4 ITEM 5 – FEES AND COMPENSATION ............................................................................................................ 5 ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT .................................................. 8 ITEM 7 – TYPES OF CLIENTS .......................................................................................................................... 8 ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS ....................................... 8 ITEM 9 – DISCIPLINARY INFORMATION ...................................................................................................... 11 ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES OR AFFILIATIONS ...................................................... 11 ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING ..................................................................................................................................................... 12 ITEM 12 – BROKERAGE PRACTICES ............................................................................................................. 13 ITEM 13 – REVIEW OF ACCOUNTS .............................................................................................................. 16 ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION ..................................................................... 17 ITEM 15 – CUSTODY .................................................................................................................................... 17 ITEM 16 – INVESTMENT DISCRETION ......................................................................................................... 18 ITEM 17 – VOTING CLIENT SECURITIES ....................................................................................................... 18 ITEM 18 – FINANCIAL INFORMATION ......................................................................................................... 19 Filed 3/18/2026 3 of 19  AZA Capital Management Part 2A of Form ADV ITEM 4 – ADVISORY BUSINESS A. General Description of Advisory Firm AZA Capital Management (“AZA,” the “Adviser,” or “we”) is an independent, fee-only investment advisory firm that manages value-seeking investment strategies designed to adapt to changing market conditions. Our approach emphasizes identifying asset classes and securities trading at attractive valuations while helping long-term investors navigate market cycles by avoiding common pitfalls and capitalizing on opportunities as markets rise and fall over time. Founded in 1997, AZA is a privately held corporation owned and operated by its employees. Christopher Recker, Jeffrey Keen, and Michael LaFontaine each own more than 25% of the firm’s outstanding common stock. AZA’s principal place of business is in Chicago, Illinois. B. Description of Advisory Services Offered We combine quantitative analysis and qualitative research to help our clients target their investment objectives while navigating the long-term changes in market conditions. Our services are tailored to the needs of each client and include, but are not limited to, the following: Wealth Management For Individuals and Families • Risk “comfort zone” identification • Asset allocation guidance and management • Investment selection and management • Financial planning related to savings, retirement, and income • Performance reporting, market commentary, and education Asset Management For Financial Advisors and Their Clients • Portfolio allocation guidance and management • Separately managed account strategies • Strategies provided on third-party TAMP platform Employer-Sponsored Retirement Plans For Businesses and Organizations • Identify, develop, and implement plan design concepts that best achieve the goals of recruiting and retention, cost efficiency, and participant retirement readiness. • Develop/implement policies and procedures to ensure plans meet fiduciary compliance requirements and adhere to fiduciary best practices. • Screen, select, and monitor investment options Filed 3/18/2026 4 of 19  AZA Capital Management Part 2A of Form ADV In some situations, we implement investment advice on behalf of clients in certain held-away accounts that are maintained at independent third-party custodians. These held-away accounts are often 401(k) accounts, 529 plans and other assets that are not held at our primary custodian(s). The order management system that we use for held-away accounts is provided by Pontera Solutions, Inc. We review, monitor, and manage these held-away accounts in an integrated way with client accounts held at our primary custodians. Further information about this service is available in Item 5. As a fiduciary, we have duties of care and of loyalty to you and are subject to obligations imposed on us by the federal and state securities laws. As a result, you have certain rights that you cannot waive or limit by contract. Nothing in our agreement with you should be interpreted as a limitation of our obligations under the federal and state securities laws or as a waiver of any non-waivable rights you possess. C. Availability of Tailored Services for Individual Clients We have the ability to tailor our services and will provide investment advice and management based on each client’s specific objectives. When practical we will accommodate reasonable client restrictions with respect to certain investments, security types, tax considerations, or account features. Certain investment strategies and portfolios may be more accommodating of restrictions than others. As a result, the performance of an account within a particular investment objective may differ from other accounts within that same investment objective. Differences in portfolio composition may be attributable to a variety of factors, including but not limited to, the type of account, specific investment restrictions and guidelines, and the size and frequency of client contributions and withdrawals. D. Wrap Fee Programs AZA currently does not participate in any wrap fee programs. E. Assets Under Management Calculated as of December 31, 2025 Discretionary Basis: $ 334,873,017 Non-Discretionary Basis: $ 4,694,259 Total Assets Under Management: $ 339,567,276 ITEM 5 – FEES AND COMPENSATION A. Compensation for Advisory Services AZA is a “fee-only” investment advisor, which means our remuneration is derived solely from our fees for services provided to clients. We are not affiliated with a brokerage firm and do not receive compensation for the sale of products, such as mutual funds, annuities, or insurance policies. Filed 3/18/2026 5 of 19  AZA Capital Management Part 2A of Form ADV We charge each client an investment advisory fee (the “Advisory Fee”) based on the value of the client’s assets under management and the services provided. The Advisory Fee is defined at the outset of the advisory relationship and generally ranges from 0.40% to 1.20% per year depending on the services rendered. In certain circumstances, a flat dollar fee may be utilized instead of a percentage of managed assets. All fees are subject to negotiation, and it is anticipated that such situations may occur with larger, more complex projects and relationships. Our fees are based on the market value of your assets under our management, including cash, accrued interest, and securities purchased on margin. For certain clients, we charge an advisory fee for services provided with respect to the held-away accounts mentioned above in Item 4, just as we do with client accounts held at our primary custodians. The specific fee schedule charged by us is provided in the client’s investment advisory agreement with us. B. Payment of Fees to Adviser Payment schedules may differ among clients depending on the services provided and the terms of the client agreement. Quarterly, In Advance: For payment schedules that are quarterly in advance, the Advisory Fee is payable at the beginning of each calendar quarter and in advance of services provided. Quarterly, In Arrears: For payment schedules that are quarterly in arrears, the Advisory Fee is payable after the completion of each calendar quarter and after services have been provided. Monthly, In Arrears: For payment schedules that are monthly in arrears, the Advisory Fees is payable after the completion of each calendar month and after services have been provided. Additional Information: Advisory Fees rendered for a partial period are calculated on a pro rata basis. AZA normally requires that Advisory Fees be debited directly from a client’s managed investment account(s). Depending on a corporate retirement plan’s particular service agreement, the Advisory Fees for a plan may be invoiced by the Adviser or collected by the plan’s recordkeeper, who in turn sends payment to the Adviser. In certain situations and with specific client agreement, advisors may access our investment strategies via Axxcess Wealth Management, a turn-key asset management program (TAMP). In such situations, AZA does not handle the billing process, and it may follow a different schedule than AZA’s process noted above. C. Other Fees and Expenses In addition to paying Advisory Fees to the Adviser, client accounts may be subject to other investment expenses such as fund expenses, external manager fees, reporting fees, custodial charges, brokerage fees, commissions, and related costs. These may include interest expenses, taxes, transfer and registration fees, foreign exchange transaction fees, wire transfer or electronic fund fees, and other portfolio expenses. Filed 3/18/2026 6 of 19  AZA Capital Management Part 2A of Form ADV Please refer to Item 12 in this brochure for a discussion of AZA’s brokerage practices, including factors that we consider when selecting brokers and account custodians. Additionally, client accounts may be subject to costs, expenses, and fees associated with investment products or services that may be necessary or incidental to an investment account or strategy. Client assets may be invested in mutual funds, exchange-traded funds (ETFs), or other investment vehicles. In such cases, the client will bear its pro rata share of the investment management fee and other fees assessed by the investment vehicle, which are in addition to the investment Advisory Fee paid to AZA. All fees paid to AZA for investment advisory services are separate and distinct from the fees and expenses charged by ETFs and mutual funds. These fees and expenses are described in each fund’s prospectus and generally include a management fee, shareholder servicing, other fund expenses, and sometimes a distribution fee. If a fund also imposes sales charges, clients may pay an initial or deferred sales charge. AZA generally limits the utilization of mutual funds in the investment accounts that we manage. D. Fee Billing and Refunds AZA calculates Advisory Fees based on the fair market value of the managed assets as reported by Orion Advisor Technology (“Orion”), a third-party vendor of portfolio accounting technology. Orion obtains pricing from the account custodians but may also include accrued interest on fixed income securities when calculating fair market value. Depending upon the client agreement, AZA will use one of the following valuation date methods: 1) last business day of the billing cycle, or 2) average daily balance over the billing cycle. AZA prorates its Advisory Fees for accounts initiated or terminated during a billing period. AZA also prorates its Advisory Fees for capital contributions made during a billing period and assesses these particular fees in arrears during the subsequent billing cycle. If a client account has a margin balance, Advisory Fees will be based on the total value of the account, including the margin. The investment advisory agreement may be terminated by the client or AZA at any time upon written notice to the other party. With respect to any unearned Advisory Fees billed in advance, a prorated refund will be calculated based on the number of days remaining from the termination date to the end of the calendar quarter. Any refund due to the client will be returned within 30 days following the close of the quarter in which the termination occurred. With respect to any earned Advisory Fees due in arrears to the Adviser, a prorated invoice will be calculated based on the number of days the service agreement was active during the unbilled period and sent to the former client for payment. Termination of AZA’s agreement shall not affect liabilities or obligations incurred from transactions initiated under our agreement prior to the termination date, such as the purchase of investments by AZA for client’s account. Clients are responsible for any cost incurred in transferring assets from their account to a different account and any Advisory Fees accrued and unpaid at the time of termination. After the termination date, AZA will have no further duties or obligations to the client under our agreement. E. Compensation for the Sale of Securities Neither AZA nor the firm’s representatives receive any commissions or compensation for the sale of securities or other investment products. Filed 3/18/2026 7 of 19  AZA Capital Management Part 2A of Form ADV ITEM 6 – PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT AZA currently does not charge performance-based fees (i.e., fees based on a share of capital gains or capital appreciation in a portfolio). ITEM 7 – TYPES OF CLIENTS AZA provides investment management and consulting services to individuals and families, other financial advisors and their clients, institutions, corporate pension and profit-sharing plans, employer-sponsored retirement plans, and charitable organizations. AZA generally will require a minimum of $200,000 of assets under management but may make exceptions in its sole and absolute discretion. Accounts in one household may be combined to meet the minimum. If a client’s assets fall below the required minimum due to market fluctuations only, the client will not be required to invest additional funds with the Adviser to meet the minimum. ITEM 8 – METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS A. Methods of Analysis In general AZA employs quantitative analysis and qualitative research of the U.S. and global economies, financial stress indicators, market valuations and trends, and various types of securities when formulating investment advice and managing assets. AZA conducts its own research utilizing information from third parties. Information sources include, but are not limited to, the following: (i) financial newspapers and magazines, (ii) research prepared by other organizations, (iii) annual reports, prospectuses, and other SEC filings, and (iv) company press releases, presentations, and other corporate communications. AZA also purchases and reviews information from recognized financial data aggregators. All investing involves risk, including the possible loss of principal, and clients should be prepared to bear that loss. B. Material Risks Relating to Investment Strategies AZA offers a variety of investment approaches that aim to address a wide range of client needs and objectives. Portfolios generally are tailored to a client’s personal goals, investment objectives, risk tolerance, and financial circumstances. The investment strategies most commonly employed by our clients are discussed as follows: 1. DRIV Core – The DRIV Core strategy pairs passive indexing with tactical allocation to create an adaptable portfolio that seeks to achieve returns comparable to the broad U.S. stock market over full market cycles but with less volatility and downside risk. The goal is to achieve superior risk-adjusted returns over the long run. Filed 3/18/2026 8 of 19  AZA Capital Management Part 2A of Form ADV DRIV Core varies its allocation between stock and bond investments over time and through different market conditions, based on our analysis of valuations and projected returns. The target equity allocation can range from approximately 20% to 80% with a median of 50%. This strategy invests primarily in index-based exchange traded funds (ETFs). The allocation among the investments is actively managed over time. Portfolio allocation decisions are based on a multi-factor model, which includes proprietary trend analysis in equity valuations and price momentum, credit analysis, and economic parameters. Margin is not used in this strategy, unless directed by the client. 2. Adaptive 40 – The Adaptive 40 strategy pairs passive indexing with tactical allocation to create an adaptable portfolio that seeks to achieve returns comparable to a static 40/60 blended portfolio over full market cycles but with less volatility and downside risk. The Adaptive 40 strategy is comprised of approximately 20% static equity, 40% tactical allocation via our DRIV Core strategy, and 40% static bond. DRIV Core varies its allocation between stock and bond investments over time and through different market conditions, based on our analysis of valuations and projected returns. The combination of these components allows the target equity allocation to range from approximately 28% to 52% with a median of 40%. This strategy invests primarily in index-based exchange traded funds (ETFs). The allocation among the investments is actively managed over time. Portfolio allocation decisions are based on a multi-factor model, which includes proprietary trend analysis in equity valuations and price momentum, credit analysis, and economic parameters. Margin is not used in this strategy, unless directed by the client. 3. Adaptive 60 – The Adaptive 60 strategy pairs passive indexing with tactical allocation to create an adaptable portfolio that seeks to achieve returns comparable to a static 60/40 blended portfolio over full market cycles but with less volatility and downside risk. The Adaptive 60 strategy is comprised of approximately 40% static equity, 40% tactical allocation via our DRIV Core strategy, and 20% static bond. DRIV Core varies its allocation between stock and bond investments over time and through different market conditions, based on our analysis of valuations and projected returns. The combination of these components allows the target equity allocation to range from approximately 48% to 72% with a median of 60%. This strategy invests primarily in index-based exchange traded funds (ETFs). The allocation among the investments is actively managed over time. Portfolio allocation decisions are based on a multi-factor model, which includes proprietary trend analysis in equity valuations and price momentum, credit analysis, and economic parameters. Margin is not used in this strategy, unless directed by the client. Filed 3/18/2026 9 of 19  AZA Capital Management Part 2A of Form ADV 4. Adaptive 80 – The Adaptive 80 strategy pairs passive indexing with tactical allocation to create an adaptable portfolio that seeks to achieve returns comparable to a static 80/20 blended portfolio over full market cycles but with less volatility and downside risk. The Adaptive 80 strategy is comprised of approximately 60% static equity and 40% tactical allocation via our DRIV Core strategy. DRIV Core varies its allocation between stock and bond investments over time and through different market conditions, based on our analysis of valuations and projected returns. The combination of these components allows the target equity allocation to range from approximately 68% to 92% with a median of 80%. This strategy invests primarily in index-based exchange traded funds (ETFs). The allocation among the investments is actively managed over time. Portfolio allocation decisions are based on a multi-factor model, which includes proprietary trend analysis in equity valuations and price momentum, credit analysis, and economic parameters. Margin is not used in this strategy, unless directed by the client. 5. Custom Bond Portfolios – Our custom bond portfolios offer customized solutions for a client’s income, duration, and tax needs. The composition of the portfolio will be comprised of a diversified mix of individual bonds, based on risk and income objectives. Bonds can be municipal, corporate, or government. Our goal is to manage, to the degree possible, the inherent risks of investing in bonds. However, it should be noted that bonds carry the following risks: 1) interest rate risk, 2) reinvestment risk, 3) inflation risk, 4) credit/default risk, 5) rating downgrade, and 6) liquidity risk. Margin is not used in this strategy, unless directed by the client. C. Risks Associated with Types of Securities that are Primarily Utilized Equity Securities: The value of equity securities fluctuates in response to issuer, political, market, and economic developments. Fluctuations can be dramatic over the short as well as long term, and different parts of the market and different types of equity securities can react differently to these developments. For example, large cap stocks can react differently from small cap stocks, and “growth” stocks can react differently from “value” stocks. Issuer, political, or economic developments can affect a single issuer, issuers within an industry or economic sector or geographic region, or the market as a whole. Changes in the financial condition of a single issuer can impact the market as a whole. Terrorism and related geo- political risks have led, and may in the future lead, to increased short-term market volatility and may have adverse long-term effects on world economies and markets generally. Exchange Traded Funds: Because exchange trade funds (“ETFs”) are, by definition, portfolios of securities, AZA believes that the unsystematic risk associated with investments in ETFs is generally very low relative to investments in ordinary securities of individual issuers. However, there are events that can trigger sharp and sometimes adverse price movements in ETFs that are not related to movements of the market in Filed 3/18/2026 10 of 19  AZA Capital Management Part 2A of Form ADV general. Not limited to, but among these, are surprise dividends, changes to regular dividend amounts, announcements of rights offerings and possible surprise revisions to net asset values of the ETF. Fixed Income and Debt Securities: Investment in fixed income and debt securities such as bonds, notes, and asset backed securities, subject a client’s portfolios to the risk that the value of these securities overall will decline because of rising interest rates. Similarly, portfolios that hold such securities are subject to the risk that the portfolio’s income will decline because of falling interest rates. Investments in these types of securities will also be subject to the credit risk created when a debt issuer fails to pay interest and principal in a timely manner, or that negative perceptions of the issuer’s ability to make such payments will cause the price of that debt to decline. Lastly, investments in debt securities will also subject the investments to the risk that the securities may fluctuate more in price, and are less liquid than higher rated securities because issuers of such lower rated debt securities are not as strong financially. Equity Options: Various option strategies give the holder the right to acquire or sell underlying securities at the contract strike price up until expiration of the option. Long option positions entail greater risk but allow an investor to gain market exposure to a particular security or group of securities without the capital commitment required to purchase the underlying security or groups of securities. In addition, options allow investors to hedge security positions held in the portfolio. For detailed information on the use of options and option strategies, please contact the Options Clearing Corporation for the current Options Risk Disclosure Statement. ITEM 9 – DISCIPLINARY INFORMATION AZA is required to disclose any legal or disciplinary events that are material to a client’s or a prospective client’s evaluation of the Adviser’s business or the integrity of the Adviser’s management. AZA has no disciplinary matters to disclose under this Item. ITEM 10 – OTHER FINANCIAL INDUSTRY ACTIVITIES OR AFFILIATIONS A. Broker-Dealer Registration Status Not applicable. B. Futures or Commodities-Related Registration Status Not applicable. C. Material Relationships or Arrangement with Related Industry Participants Not applicable. D. Recommended Third Party Advisers Not applicable. Filed 3/18/2026 11 of 19  AZA Capital Management Part 2A of Form ADV ITEM 11 – CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING AZA has adopted a Code of Ethics (the “Code”) for all supervised persons of the firm describing its high standard of business conduct and fiduciary duty to its clients. The Code includes provisions relating to the confidentiality of client information, a prohibition on insider trading, a prohibition of rumor mongering, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at AZA must acknowledge the terms of the Code annually, or as amended. Clients or prospective clients may obtain a copy of the firm’s Code by contacting us by phone at 312-429-0880 or by email at www.azacapital.com/contact. AZA anticipates that, in appropriate circumstances and consistent with clients’ investment objectives, it will recommend to advisory clients or prospective clients the purchase or sale of securities in which AZA, its affiliates and/or clients, directly or indirectly, have a material financial interest. AZA’s employees and persons associated with AZA are required to follow AZA’s Code. Subject to satisfying this policy and applicable laws, officers, directors and employees of AZA and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for AZA’s clients. The Code is designed to assure that the personal securities transactions, activities and interest of the employees of AZA will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code certain classes of securities have been designated as exempt transactions, based upon a determination that these would not materially interfere with the best interest of AZA’s clients. Nonetheless, because the Code in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is monitored under the Code to reasonably prevent conflicts of interest between AZA and our clients. Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with AZA’s obligation of best execution. In such circumstances, the affiliated and client accounts will receive securities at a total average price. Each affiliated and client account will pay its own commission rate by trade. AZA will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis when practical. Any exceptions will be documented. It is AZA’s policy that the firm will not perform any principal transactions or agency cross transactions. In a principal transaction, an adviser, acting for its own account, buys a security from, or sells a security to, the account of a client. An agency cross transaction is defined as a transaction where a person acts as an investment adviser in relation to a transaction in which the investment adviser, or any person controlled by or under common control with the investment adviser, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an adviser is dually registered as a broker-dealer or has an affiliated broker-dealer. Filed 3/18/2026 12 of 19  AZA Capital Management Part 2A of Form ADV ITEM 12 – BROKERAGE PRACTICES A. Factors Considered in Selecting or Recommending Broker-Dealers for Client Transactions AZA generally will seek “best execution” in light of the circumstances involved in a particular transaction. The Adviser considers a number of factors in selecting a broker-dealer to execute transactions and determining the reasonableness of the broker-dealers compensation (i.e., commissions). Such factors include net price, reputation, financial strength and stability, efficiency of execution and error resolution, and offering to the Adviser online access to computerized data regarding a client’s accounts. In selecting a broker-dealer to execute transactions and determining the reasonableness of the broker-dealer’s compensation, the Adviser need not solicit competitive bids and does not have an obligation to seek the lowest available commission cost. It is not the Adviser’s practice to negotiate “execution only” commission rates, thus a client may be deemed to be paying for research, brokerage, or other services provided by a broker-dealer which are included in the commission rate. AZA currently has arrangements with Axos Advisor Services (“Axos”) and Schwab Advisor Services (“Schwab”) whereby the Adviser would suggest to its clients that Axos or Schwab serve as the custodian to their accounts. Axos Advisor Services is a trademark of Axos Clearing LLC and provides back-office services for registered investment advisers. Neither Axos Advisor Services nor Axos Clearing LLC provides investment advice or makes investment recommendations in any capacity. Securities products are offered by Axos Clearing LLC, Member FINRA & SIPC. Schwab Advisor Services serves independent investment advisors and includes the custody, trading, and support services of Charles Schwab & Co., Inc. a registered broker-dealer and member SIPC, and the technology products and services of Performance Technologies, Inc. (“PTI”). Schwab and PTI are separate companies affiliated as subsidiaries of The Charles Schwab Corporation, but their products and services are independent of each other. The Adviser is separate and unaffiliated with Axos and Schwab, and therefore, is independently owned and operated. Axos and Schwab provide services that include custody of client securities, trade execution, and clearance and settlement of transactions. The duty of best execution is not eliminated by the foregoing arrangements the Adviser currently has with Axos and Schwab. (Please see the disclosures under Item 14 below.) Schwab and Axos provide AZA with access to its institutional trading and custody services, which are typically not available to retail investors but are typically offered to independent investment advisers such as AZA. Schwab and Axos also makes available products and services that benefit AZA but may not directly benefit the client or the client’s account. These products and services assist us in managing and administering client accounts. They include investment research, both proprietary and that of third parties. AZA may use this research to service all or some substantial number of client accounts, including accounts maintained at other custodians. In addition to investment research, Schwab and Axos also make available software and other technology that: facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate trade execution and allocate aggregated trade orders for multiple client accounts; • provide access to client account data (such as duplicate trade confirmations and account statements); • • • provide pricing and other market data; Filed 3/18/2026 13 of 19  AZA Capital Management Part 2A of Form ADV facilitate payment of our fees from our clients’ accounts; and • • assist with back-office functions, recordkeeping, and client reporting. Schwab and Axos also offer other services intended to help us manage and further develop our business enterprise. These services include: technology, compliance, legal, and business consulting; and • educational conferences and events; • • publications and conferences on practice management and business succession. Schwab and Axos may provide some of these services directly. In other cases, it will arrange for third-party vendors to provide the services to the Firm. Schwab and Axos may also discount or waive fees for some of these services or pay all or a part of a third party’s fees. Schwab and Axos may also provide us with other benefits. 1. Research and Other Soft Dollar Benefits The Adviser has no formal soft dollar arrangements and does not use soft dollars to acquire any research services or products from broker-dealers. 2. Brokerage for Client Referrals Adviser has no active referral arrangements with any broker dealers. Adviser seeks to execute client trades through broker dealers where the Adviser believes that clients’ trades will be consistent with seeking best execution. 3. Directed Brokerage A client may instruct the Adviser to execute any or all securities transactions for their account with or through one or more brokers designated by the client. When a client directs the Adviser to use a specified broker-dealer to execute all or a portion of the client’s securities transactions, the Adviser treats the client direction as a decision by the client to retain, to the extent of the direction, the discretion the Adviser would otherwise have in selecting broker-dealers to affect transactions and in negotiating commissions for the client’s account. Although the Adviser attempts to affect such transactions in a manner consistent with its policy of seeking best execution, there may be occasions where it is unable to do so, in which case the Adviser will continue to comply with the client’s instructions. Transactions in the same security for accounts that have directed the use of the same broker will be aggregated. When the directed broker- dealer is unable to execute a trade, the Adviser will select broker-dealers other than the directed broker- dealer to affect client securities transactions. A client who directs the Adviser to use a particular broker- dealer to affect transactions should consider whether such direction may result in certain costs or disadvantages to the client. Such costs may include higher brokerage commissions (because the Adviser may not be able to aggregate orders to reduce transaction costs), less favorable execution of transactions, and the potential of exclusion from the client's portfolio of certain securities due to the inability of the particular broker-dealer in question to provide adequate price and execution. By permitting a client to direct the Adviser to execute the client’s trades through a specified broker-dealer, the Adviser will make no attempt to negotiate commissions on behalf of the client and, as a result, in some transactions such clients may pay materially disparate commissions depending on their commission arrangement with the Filed 3/18/2026 14 of 19  AZA Capital Management Part 2A of Form ADV specified broker-dealer and upon other factors such as number of shares, round and odd lots, and the market for the security. The commissions charged to clients that direct the Adviser to execute the client’s trades through a specified broker-dealer may in some transactions be materially different that those of clients who do not direct the execution of their trades. Clients that direct the Adviser to execute trades through a specified broker-dealer may also lose the ability to negotiate volume commission discounts on batched transactions that may otherwise be available to other clients of the Adviser, and this may cost such clients more money. If the Adviser believes, in its exclusive discretion, that it cannot satisfy its fiduciary duty of best execution by executing a transaction for a client account with a broker designated by the client, the Adviser may execute that transaction with a different broker-dealer. Any client providing instructions to the Adviser regarding direction of brokerage transactions must notify the Adviser in writing if the client desires the Adviser to cease executing transactions with or through any such broker-dealer. B. Trade Allocation and Order Aggregation The Adviser often uses aggregated block transactions in instances where a security is purchased or sold for multiple accounts contemporaneously (or near the same time) and using the same executing broker- dealer. Such aggregation may enable the Adviser to obtain for clients a more favorable price or a better commission rate based upon the volume of a particular transaction. However, in cases where the client has negotiated the commission rate directly with the broker, the Adviser may not be able to obtain more favorable commission rates based on an aggregated trade. In such cases, the client will be precluded from receiving the benefit of any possible commission discounts that might otherwise be available as a result of the aggregated trade. When aggregated block trades are made across multiple custodians/brokerage firms, the order of trading may impact the transaction price. While we generally send block trades simultaneously via the FIX trading protocol, for one-off block trades that cannot be sent simultaneously, we randomly generate the order of custodians to be traded to mitigate price effects over time. TAMP programs and applicable non-discretionary accounts are notified of allocation changes after orders are placed for discretionary accounts. AZA is not responsible for executing the trade orders for accounts in TAMP programs or for certain non-discretionary accounts in which a client executes trades. When an aggregated order is filled completely, the Adviser allocates the securities purchased or proceeds of sale pro rata among the participating accounts, based on the purchase or sale order. Adjustments or changes may be made under certain circumstances, such as to avoid odd lots or excessively small allocations. If the order at a particular broker is filled at several different prices, through multiple trades, generally all such participating accounts will receive the average price and pay the average commission, subject to odd lots, rounding, and market practice. If an aggregated order is only partially filled, the Adviser’s procedures provide that the securities or proceeds are to be allocated in a manner deemed fair and equitable to clients. Depending on the investment strategy pursued and the type of security, this may result in a pro rata allocation to all participating clients. The Adviser and its related persons may also participate in an aggregated order. Filed 3/18/2026 15 of 19  AZA Capital Management Part 2A of Form ADV Trade Error Policy The Adviser has the responsibility to process trade orders correctly, promptly, and ensure the best interest of our clients is served. If it appears that a trade error has occurred, the Adviser will review the relevant facts and circumstances to determine an appropriate course of action. To the extent that trade errors and breaches of investment guidelines and restrictions occur, the Adviser’s trade error correction policy is to ensure that clients are treated fairly and, following error correction, are in the same position they would have been if the error had not occurred and in such a manner that the client incurs no loss. The Adviser will have discretion to resolve a particular error in any appropriate manner that is consistent with the above stated policy. A trade error will not benefit the Adviser in any way. The gains and losses are reconciled according to the policy of the applicable account custodian. If a trade error results in a loss, the Adviser will reimburse the client, unless the executing broker’s policy is to absorb de minimus losses (e.g., under $100). If a trade error results in a gain, the client will retain the gain unless the executing broker’s policy is to donate gains to charity. ITEM 13 – REVIEW OF ACCOUNTS A. Frequency and Nature of Review AZA has adopted a team approach to account management and review. The securities in client accounts are reviewed by the Chief Investment Officer and firm principals on a periodic basis and generally no less frequently than weekly. Reviews of individual account holdings and performance are conducted by the Chief Investment Officer and firm principals on a periodic basis and generally no less frequently than quarterly. B. Factors Prompting a Non-Periodic Review of Accounts Client accounts and strategies may be reviewed and proactively updated at times that do not coincide with a standard review schedule. Non-periodic account reviews and updates may be the result of tactical investment shifts, client requests, significant market events affecting the prices of one or more securities in client accounts, or changes in the financial circumstance and investment planning goals, investment objectives, or guidelines of a particular client. Specific arrangements with particular clients also may trigger reviews of client accounts on a non-periodic basis. C. Content and Frequency of Regular Account Report Direct clients of the Adviser are provided with quarterly performance reports and portfolio commentary. At a minimum, these reports include a list of portfolio holdings and time-weighted total returns calculated net of all fees and expenses. Supplemental reports may be used to provide additional detail. Reports may be delivered to the client as hard copies or electronically in accordance with the client’s agreement with the Adviser. In instances where AZA acts as a sub-advisor to third-party financial advisors or TAMP programs, the responsibility of client reporting is assumed by the primary advisor with the direct client relationship. Filed 3/18/2026 16 of 19  AZA Capital Management Part 2A of Form ADV ITEM 14 – CLIENT REFERRALS AND OTHER COMPENSATION A. Economic Benefits Received from Non-Clients for Providing Services to Clients Not applicable. B. Compensation to Non-Supervised Persons for Client Referrals AZA has arrangements in place with certain third parties, called promoters, under which such promoters refer clients to us in exchange for a percentage of the advisory fees we collect from such referred clients. Such compensation creates an incentive for the promoters to refer clients to us, which is a conflict of interest for the promoters. Rule 206(4)-1 of the Advisers Act addresses this conflict of interest by, among other things, requiring disclosure of whether the promoter is a client or a non-client and a description of the material conflicts of interest and material terms of the compensation arrangement with the promoter. Accordingly, we require promoters to disclose to referred clients, in writing: whether the promoter is a client or a non-client; that the promoter will be compensated for the referral; the material conflicts of interest arising from the relationship and/or compensation arrangement; and the material terms of the compensation arrangement, including a description of the compensation to be provided for the referral. ITEM 15 – CUSTODY Under SEC rules, the Adviser may be viewed for regulatory purposes as having custody of client funds when Advisory Fees are debited directly by a qualified custodian who then automatically pays the Adviser. We do not have physical custody of any of your funds and/or securities. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. At least quarterly, you will receive account statements from the independent, qualified custodian(s) holding your funds and securities. The account statements from your custodian(s) will indicate the amount of our Advisory Fee deducted from your account(s) each billing period. You should carefully review account statements for accuracy. Additionally, you should compare our reports with the statements from your account custodian(s) to reconcile the information reflected on each statement. For instances where clients authorized a standing letter of authorization for Adviser to transfer funds, Adviser will have custody as defined by the SEC. On a very limited basis and with client specific agreement, the Adviser may have custody of client funds due to trustee arrangements. Adviser has retained an independent public accountant to verify assets over which Adviser provides trustee services through surprise examination. The independent accountant must file its certificate on Form ADV-E with the SEC within 120 days of the commencement of the examination. If you have a question regarding your account statement or if you did not receive a statement from your custodian, please contact us by phone at 312-429-0880 or by email at www.azacapital.com/contact. Filed 3/18/2026 17 of 19  AZA Capital Management Part 2A of Form ADV ITEM 16 – INVESTMENT DISCRETION In general, the Adviser will provide investment advisory services on a discretionary basis to clients. Please see Item 4 above for a description of the limitations that clients may place on the Adviser’s discretionary authority. Prior to assuming full discretion in managing a client’s assets, the Adviser will enter into an investment advisory agreement and/or other agreements (e.g., custodian limited power of attorney) that sets forth the scope of the Adviser’s discretion. When granted discretionary authority, the Adviser will have the authority, without obtaining specific consent from the client, to determine (i) the securities to be purchased and sold for the client account (subject to restrictions on its activities set forth in the applicable investment advisory agreement and any written investment guidelines) and (ii) the amount of securities to be purchased or sold for the client account. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. A client’s investment guidelines and restrictions must be provided to the Adviser in writing. ITEM 17 – VOTING CLIENT SECURITIES When authorized by the client, the Adviser will vote client securities (i.e., proxy voting). The Adviser has adopted and implemented policies and procedures that we believe are reasonably designed to ensure that proxies are voted in the best interest of clients, in accordance with our fiduciary duties and SEC rule 206(4)-6 under the Investment Advisers Act of 1940. Our proxy voting guidelines have been tailored to reflect these specific obligations. In addition to SEC requirements governing advisers, our proxy voting policies reflect the fiduciary standards and responsibilities for ERISA. With respect to ERISA accounts, we will always vote proxies unless the plan documents specifically reserve the plan sponsor’s right to vote its own proxies. If situations should arise where there may exist conflict of interest between the Adviser and a client with respect to any shareholder proposals for which proxies are being solicited, the Adviser will request the client’s instructions with respect to the vote. Clients may obtain a copy of AZA’s complete proxy voting policies and procedures upon request. Clients may also obtain information about how AZA voted any proxies on behalf of their account(s) by contacting us by phone at 312-429-0880 or by email at www.azacapital.com/contact. Filed 3/18/2026 18 of 19  AZA Capital Management Part 2A of Form ADV ITEM 18 – FINANCIAL INFORMATION A. Balance Sheet AZA does not require the prepayment of fees of $1200 or more, six months or more in advance, and as such is not required to file a balance sheet. B. Financial Conditions Reasonably Likely to Impair Advisory Firm’s Ability to Meet Commitments to Clients AZA does not have any financial issues that would impair its ability to provide services to clients. C. Bankruptcy Petitions during the Past Ten Years Not applicable. Filed 3/18/2026 19 of 19