BEACON CAPITAL MANAGEMENT, INC.

Item 1: Cover Page 7777 Washington Village Drive Suite 280 Dayton, Ohio, 45459 (937) 439-9093 www.beaconinvesting.com riacompliance@sfgmembers.com Wrap Fee Program Brochure Part 2A – Appendix 1 of Form ADV Updated: November __, 2025 This wrap fee brochure provides information about the qualifications and business practices of Beacon Capital Management, Inc. If you have any questions about the contents of this brochure, please do not hesitate to contact us at (515) 221-4879 or by email at: riacompliance@sfgmembers.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. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about Beacon Capital Management is also available on the SEC’s website at www.adviserinfo.sec.gov. Beacon Capital Management Inc.’s CRD number is 120641.  Beacon Capital Management, Inc. ADV Part 2A – Appendix 1 Item 2: Material Changes There have been no material changes since the last annual client brochure. Page 2 of 11  Beacon Capital Management, Inc. ADV Part 2A – Appendix 1 Item 3: Table of Contents Item 1: Cover Page ........................................................................................................................................ 1 Item 2: Material Changes .............................................................................................................................. 2 Item 3: Table of Contents .............................................................................................................................. 3 Item 4: Services, Fees and Compensation .................................................................................................... 4 Item 5: Account Requirements and Types of Clients .................................................................................... 6 Item 6: Portfolio Manager Selection and Evaluation .................................................................................... 6 Item 7: Client Information Provided to Portfolio Managers ......................................................................... 8 Item 8: Client Contact with Portfolio Managers ............................................................................................ 8 Item 9: Additional Information ..................................................................................................................... 8 Page 3 of 11  Beacon Capital Management, Inc. ADV Part 2A – Appendix 1 Item 4: Services, Fees and Compensation Beacon Capital Management, Inc. (“Beacon”) sponsors a wrap fee program for which it is also the portfolio manager. Wrap fee programs are investment programs where the investor pays one stated fee that covers both management fees and transaction costs from a non-affiliated custodian. Beacon does not manage those wrap fee accounts any differently than non-wrap fee accounts. A portion of the fees paid to the wrap account program will be paid to Beacon as a management fee. Beacon offers the following wrap investment services to retail investors (“Clients”): 1. Investment Supervisory Services For a limited number of legacy Clients only, Beacon offers ongoing portfolio management services based on their individual goals, objectives, time horizon, and risk tolerances. In these arrangements, Beacon provides services that are tailored to each individual Client’s needs, and are also responsible for: ensuring investments are suitable for the Client, providing more detailed reporting, and reviewing Client investment objectives on a regular basis. Investment Supervisory Services include, but are not limited to, the following: • Investment strategy • Personal investment policy • Asset allocation • Asset selection • Risk tolerance • Regular portfolio monitoring Legacy supervisory Clients can request reasonable restrictions as detailed above for Direct Accounts. Aside from that, Beacon does not manage these legacy Client accounts any differently than other Client accounts. 2. Investment Advisory Services Beacon provides Investment Advisory Services to Clients who are introduced to Beacon through other non-affiliated financial institutions (the “Retail Advisor”). In this structure, it is the duty of the Retail Advisor to ensure Beacon’s strategies are suitable for a Client. It is the sole responsibility of the Retail Advisor to review Client objectives and communicate changes in investment recommendations to Beacon. The Retail Advisor is responsible for assisting the Client in understanding and determining the most appropriate services and strategies provided by Beacon; communicating with the Client and answering Client inquiries; updating Client information and acquiring suitability information; delivering documents on Beacon’s behalf; and providing updates to Beacon as necessary. After the Retail Advisor has determined the most appropriate portfolio strategy for the Client’s account, Beacon will manage the account continuously according to the invested strategy’s goals and objectives. Beacon has created a series of strategies, each with unique model offerings, constructed using mutual funds and/or ETFs. Beacon currently provides three unique strategy offerings, all of Page 4 of 11  Beacon Capital Management, Inc. ADV Part 2A – Appendix 1 which attempt to limit the impact of extreme market volatility when internal indicators signal a more defensive allocation may be needed. a. Beacon Signal Strategy The Beacon Signal Strategy includes tactical investment models designed to respond to real-time market risk using a mechanical price-based risk response. The models in the strategy use proprietary market-based indices that trigger a predefined exit from equities when conditions indicate a risk of systemic market decline. The strategy also employs a systematic rules-based process for a return to equities based on the time needed for the indices to establish a low watermark. The longer the indices take to establish a low watermark, the larger recovery we will need to re-enter equities. b. Beacon Precision Strategy The Beacon Precision Strategy is a suite of rules-based models designed to dynamically adjust individual positions based on market trends. The Precision Strategy utilizes a proprietary blend of moving averages based on technical indicators that target sustained strength or weakness for each holding independently. When an individual holding shows significant weakness, that holding is sold and reallocated to a more defensive holding. When that same holding shows sustained strength, the defensive holding is sold, and the original holding is reintroduced into the portfolio. c. Beacon Outlook Strategy The Beacon Outlook Strategy is a collection of tactical, data-driven investment models designed to respond to changing economic conditions. These models dynamically adjust market exposure in response to shifts in economic data positioning more aggressively when indicators point to strength and moving defensively when the macro environment weakens. The Beacon Economic Index is the tool Beacon uses to measure the strength of the US economy and guide investment decisions. The Beacon Economic Index transforms a range of data including employment, income, manufacturing, and inflation figures into an indicator used to help us guide investment decisions. Unlike other Beacon model strategies, the Beacon Outlook Strategy is not implemented primarily on a rules-based basis; rather, it allows for the application of more discretionary judgment by us in our execution. As of December 31, 2024 Total Wrap Assets Under Management Maximum Annual Fee (including wrapped fees) $2,313,900,277 1.80% for Investment Supervisory Services .55% for Investment Advisory Services Maximum Annual Fee to Beacon (excluding wrapped fees) 1.80% for Investment Supervisory Services .55% for Investment Advisory Services Beacon assesses a minimum annual fee of $400 for both Investment Supervisory and Investment Advisory Services. The fee is negotiable, and the final fee schedule is attached in the Client’s investment management agreement. The fee is generally withdrawn directly from the Client’s account. The fee is paid monthly or quarterly in advance or in arrears depending upon each Client’s situation, and Clients may terminate their contracts with ten (10) days’ written notice. If a fee is paid in advance, then refunds Page 5 of 11  Beacon Capital Management, Inc. ADV Part 2A – Appendix 1 are given on a prorated basis based on the number of days remaining in a quarter at the point of termination. Clients may terminate their contracts without penalty, for full refund, within 5 business days of signing. In addition to the fee, Clients may also pay fees and expenses related to the Client’s investments in the underlaying mutual funds, ETFs or other investment vehicles used within the Client account. Consult the prospectuses of the invested mutual funds and/or ETFs for a complete description of all fees and expenses. Services similar to those offered by Beacon may be available elsewhere for more or less than the amount Beacon charges for investment advisory services rendered to Clients enrolled in the wrap fee program. For additional information regarding Beacon’s Fees and Compensation for advisory services provided, please see Item 5 of Beacon’s ADV Part 2A. The wrap fee program may cost the Client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program including the cost of the services if provided separately and the trading activity in the Client Account. Although the wrap fee program is one fee for all management and brokerage services, there may be additional fees not associated with the management of Client’s account. These fees may include trading fees, national securities exchange fees, wire transfer fees or other fees required by law. Beacon does not receive performance-based fees for advisory services provided to its clients. Neither Beacon nor any representatives of Beacon receive any additional compensation for the participation of Client’s in the wrap fee program. However, compensation received may be more than what would have been received if Client paid separately for investment advice, brokerage, and/or for other services. Therefore, Beacon may have a financial incentive to recommend the wrap fee program to clients. Item 5: Account Requirements and Types of Clients Beacon’s strategies generally require a $25,000 account minimum. The minimum requirement is negotiable at Beacon 's discretion. Beacon can group certain related Client accounts for the purposes of achieving the minimum account size. Beacon generally provides investment supervisory and investment advisory services to the following types of Clients: Individuals • • High-Net-Worth Individuals • Corporations or Business Entities Item 6: Portfolio Manager Selection and Evaluation Beacon serves as the sole portfolio manager for the wrap fee program and will not select any outside portfolio managers. Page 6 of 11  Beacon Capital Management, Inc. ADV Part 2A – Appendix 1 Beacon will use industry standards to calculate portfolio manager performance, including comparisons against benchmark figures, performance, structure, adherence to Client guidelines, prices, market conditions, portfolio holdings, transactions, and cash flows. Beacon reviews the performance information to determine and verify its accuracy and compliance with presentation standards. The performance information is reviewed daily and is reviewed by Beacon. No related persons of Beacon act as a portfolio manager for the wrap fee program. As such, there are no conflicts of interest with related persons and Beacon will not select any related persons as portfolio managers for this wrap fee program. Beacon offers Investment Supervisory and Investment Advisory Services to its wrap fee program Clients, as detailed in Item 4 of this Appendix. Beacon limits portfolio management to mutual funds, equities, bonds, fixed income, debt securities, ETFs, third party money managers, REITs, insurance products including annuities, and government securities. Beacon may use other securities as well to help diversify a portfolio when applicable. Beacon offers the same suite of services to all of its clients within the same type of advisory service. When applicable, specific client financial plans and their implementation are dependent upon the Client Investment Management Planning Questionnaire which outlines each client’s current situation (income, tax levels, and risk tolerance levels) or the information obtained by Beacon from the client via the Firm, both of which can be used to construct a client specific plan to aid in the selection of a portfolio that matches its restrictions, needs, and targets. Clients can request reasonable restrictions on how their account is allocated, but Beacon may not be able to accommodate all restrictions based on specific mandates of particular strategies. If Beacon cannot accommodate a requested restriction, the client will be notified and given the option to withdraw their request, or the client can work with their Retail Advisor to find an investment solution that meets the Client’s expectations. If Beacon is unable to accommodate a Client’s requested restrictions, the Client will need to find another firm to help meet their financial objectives. Beacon uses technical analysis to understand the historic patterns of the market and create a comprehensive strategies that respond to different market environments. Methods of analysis include measurements such as portfolio drawdown, deviation, macroeconomic updates, security breadth, risk profile, drift, and stress testing. Beacon’s investment processes, including monitoring and maintaining existing strategies, evaluating new investments, and other issues related directly to the types of investments and methods of analysis, are governed by Beacon’s Investment Committee. The Investment Committee is comprised of investment professionals with broad and diverse expertise in portfolio management, trading, and legal/compliance. The Investment Committee is tasked with monitoring the current state of the economy and markets, analyzing and reporting on the performance of Beacon’s proprietary model portfolio strategies, and researching and selecting various investments and investment strategies for Beacon, among other duties. Beacon seeks to deliver consistent returns for the mid to long term investor primarily through a mechanical investment management approach, which seek to minimize severe market volatility. Beacon’s portfolios are based on broad-based diversification. Additionally, certain Beacon strategies Page 7 of 11  Beacon Capital Management, Inc. ADV Part 2A – Appendix 1 utilize a number of data-driven indicators and for some portfolios, pre-determined rules to dictate when to respond to changing markets. Investing involves risk of loss that Clients should be prepared to bear. Many factors affect performance, and past performance does not guarantee futures results. Account values are expected to fluctuate and clients could lose money by investing. There is no assurance that Beacon will achieve the Client’s investment objective, and Beacon’s investment strategy will not necessarily produce the intended results. Beacon will not ask for nor accept voting authority for Client-held securities, except for certain accounts subject to ERISA where the plan documents or our agreement expressly assign proxy voting authority to Beacon. In those limited circumstances, Beacon will vote proxies in accordance with our ERISA proxy voting policies and procedures and solely for purposes of fulfilling our obligations under ERISA. 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. Item 7: Client Information Provided to Portfolio Managers All Client information that is collected, including basic information, risk tolerance, sophistication level, and income level, will be collected by the Client’s Retail Advisor and provided to Beacon. As that information changes and is updated, Beacon is to have immediate access to that information from the Client via information received on behalf of the Client from the Retail Advisor. Once the updated information is collected, Beacon will process and implement appropriate portfolio updates. Item 8: Client Contact with Portfolio Managers Beacon places no restrictions on Client’s ability to contact its portfolio managers. Item 9: Additional Information There are no legal or disciplinary events that are material to a Client’s or prospective Client’s evaluation of Beacon or the integrity of Beacon’s management. Brett Agnew, General Counsel of Beacon, is a registered representative of Sammons Financial Network, LLC, an affiliated broker-dealer. No other management persons of Beacon are registered or have an application to register as a broker-dealer or as a registered representative of a broker-dealer. Beacon maintains relationships with certain of our affiliates or persons under common control and shares central services with Sammons Financial Group, Inc. (“SFG”), including: • Certain senior managers who work within SFG are involved in aspects of Beacon’s business activities but do not exercise control over setting strategy, policy, or investment decision making. All decision making relating to securities selection and portfolio construction and maintenance of Beacon Client accounts is performed by Beacon personnel. Page 8 of 11  Beacon Capital Management, Inc. ADV Part 2A – Appendix 1 • Certain Supervised Persons serve as dual employees, including as senior managers, officers, or directors, for various affiliates (e.g., other SFG companies). • Beacon shares services, resources, and business functions such as operations, information technology, information systems, human resources, business continuity, legal, compliance, finance, operational risk management, and internal audit. Some of these services can have a portion of the processes outsourced to a third-party service provider. Beacon is a direct subsidiary of SFG and is therefore affiliated with various insurance companies through this corporate relationship. Beacon does not act as an investment adviser to any affiliated insurance companies. Beacon receives compensation as the adviser to the Beacon Funds which creates a conflict of interest in situations where a Client can access Beacon’s strategies through the Beacon Funds as well as other channels such as a Wrap Fee Program. The fee structure of the Beacon Funds creates an incentive for Beacon to solicit purchases of the Funds over other strategies. Your financial professional will help you to determine what investment vehicles are appropriate for you given your investment objectives, risk tolerance, financial circumstances, and other criteria. Beacon will not recommend one strategy over another to the Client. Beacon will not purchase shares of our Funds within our offered portfolios for Client accounts in order to remove the conflict of interest where Beacon would receive the advisory fee from our Funds in addition to the advisory fee earned from the Client account which would result in a duplication of fees to the Client. Additionally, certain Related Persons of Beacon have provided seed capital to ETFs which Beacon serves as the investment adviser or a sub-adviser. These Related Persons have an economic interest in the performance or growth of these ETFs. This arrangement creates a potential conflict of interest, as Beacon has an incentive to recommend or retain these ETFs in Client accounts in order to minimize expenses to our related person. Beacon addresses this conflict through our compliance policies, including investment committee oversight, best execution reviews, and regular monitoring of product usage. Beacon does not receive compensation from other investment advisors for recommending or selecting their services for its clients. Beacon maintains a written Code of Ethics (the “Code”) designed to meet the requirements of Rule 204A-1 under the Advisers Act. The Code is intended to ensure that all acts, practices, and courses of business engaged in by the Firm reflect high standards of integrity and comply with the requirements of applicable federal securities laws. All officers, directors, employees, and control persons (“Supervised Persons”) are subject to requirements of the Code. The Code is based on the principle that Supervised Persons owe a fiduciary duty to Clients, including the duties of honesty, good faith, and fair dealing. Supervised Persons have an ethical and legal obligation to avoid material conflict-of-interest situations, disclose potential conflicts and seek clarification when warranted. To that end, Supervised Persons must comply with restrictions and reporting requirements related to the offering or receipt of gifts and entertainment. Supervised Persons must also obtain pre-approval for outside business activities that could conflict with their duties or with Clients. Supervised Persons, along with certain employees of Beacon affiliates who have access to non-public information regarding purchases and sales of Client securities, holdings, or proprietary information Page 9 of 11  Beacon Capital Management, Inc. ADV Part 2A – Appendix 1 about Beacon’s models are deemed to be Access Persons The Code is designed to assure that the personal securities transactions, activities, and interests of Beacon’s Supervised Persons will not interfere with Client accounts or otherwise take unfair advantage of Client relationships. Accordingly, among other things, an Access Person may not: • Profit, or cause others to profit, based on his or her knowledge of completed or contemplated Client transactions; • Engage in fraudulent conduct in connection with the trading of securities in a Client account; or • Personally benefit by causing a Client to act, or fail to act, in making investment decisions. To further mitigate potential conflicts of interest, the Code imposes restrictions on personal securities transactions in which Access Persons have a beneficial interest, including preclearance and holding period requirements for certain reportable securities. Violations of the Code can result in personal sanctions, including termination of employment. Clients can request a copy of the Code of Ethics by contacting Beacon’s Chief Compliance Officer at riacompliance@sfgmembers.com. Beacon does not recommend that clients buy or sell any security in which a related person to Beacon has a material financial interest. From time to time, Beacon, its employees, Supervised Persons and other related persons, will buy or sell securities for themselves that they also recommend to Clients. Such transactions create a conflict of interest as it provides an opportunity to profit prior to or because of a Client’s transaction. Beacon’s policy is that all transactions in Client-held securities by Beacon, its employees, Supervised Persons and other related persons, will be completed simultaneously with, or after, the Client. Beacon’s Supervised Persons are bound by the Firm’s Insider Trading Policy and Code of Ethics. In addition to having their personal securities transactions monitored, pre-clearance of trades in certain securities is required for persons who are in possession of certain material, non-public information. Beacon’s Chief Compliance Officer will maintain a list of restricted securities requiring pre-approval. Client accounts are monitored on an ongoing basis by Beacon. • Portfolio management and trading personnel: review accounts daily for adherence to model • targets, cash levels, drift, restrictions, and trading activity. Investment Committee: reviews strategy level positioning, performance, and risk metrics at least monthly. • Operations: reconciles positions, transactions, and corporate actions daily on open market days. Titles of Beacon’s Supervised Persons that conduct these reviews: Portfolio Strategists / Analysts, Trading Analysts, Operations Specialists, and Investment Committee members. Reviews might include comparisons against benchmark figures, performance, structure, adherence to client guidelines, prices, market conditions, portfolio holdings, transactions, and cash flows. Page 10 of 11  Beacon Capital Management, Inc. ADV Part 2A – Appendix 1 Beacon audits a subset of Client accounts on an ongoing basis for consistency with Client objectives, portfolio guidelines, and restrictions. Client accounts may also be reviewed outside the set cadence under a variety of circumstances, including Client inquiry, atypical market activity, compliance checks, or changes in Client’s financial situation, including retirement, termination of employment, or physical move. Clients engaged in investment supervisory and investment advisory services will receive, at minimum, a quarterly performance evaluation report from Beacon detailing the Client’s account. Each Client will also receive a monthly statement from their custodian detailing their client account. Beacon may receive some economic benefit from its custodians in the form of support products and services it makes available to Beacon and other independent investment advisors that have their client accounts maintained at TD Ameritrade, Schwab or FCC. These products and services, how they benefit Beacon, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices in Beacon’s Form ADV Part 2A). The availability of products and services offered by TD Ameritrade, Schwab or FCC is not based on Beacon providing particular investment advice, such as buying particular securities for clients. Beacon enters arrangements with Retail Advisors that qualify as promoter activities under SEC Rule 206(4)-1 of the Advisers Act (the “SEC Promoter Rule”). Through these arrangements, Beacon agrees to pay a referral fee, which is based upon a percentage of the investment management fee, to Retail Advisors in exchange for them promoting Beacon’s advisory services to Clients. In connection with these arrangements, Beacon will comply with the SEC Promoter Rule. The Retail Advisors describe Beacon’s investment strategies to perspective Clients and provide ongoing resources to referred Clients but do not themselves provide ongoing investment advice. The amount of the referral fee is disclosed to Client via the investment management agreement and Promoter Disclosure Statement. Beacon may pay a portion of the investment management fee to other affiliated or non-affiliated parties who assist with certain administrative tasks associated with the management of the Client account. Retail Advisors, on their own and not related in any way to their agreements with Beacon and not on Beacon’s recommendation, may also sell insurance, annuities, mutual funds, stocks, bonds, and/or limited partnerships to Clients in exchange for separate and typical commissions. Beacon does not require nor solicit prepayment of fees. Beacon does not have any financial conditions that are likely to reasonably impair its ability to meet its contractual commitments to its clients. Beacon has not been the subject of a bankruptcy petition. Page 11 of 11