FORM ADV PART 2A

Part 2A of Form ADV: Brochure Item 1 Cover Chicago Capital Management Advisors, LLC CRD#123483 4722 Main Street Lisle, IL 60532 Additional Supervisory Branch Office: 77 W Washington St. Suite 1801, Chicago, IL 60602 Tel: (630) 241-1122 Fax: (630) 435-9129 Email: ccma@chicagomanagement.net Website: www.chicagomanagement.com This brochure provides information about the Advisory Personnel of Chicago Capital Management Advisors, LLC (“CCMA”). If you have any questions about the contents of this brochure, please contact us at (630) 241-1122 or email us at ccma@chicagomanagement.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 does not imply a certain level of skill or training. Additional information about CCMA also is available on the SEC’s website at www.adviserinfo.sec.gov. Date: 10/14/2026 Approved by: Michael Grady Chicago Capital Management Advisors, LLC 1  Part 2A of Form ADV: Brochure Item 2 Material Changes Since the last annual update amendment dated March 18, 2026 , the following changes have been made. Item 4, Advisory Business, has been updated to describe CCMA’s ongoing advisory services for certain Held- Away Assets that clients previously acquired and continue to own outside their primary managed accounts. Item 5, Fees and Compensation, has been updated to describe how CCMA calculates and deducts advisory fees attributable to Held-Away Assets, including the valuation information used and the related conflict of interest. Item 8, Methods of Analysis, Investment Strategies and Risk of Loss, has been updated to describe CCMA’s review of Held-Away Assets and the material risks associated with those investments. Item 13, Review of Accounts, has been updated to explain how Held-Away Assets accepted for ongoing advisory services are included in CCMA’s account-review process. Item 15, Custody, has been updated to disclose that CCMA is deemed to have custody of certain client assets because of client-established standing letters of authorization. The disclosure also explains why CCMA does not obtain an annual surprise examination in connection with those arrangements. Item 15, Custody, has also been updated to describe the custody treatment of Held-Away Assets and the conditions CCMA will confirm before relying on the custody exception applicable to certain privately offered securities. Chicago Capital Management Advisors, LLC 2  Part 2A of Form ADV: Brochure Item 3 Table of Contents Item 1 Cover ........................................................................................................................................................................................ 1 Item 2 Material Changes ...................................................................................................................................................................... 2 Item 3 Table of Contents ..................................................................................................................................................................... 3 Item 4 Advisory Business .................................................................................................................................................................... 4 Item 5 Fees and Compensation ............................................................................................................................................................ 7 Item 6 Performance-Based Fees and Side-by-Side Management ....................................................................................................... 11 Item 7 Types of Clients ...................................................................................................................................................................... 11 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss................................................................................................ 12 Item 9 Disciplinary Information ........................................................................................................................................................ 14 Item 10 Other Financial Industry Activities and Affiliations ............................................................................................................. 14 Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................................... 15 Item 12 Brokerage Practices .............................................................................................................................................................. 16 Item 13 Review of Accounts.............................................................................................................................................................. 17 Item 14 Client Referrals and Other Compensation ............................................................................................................................ 17 Item 15 Custody................................................................................................................................................................................. 17 Item 16 Investment Discretion ........................................................................................................................................................... 20 Item 17 Voting Client Securities ........................................................................................................................................................ 20 Item 18 Financial Information ........................................................................................................................................................... 21 Item 19 - Social Media Policy ........................................................................................................................................................... 21 Item 20 Business Continuity Plan (BCP) ........................................................................................................................................... 21 Chicago Capital Management Advisors, LLC 3  Part 2A of Form ADV: Brochure Item 4 Advisory Business Chicago Capital Management Advisors, LLC ("CCMA," or "the firm" or "the advisor") is an Illinois limited liability company formed in November 2002 and registered as an investment adviser since January 2003. LCM Holdings, Inc (40%) and Chicago Capital Investment Group, LLC (60%) of CCMA MRGF Family Trust, Mr. Dan O’Halloran and Mr. Kristopher Kessler are the controlling shareholders of Chicago Capital Investment Group, LLC. Mr. Michael Grady and Mr. Dan O’Halloran are the President and CCO of CCMA and the Portfolio Managers. Please refer to Form ADV Part 1 Schedule A and B for more information on the ownership of Chicago Capital Management Advisors. Chicago Capital Management Advisors, Inc. (CCMA) provides investment advisory services in the management of investment portfolios for various clients. CCMA does not typically create financial plans except as incidental to interviewing a client to establish suitability parameters for the portfolio management advice that CCMA supplies. However, it will provide comprehensive financial planning for complex estate, insurance, and tax planning beyond the scope of traditional financial plans. The firm seeks to establish which portfolio strategy it will recommend to its customers through a careful, fact-finding interview and discussions with each client. CCMA bases its recommendations for the specific securities for a client's account on each client's needs. In formulating its recommendations, in engaging CCMA, a client is authorizing CCMA to rely on the accuracy of the information the client provides. CCMA is not required to verify the information that the client provides directly or through any professionals the client uses. CCMA also offers; Comprehensive Financial Planning for complex issue integrating estate, tax planning, businesses disposition planning, and insurance planning: CCMA can charge an hourly fee which is provided upon request only to provide analysis of stock, non-stock, bond financial investments, insurance, estate, and tax planning. The fee will range from $200 an hour to $500 an hour based on the complexity of the analysis. After a thorough review of all pertinent Client provided data and objectives and mutually agreed upon assumptions, the Adviser will analyze the Clients financial situation including, but not limited to: net worth (assets and liabilities), corporate benefits, cash flow strategies (current and projected, retirement planning, risk management, investment portfolio, specific financial needs as determined by the client, and tax and estate planning considerations). Upon completion of the analysis, the Adviser will make recommendations including suggested strategies to achieve Client’s stated objectives. The Adviser will provide Client with a written report of all analysis and recommendations. In the event Client wishes to engage the Adviser to provide additional services Client and Adviser will establish mutually agreed upon terms for the continuation of services. The Client will be required to sign a new Client agreement and additional fees may apply for additional reviews. Financial Planning clients are not required to use CCMA to provide ongoing management of their investment portfolio. If the client acts on certain recommendations, the adviser or an associated person may receive commissions from the sale of insurance, real estate, bonds, and stocks. If the client accepts CCMA's recommendation(s), the client may direct CCMA to place the purchase and/ or sale orders for the client's account. Clients can select between Charles Schwab and Co. (“SCHWAB”), ETC Brokerage Services/Equity Trust (“ETAS”), LaSalle St. Securities/National Financial Services, LLC. ("NFS"), Goldman Sachs/Folio Institutional (“Folio”) or RBC Correspondent Services (“RBC”) to custody accounts. Fees are described in Section 5, Clients may impose reasonable restrictions on the adviser's discretion to invest in certain securities or types of securities if a client provides clear, written directions to that effect. Clients may opt to have their account managed on a not-exclusively discretionary basis and may direct the investment of all or a portion of their account. The client allows the power of discretion to an adviser by means of a limited power of attorney, which the client may revoke at any time. Chicago Capital Management Advisors, LLC 4  Part 2A of Form ADV: Brochure CCMA also utilizes 3rd party managers, Empirical Asset Management, Inc., and Asset Strategies, Inc. for discretionary managed portfolios, which will primarily be using Charles Schwab and Co. (“SCHWAB”) to custody accounts. CCMA also has a referral agreement with Asset Mark, Inc. Services. Sustainable Equity (ESG) Bayesian High Quality Reinforced Value Equity Income All Cap Equity Sector Rotation Asset Allocation: Conservative Moderate Conservative Empirical Asset Management, Inc (“EAM”) EAM is an SEC registered Advisory registered since 2010 1. The Services permit CCMA to retain EAM investment management services in order to obtain discretionary portfolio advisory services for certain of their Clients’ accounts opened and maintained at Charles Schwab or other mutually agreed upon custodians. Available investment models include: • • • • • • • • • • Moderate Moderate Aggressive Aggressive • • • Detail description of each strategy is provided in Empirical’s Schedule 2A Brochure- Please review both CCMA and Empirical Schedule 2A Brochure. Which can be found here for EAM https://adviserinfo.sec.gov/firm/summary/155436 and here CCMA https://adviserinfo.sec.gov/firm/summary/123483 Asset Strategies, Inc. Asset Strategies, Inc. is a wholey owned subsidiary of Chicago Capital Investment Group, LLC (CCIG) that is also the control shareholder of CCMA. The control shareholders of CCIG are all principals of CCMA. Michael Grady, Dan O’Halloran and Kristopher Kessler. Asset Strategies, Inc. is a State Registered Investment Advisory, registered since 1984. Michael Grady is CIO. Asset Strategies, Inc. provides from Customized Moderate Aggressive to Moderate Conservative Portfolio strategies at Charles Schwab with an emphasis on a significant percentage of the portfolio in conservative fixed income investments such as CD, AA or better rated Municipal Bonds, and Treasuries in conjunction with a diverse asset class in equities. Delta Investment Management LLC (“Delta”) Delta Investment Management, LLC (referred to as “they,” or “Delta”), has been registered as an investment advisor since April 2009. The principals and owners are Nicholas Atkeson and Andrew Houghton. Chicago Capital Management Advisors, LLC 5  Part 2A of Form ADV: Brochure Delta provides investment consulting and investment management services to its clients. Delta charges fees based on assets under management (asset-based fees) and does not charge fees separately for investment consulting services. For those clients who request a comprehensive investment plan, Delta will design a plan that meets industry standard practice and may include the use of third-party mutual funds as a way to achieve the financial objectives identified in the plan. With the client’s approval, Delta will implement the financial plan. Within the plan, some portion of the client's funds could be allocated to the one of the following strategies: Delta Tactical Capital Appreciation, Delta Kress Tactical, Delta Tactical Core, Delta Opportunity, Delta Tactical Dividend, Delta Multi-Fund Diversified, Delta Blue Chip Growth, or Delta Equity Income or could be managed by Delta in a custom account. Some portion of our clients maintain only a portion of their total investable assets with Delta Investment Management. Many of these clients with only a portion of their liquid net worth managed by Delta have their funds in the Delta Kress Tactical, Delta Tactical Capital Appreciation, Delta Tactical Dividend, Delta Multi- Fund Diversified, Delta Opportunity, Delta Blue Chip Growth, Delta Equity Income, and/or Core strategies. AssetMark, Inc. CCMA Provides referral services for AssetMark. AssetMark pays CCMA a referral fee, after expenses, as a percentage of the fees they collect from referred client. AssetMark and AssetMark Trust Company (“AssetMark Trust”) are wholly-owned Indirect subsidiaries of Huatai Securities, Co., Ltd. (“HTSC”). HTSC is a financial services and securities brokerage firm, Incorporated in China and listed on the Shanghai and Hong Kong stock exchanges. AssetMark is the sponsor of the AssetMark Platform (the “Platform”) through which it offers its advisory services to its clients. AssetMark is an investment adviser registered with the U.S. Securities and Exchange Commission providing various investment supervisory services to a variety of clients. The investment divisions of AssetMark, are known as Aris (“Aris”) and Savos Investments (“Savos”). AssetMark serves as the Portfolio Strategist and Investment Manager for the Guided Portfolios, which includes the GPS Fund Strategies and GPS Select. GPS Fund Strategies shall invest in predetermined allocations of the GuidePath Funds. GPS Select will invest in pre-determined allocations to various Investment Approaches as well as additional investment options within each Investment Approach, and will make allocations to various Portfolio Strategists and Investment Managers. Description of advisory services AssetMark offers these various Platform options (“Solution Types”) for the client’s investment objectives and financial condition. Each of the Solution Types can be implemented with a number of options, such as a selection of an Investment Approach, a group of available “Portfolio Strategists,” a variety of account “Mandates” and a range of “Risk/Return Profiles,” so that the client can customize a strategy by which each of the client’s accounts under the Platform will be managed or maintained. The specific Solution Type and the components of the strategy selected for a client’s account as the culmination of this process are referred to as the client’s investment “Strategy.” A client may establish one or more investment accounts (each an “Account”) through the Platform, and the client’s Accounts are collectively referred to as the client’s “Portfolio.” AssetMark offers the following advisory services or Solution Types to Clients: I. GPS Fund Strategies GPS Select Custom GPS Select Guided Portfolios a. b. c. Chicago Capital Management Advisors, LLC 6  Part 2A of Form ADV: Brochure Multiple Strategy Accounts II. AssetMark provides investment supervisory services to clients through the Platform, as well as providing advisor consulting and administrative services to third party independent investment advisors with clients investing through the Platform. An Administrative/NonManaged Account can also be provided as an administrative convenience for the Client. Assets in an Administrative/Non-Managed Account are not managed or advised by AssetMark, and AssetMark is not responsible for their investment or management. AssetMark manages each client Account according to the client’s selected Solution Types under the terms of the AssetMark Investment Management Services Agreement (“IMSA”). AssetMark had 160 billion in platform assets under management as of December 31, 2025. This includes assets held in proprietary mutual funds. Other services – Advisor model platform In addition to the investment supervisory services offered clients directly by AssetMark upon referral by Financial Advisory Firms, the Platform Solution Types are offered by Financial Advisory Firms serving as the investment advisor for their clients with accounts invested through the Platform. For these Financial Advisory Firms and their clients, AssetMark serves as the Platform sponsor and provides the Financial Advisory Firms with administrative and consulting services. Please be assured that before making such a decision and selecting other advisers, we will be sure advisers are properly licensed and registered as an investment adviser. Third-party managers/advisers will not be added to a customer’s account without prior signature of approval from the customer. Other services – Held-Away Assets CCMA provides ongoing advisory services with respect to certain assets maintained outside clients’ primary managed accounts, including mutual fund shares held directly with a mutual fund company, assets in former-employer retirement plans that permit independent advisory management, inherited individual retirement accounts, legacy annuity and variable insurance contracts, and certain private alternative investments previously acquired by clients through private offerings (collectively, “Held-Away Assets”). The custodian, issuer, insurance company, plan provider, transfer agent, or other applicable recordkeeper maintains the official ownership and account records for each Held-Away Asset. CCMA does not offer or facilitate new purchases of Held-Away Assets. Its services are limited to Held-Away Assets already owned by clients and accepted by CCMA for ongoing advisory services. Before accepting a Held-Away Asset for ongoing advisory services, CCMA reviews available information appropriate to the asset, including account or ownership records, contract or offering documents, transfer or liquidity restrictions, valuation information, and statements or reports from the applicable custodian, issuer, insurance company, plan provider, transfer agent, sponsor, or other recordkeeper. For each Held-Away Asset accepted for ongoing advisory services, CCMA records the asset in its portfolio-management or reporting system and obtains and retains available information from the applicable custodian, issuer, insurance company, plan provider, sponsor, trustee, transfer agent, property manager, or other appropriate source. CCMA maintains the related records in accordance with its books and records procedures. The liquidity, transferability, and transaction requirements applicable to Held-Away Assets vary by asset type. Certain assets are subject to surrender charges, plan or contract restrictions, issuer consent requirements, limited secondary markets, or Chicago Capital Management Advisors, LLC 7  Part 2A of Form ADV: Brochure other limitations. CCMA’s authority is limited to the authority granted by the client in writing and permitted by the applicable custodian, issuer, insurance company, plan provider, or other recordkeeper. The client remains responsible for providing any required authorization, authentication, consent, or signature. CCMA includes a Held Away Asset interest in its regulatory assets under management only when CCMA provides continuous and regular supervisory or management services with respect to the interest. CCMA does not participate in wrap-fee programs. As of 12/31/2025 CCMA’s assets under management had approximately USD $135,217,00 in discretionary assets. Item 5 Fees and Compensation Fees are fully transparent of all costs associated, including CCMA as the manager, the Advisor Representative and Infrastructure. Fees are calculated based on total assets per household. Customers will receive advance billing notice either on statement or in an invoice and the fee will be deducted from the account monthly up to through National Financial and Folio in arrears, quarterly in arrears at RBC Clearing, Schwab, Delta and Equity Trust Advisor Solutions and quarterly in advance at AssetMark and Empirical Asset Management according to the following schedule. Clients will incur brokerage and other transaction costs, please see the section below of this brochure for detailed information which discusses these costs. No performance fee is charged. Fee rate may be negotiated but it will be fixed once contract is signed until revised by both parties. Equity and Asset Allocation Accounts $100,000-249,999 $250,000-499,999 $500,000-999,999 2.25% Maximum Fee 2.00% Maximum Fee 1.75% Maximum Fee $1,000,000-2,499,999 $2,500,000-4,999,999 $5,000,000 Plus 1.50% Maximum Fee 1.25% Maximum Fee 1.00% Maximum Fee Fixed Income Accounts Minimum $100,000-249,999 $250,000-999,999 $1,000,000-4,999,999 $5,000,000 plus 1.25% Maximum Fee 1.00% Maximum Fee 0.75% Maximum Fee 0.50% Maximum Fee Clients will be given the opportunity to choose from multiple clearing firms: • National Financial Services, LLC (“NFSC”) through executing broker LaSalle St. Securities, LLC charges a $7.00 per transaction charge in addition to the fees above. • RBC Clearing (“RBC”) through executing broker-dealer American Investment Services, Inc. charges a $15.00 per transaction charge in addition to the fees above. • Charles Schwab (“SCHWAB”) Charles Schwab (SCHWAB) through its executing broker dealer Charles Schwab & Co. does not charge any fees on electronic trades for listed and NMS equities, $6.95 on Non-NMS OTC electronic trades, $0.65 per option contract on electronic trades, $1.00 per bond ($10 min-$250 max) for online pricing and $45.00 for electronic non-Schwab Mutual Fund trades. Chicago Capital Management Advisors, LLC 8  Part 2A of Form ADV: Brochure • Folio Institutional (“FOLIO”) through its executing broker dealer Folio Investments does not charge any fees on transactions for trades during the window trade period but does charge $3.95 per transaction for trades outside of the window trade period. Accounts are also charged a $7.95 administration fee per month. • ETC Brokerage Services/Equity Trust (“ETAS”) Equity Trust Advisor Solutions charges additional transaction fees will apply as follows and will be paid by the client in addition to the fees above through Equity Advisor Solutions broker-dealer. Equity Securities / Exchange -Traded Funds $6.95 per transaction. Mutual Funds $20 per transaction. Options $18 per transaction plus $1.00 per contract. Fixed Income Investments – Bonds, Mortgage-Backed Securities, OTC Corporate Bonds, Government Securities, Collateralized Mortgage Obligations, Money Market Instruments/CDs, Municipal Bonds, Unit Investment Trusts, and Zero-Coupon Bonds $35 per transaction. An additional miscellaneous/mail charge of $3.50 will be charged on each transaction. Find clearing firms complete fee schedules at: https://www.chicagomanagement.com/fee-schedule Lower fees for comparable services may be available from other sources. The combination of fees for CCMA and transaction fees combined will not exceed the Cap of 2.5%. Example of common fees from the Clearing firms: NFSC RBC Folio Schwab IRA Annual fee $ 45.00 $ 50.00 $ 25.00 - IRA Closing Fee $ 125.00 $ 120.00 $ 100.00 $75 Check/Debit Card fee $ 50.00 $ 100.00 $ 7.50* $0 $25 Wire fee $ 15.00 $ 20.00 $ 30.00 Paper Statements $ - $ - $ 12.50* - ACAT/Transfer out fee $ 75.00 $ 75.00 $ 100.00 $50 * Folio does not have a Debit card option- $7.50 for first $25 checks NFSC and RBC fee inclusive of first 25 checks ** Monthly paper statement fee or $12.50 for Folio and Quarterly fee of $7.50 for EAS The affiliated broker-dealer American Trust Investment services, Inc. may retain a concession from fixed price offerings such as "private placements" or " public offerings" where no price improvement or discount is possible. If so, those positions will be taken off the fee engine, and no ongoing monthly fees will be charged. There are additional mutual fund expenses built into the funds. Fee schedules for any fund in an account will be provided upon request. No compensation is accepted for the sale of securities or other investment products. We use third parties and third-party software to calculate the management fees. Upon termination notice, NFSC, FOLIO, Chicago Capital Management Advisors, LLC 9  Part 2A of Form ADV: Brochure RBC, SCHWAB, DELTA ETAS and are paid in arrears and fees are calculated through date of termination. E NA a n d ASSETMARK is paid in advance and fees are calculated through date of termination of previous quarter. Termination and Proration If an account is terminated between payment cycles the fees will be prorated to the date of termination and charged or in the case of EAM or ASSETMARK the fees will be credited to the date of distribution. Third-Party Advisers Compensation primarily using Schwab as Custodian: Delta Investment Management LLC Fees & Compensation Investment management services are provided for an asset-based fee ranging from 1.00% to 1.85%, based on the value of the assets being managed. The negotiated fee takes into account use of third-party strategy provider(s), the scope and complexity of the services provided, account size, and account history with Delta including duration and services provided. The annual fee on all accounts are billed quarterly, in advance, based on the account’s net asset value on the last day of the previous billing cycle, as reflected in the ELECTRONIC DATA transmitted to us by the custodian of the account. In the event the Delta Advisor Agreement is executed, and the account funded at any time other than the first day of a calendar quarter, the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. “Net asset value” = long market value – short market value + credit balance – debit balance + money market fund balance. Fees cover Delta’s investment advisory, reporting, and account-related services. Fees do not cover any execution-related expenses, commissions, if any, securities exchange fees, or other fees required by law or charged by the broker-dealer with custody of the account. Clients are responsible for commissions, fees, and other charges, if any, associated with such transactions and the maintenance of their account(s). Fees are negotiable in limited circumstances. mutual fund loads (if applicable). These charges are paid to brokers as a form of commission. management fees for ETFs and mutual funds. These are fees charged by the managers of the ETF or mutual fund brokerage costs and transaction fees for any securities or fixed-income trades. These are generally charged by your In addition to the advisory fee shown above, you are responsible for paying fees associated with investing for your account. This pertains to all accounts except those participating in the wrap program. These fees include: • • and are a portion of the expenses of the ETF or mutual fund. • custodian and/or executing broker. Asset Strategies, Inc. Fees and Compensation Assets Strategies’ fees are billed quarterly in arrears, with fees ranging from .25% for larger shorter term fixed-income accounts to 1.25% for asset-allocated accounts with a higher percentage of equities. Fees cover Asset Strategies’ investment advisory, reporting, and account-related services. Fees do not cover any execution- related expenses, commissions, if any, securities exchange fees, or other fees required by law or charged by the broker-dealer with custody of the account. Clients are responsible for commissions, fees, and other charges, if any, associated with such transactions and the maintenance of their account(s). Fees are negotiable in limited circumstances. In addition to the advisory fee shown above, you are responsible for paying fees associated with investing for your account. Chicago Capital Management Advisors, LLC 10  Part 2A of Form ADV: Brochure Empirical Asset Management Fees and Compensation Fees for Advisory Services Investment Management Services Investment management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the investment management agreement. Investment management fees are based on the market value of assets under management at the end of the prior calendar quarter. Investment management fees range from 0.20% to 2.00% annually based on several factors, including: the complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the Advisor. The investment management fee in the first quarter of service is prorated from the inception date of the account[s] to the end of the first quarter. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take into consideration the aggregate assets under management with the Advisor. All securities held in accounts managed by EAM will be independently valued by the Custodian. EAM will conduct periodic reviews of the Custodian’s valuations. Use of Independent Managers – As noted in Item 4, the Advisor may implement all or a portion of a Client’s investment portfolio utilizing one or more Independent Managers. To eliminate any conflict of interest, the Advisor does not earn any compensation from an Independent Manager. The Advisor will only earn its investment advisory fee as described above. Independent Managers typically do not offer any fee discounts but may have a breakpoint schedule which will reduce the fee with an increased level of assets placed under management with an Independent Manager. The terms of such fee arrangements are included in the Independent Manager’s disclosure brochure and applicable contract[s] with the Independent Manager. The total blended fee, including the Advisor’s fee and the Independent Manager’s fee, will not exceed 2.50% annually. Fee Billing Investment Management Services Investment management fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s] at the Custodian. The Advisor or its delegate shall send an invoice to the Custodian indicating the amount of the fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due is calculated by applying the quarterly rate (annual rate divided by 365 multiplied by the number days in the billing period) to the total assets under management with EAM at the end of the prior quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written authorization permitting advisory fees to be deducted by EAM directly from their account[s] held by the Custodian as part of the investment advisory agreement and separate account forms provided by the Custodian. Use of Independent Managers – For Client accounts implemented through an Independent Manager, the Client’s overall fees will include EAM’s investment advisory fee (as noted above) plus investment management fees and/or platform fees charged by the Independent Manager. The Independent Manager will assume the responsibility for calculating the Client’s fees and deducting all fees from the Client’s account[s]. Other Fees or Expenses Clients may incur certain fees or charges imposed by third parties, other than EAM, in connection with investments made on behalf of the Client’s account[s]. For Clients not in the EAM Wrap Fee Program, Clients are responsible for all custody and securities execution fees charged by the Custodian. The Advisor's recommended Custodian does not charge securities Chicago Capital Management Advisors, LLC 11  Part 2A of Form ADV: Brochure transaction fees for ETF and equity trades in a Client's account, provided that the account meets the terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for mutual funds and other types of investments. Additionally, for Clients of the Advisor that custody with Fidelity, Fidelity charges an annual account fee of up to $90 per account. In addition, all fees paid to EAM for investment advisory services are separate and distinct from the expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A Client may be able to invest in these products directly, without the services of EAM, but would not receive the services provided by EAM which are designed, among other things, to assist the Client in determining which products or services are most appropriate for each Client’s financial situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees charged by EAM to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information Held Away Assets When CCMA accepts a Held-Away Asset for ongoing fee-based advisory services, CCMA charges an asset-based advisory fee in accordance with the client’s written investment advisory agreement. The agreement specifies the applicable fee rate and billing frequency. CCMA does not charge a fee on a Held-Away Asset until the applicable agreement is effective and CCMA has begun providing the agreed-upon services. The client’s investment advisory agreement specifies whether the value of a Held-Away Asset is combined with the client’s other household assets when determining the applicable fee rate or breakpoint or whether the fee attributable to the Held- Away Asset is calculated separately. Certain Held-Away Assets may not have readily available market quotations. CCMA calculates the fee attributable to a Held- Away Asset using the most recent value available as of the applicable billing date from the custodian, issuer, insurance company, plan provider, sponsor, trustee, transfer agent, property manager, independent valuation provider, or another source CCMA reasonably believes to be reliable. If an updated value is unavailable, CCMA may use the most recently reported value after considering whether that value remains reasonable. Values may be estimates, may be based on information that is not current, and may not represent the amount the client would receive upon a sale, transfer, redemption, liquidation, surrender, or other disposition. CCMA does not guarantee the accuracy, completeness, or timeliness of information supplied by another party. CCMA’s advisory fee increases as the reported value of a Held-Away Asset increases. This creates a conflict of interest when CCMA selects or uses a value to calculate its fee. CCMA addresses this conflict by applying its valuation procedures consistently, using available third-party information, documenting the source and date of the value used, and reviewing material valuation changes and values that have not been updated. Deduction From Another Custodial Account Fees attributable to Held-Away Assets are invoiced directly to the client or deducted from another account owned by the client and maintained with a qualified custodian, as specified in the client’s written investment advisory agreement. When fees are deducted from another custodial account, CCMA obtains the client’s written authorization and provides the client with documentation showing the value used, applicable fee rate, calculation, and amount of the fee in accordance with the advance billing-notice procedures described in this Item. CCMA provides the qualified custodian with the information necessary to process the authorized deduction. CCMA does not deduct advisory fees directly from the Held-Away Asset or from assets held by the issuer, sponsor, trustee, transfer agent, property manager, or another party associated with the asset. Chicago Capital Management Advisors, LLC 12  Part 2A of Form ADV: Brochure Item 6 Performance-Based Fees and Side-by-Side Management CCMA does not charge performance-based fees. Item 7 Types of Clients Types of clients at CCMA include; individuals (including high net worth individuals), corporations, trusts and profit-sharing plans, and individual retirement plans. We do not provide pension services to plan sponsors. The minimum account size at CCMA is $50,000 for opening an equity account or asset allocation and $100,000 for opening a fixed-income account. CCMA may take on lesser dollar amounts at the discretion of the company. Equity accounts are accounts diverse in industry, market capital, country, and equity type that are often rebalanced to balance the risk within the equity markets. Asset Allocation accounts is a strategy that mixes a wide variety of investments within a portfolio in an attempt to reduce portfolio risk. Item 8 Methods of Analysis, Investment Strategies and Risk of Loss CCMA uses a "bottoms-up" approach, which is a fundamental screening of companies for positive attributes it feels are needed in today's market. Once CCMA has its "list" of the companies, CCMA balances the portfolios to the risk tolerance profile of each client. From conservative to the most aggressive, accounts are built individually with the client's goals and risk tolerance in mind. CCMA doesn't use strategies involving frequent trading. Equity Portfolio Styles Aggressive Growth Portfolio- Higher Degree- Risk Similar to the of S&P 500 and the Russell 2000. A focus on stocks with minimal to no dividends that reinvest profits, if any, to increase the growth of the business. These stocks will offer above average risk/return ratios. Stocks in general offer a significantly greater risk of principal with the broad market falling over 40% from 2000-2002 and over 50% from 2007-2009. The individual investments in the aggressive growth model offer an even greater risk from the broad market. We acquire investments through evaluation of Market focus (what is happening in market and economy that could increase returns in certain sectors- As an Example: increasing investments in cloud-based companies where the increased use of the Internet will benefit the companies’ business in the event of a Pandemic). We also us a bottoms-up fundamentals approach of looking at the financial fundamentals of the company to determine whether they have the resources to achieve the companies’ aggressive growth goals. We also will do technical analysis to evaluate the momentum dynamics of the individual investments. The market capital will vary but we will be focused on companies that re-invest most of their cash flow or available cash into the growth of the business. We also frequently use higher Beta (Beta=Volatility) ETF’s. An Exchange Traded Fund (“ETF”) can be very industry, sector, or type of investment focused and therefore can have similar increased risks of individual stocks even though they have the diversification of a fund. A prospectus on each ETF is available upon request. While most ETF’s trade near their Net Asset Values (“NAV”) they can often trade above or below their NAV. We at times may use options. Options are time sensitive investments with great risk of expiring worthless. Sector Rotation Portfolio-Higher Degree of Risk and Volatility Similar to the Volatility of the NASDAQ The portfolio seeks to invest in different sectors to capture the trends of each sector not detected by the market. The sectors that have the highest potential to appreciate are chosen and a representative basket of stocks, closed end funds, or an Exchange Traded Fund for that sector is purchased. Because such sectors are in a different business cycle from other sectors or the market itself, CCMA plans to benefit by taking advantage of the divergent business cycles. Chicago Capital Management Advisors, LLC 13  Part 2A of Form ADV: Brochure Dividend / Growth Portfolio- Moderate-Aggressive Risk Profile, a little less volatile than the Dow Jones Industrial Average A portfolio of dividend and income paying investments with a goal of generating a yield above that of the S&P 500 while maintaining a goal of long term capital appreciation. Investments will include, bonds, CD's, preferred stocks, common stocks, and closed end funds and ETF's. Portfolios will be customized to each clients’ Dividend/Growth requirements and growth/risk expectations. Income / Dividend Portfolio-Moderate Risk Profile A portfolio of income and dividend paying investments with a goal of generating a yield above that of a laddered bond portfolio of1-10 year treasuries, while having the potential for providing long term capital appreciation. Investment may include bonds, CD's, preferred stocks, common stocks, and closed end funds and ETF's. Portfolios will be customized based on each client's income requirements and growth/risk expectations to reduce broad based portfolio risk. Hedges can be placed on the investments including options, various ETF's/mutual funds and stops. The cost of hedging should reduce returns in good markets, but should provide for limiting downside in bad markets. Options can be used to lock in the profits or protect downside without pulling out from it totally, as well as providing income at times. Moderate Conservative Moderate Moderate Aggressive Aggressive Asset Allocation Portfolios A portfolio of equity and fixed income positions tailored to meet the Client's specific risk profile. Portfolios will be balanced to the clients' current level of risk tolerance to allow the clients to have investments working toward their goals for return within the risk volatility with which they are comfortable. The weighting of the portfolio, from Aggressive to Conservative, will depend on the current income requirement versus the growth rate needed for the future. • • • • Fixed Income Portfolio Clients with more need for current income than growth require a structured portfolio composed of a "ladder" of income vehicles weighted, again, by the risk tolerance of the client. From Government Bonds, ETF's, closed end funds, mutual funds and Corporate Junk Bonds, the yield and risks are weighed, and a "ladder" of cascading maturities is put in place to give the client the income and liquidity they require. Custom Portfolio This refers to accounts that transition over to CCMA without immediate change into our existing models. This can also refer to various clients who may have individual management that is outside of our existing models. Cybersecurity. The technology systems of the Firm and its respective service providers may be vulnerable to inadvertent or deliberate interruption and consequent damage from technical or human sources. In addition to natural catastrophes, service/power outages, and network or telecommunications failures, security breaches and intrusion by unauthorized persons could result in damage, disruption, and theft of data, including investor information. The Firm has implemented cybersecurity procedures meant to address these risks. Nevertheless, given Firm’s fundamental dependence on technology, a cyber-attack or similar technology disruption could have a material adverse impact on Clients. Additionally, there are inherent limitations in cybersecurity policies and procedures and controls including the possibility that certain risks have not been identified. firm has conducted limited due diligence and risk assessments of third-party providers. However, the Firm is not able to control the cybersecurity plans, breach notifications, incident response plans and controls put in place by other services providers and/or the issuers in which the client invest. It is in the client’s best interest to monitor all of his or her accounts on a regular basis and stay informed of cybersecurity best practices. Cash Sweep Interest Risk: We utilize various custodians to hold client assets, each offering different options for managing uninvested cash balances. Some custodians provide insured deposit accounts, which may offer lower interest rates compared to other available money market options. In certain cases, the firm facilitates transactions to move client cash into higher- Chicago Capital Management Advisors, LLC 14  Part 2A of Form ADV: Brochure paying money market funds; however, these transfers do not occur daily and may result in delays when allocating funds for investment. Other custodians automatically sweep uninvested cash into money market funds, which may offer higher yields, yet clients should be aware that even higher interest rates may be available through accounts outside the custodians used by the firm. Transferring funds to external accounts, however, could limit the firm’s ability to respond quickly to market events or invest efficiently in opportunities that could potentially enhance portfolio performance. The firm strives to manage uninvested cash in a way that balances liquidity, interest income, and the ability to execute timely investment decisions. Clients are encouraged to discuss any preferences or concerns regarding cash management with their adviser. Held Away Assets Held-Away Assets involve risks that vary by asset type. These risks may include loss of principal; market, credit, liquidity, concentration, and valuation risks; surrender charges; plan, contract, or transfer restrictions; the absence of an established secondary market; dependence on an issuer, sponsor, insurance company, plan provider, property manager, or other service provider; limited or delayed information; changes or interruptions in distributions or benefits; and tax consequences. Privately offered real estate investments may also involve tenant, geographic, property, leverage, and refinancing risks. CCMA cannot assure that current valuation information will be available or that a client will be able to sell, transfer, surrender, redeem, or otherwise dispose of a Held-Away Asset when desired. Investing in securities involves risk of loss that clients should be prepared to bear Item 9 Disciplinary Information CCMA has no material information responsive to item 9. A. Neither CCMA nor its management personnel have been convicted or involved in a criminal or civil action in a domestic, foreign, or military court of competent jurisdiction. B. CCMA has not been found in violation, or involved in an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency, or any foreign financial regulatory authority. One of the managers has, without admitting or denying the findings, Mr. Kessler consented to sanctions and entry of findings that he engaged in an OBA without prior written consent of the firm. C. Neither CCMA nor its management personnel has been found in violation or involved in a self-regulatory organization (SRO) proceeding. Item 10 Other Financial Industry Activities and Affiliations Mr. Daniel O'Halloran, Mr. James Clarren, Mr. David Levinson, Mr. Justin Smith, Mr. Kristopher Kessler, Mr. Earl Stevenson, Mr. Michael DiPrimio, Chase Heiden, Robert McIsaac, and Mr. Wendell Franklin are registered as representative of American Trust Investment Services, Inc. (“ATIS”), a registered broker-dealer. CCMA is affiliated with American Trust Investment Services, Inc. through common ownership and management control but operates separately as a completely separate business. Chicago Capital Management Advisors, LLC 15  Part 2A of Form ADV: Brochure Mr. Michael Grady, Mr. Daniel O’Halloran, , Mr. Kristopher Kessler, se and Mr. Wendell Franklin are also registered with American Trust Investment Services Advisory, Inc (“ATISA”), a state registered investment advisory. ATISA provides similar portfolio strategies as CCMA but on a non-discretionary basis. Fees at the custodians are the same for CCMA customers as they are for ATISA customers. Mr. Michael Grady, Mr. Daniel O’Halloran, Ben Pfiffner, and Mr. Kristopher Kessler are also registered with Asset Strategies, Inc. (“ASI”), a state registered investment advisory. ASI provides similar portfolio strategies to clients on a discretionary basis. Fees and expenses at the custodian are the same for CCMA customers as they are for ASI customers. Mr. Michael Grady, Mr. Daniel O'Halloran, Mr. James Clarren, Mr. David Levinson, Mr. Scott Barringer, Mr. Kristopher Kessler, Mr. Levant Bishop, Mr. Earl Stevenson, James Liberman, Ben Pfiffner and Mr. Wendell Franklin, are also insurance licensed and do provide life and annuities through the broker-dealer American Trust Investment Services, Inc. (“ATIS”) and in some cases, fixed life and annuities through American Trust Insurance Group, Inc. (“ATIG”). Conflicts of Interest Advisor Representatives of CCMA also registered with ATIS, ASST and ATIG may have potential conflicts in recommendations of non-advisory products that may not be investments that would be part of a portfolio established and managed by CCMA. A. CCMA and its management personnel are not registered, nor do they have an application pending to register, as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of the foregoing entities. B. Potential Conflicts of Interest; If in the event a customer decides to do a transaction through the affiliated broker- dealer (“ATIS”) or (“ATIG”) but does not want to establish another brokerage account to do so, the transaction may be done through the same account where the managed assets are held and executed through the affiliated broker- dealer. That investment will be excluded from the fee engine and no monthly or quarterly asset fees will be charged. CCMA will not evaluate that investment on behalf of the investor, it will be the responsibility of either ATIS or ATIG. C. CCMA can refer clients to third-party advisers like AssetMark, Inc. or Delta Investment Management LLC. Please be assured that before making such a decision and selecting other advisers, we will be sure advisers are properly licensed and registered as an investment adviser. Third-party managers/advisers will not be added to a customer’s account without prior signature of approval from the customer. D. Mr. Michael Grady as President, Mr. Kristopher Kessler as the Vice president, Mr. Daniel O'Halloran as Manager, are also registered with Asset Strategies, INC, (“ASI”). E. Mr. Michael Grady as CFO, Mr. Kristopher Kessler as the Vice president, Mr. Daniel O'Halloran as President, are also registered with American Trust Investment Services Advisory, Inc (“ATISA”). Item 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading CCMA places the highest priority on maintaining its reputation for integrity and professionalism. CCMA has adopted its Code of Ethics ("Code") to ensure that the high ethical standards long maintained by CCMA continue to be applied. A copy of the Code will be provided to the clients upon request. The purpose of the Code is to preclude activities which may lead to or give the appearance of conflicts of interest, insider trading and other forms of prohibited or unethical business conduct. Chicago Capital Management Advisors, LLC 16  Part 2A of Form ADV: Brochure CCMA and its employees are subject to the following specific fiduciary obligations when dealing with clients: • The duty to have a reasonable. Independent basis for the investment advice provided; • The duty to obtain best execution for a client's transactions if CCMA is in a position to direct brokerage transactions for the client; • The duty to ensure that investment advice is suitable to meeting the client's individual objectives, needs and circumstances; • The duty to be loyal to clients; • The duty to report financial, family and other changes to client's goal and plans to CCMA management in a timely manner. Participation or Interest in Client Transaction: CCMA does have employees that are registered broker-dealer representatives and will seek authorizations from the clients for the discretion to trade with the broker-dealer deemed most appropriate. In some cases, clients of CCMA may liquidate positions for financial reasons or non-CCMA clients may require the liquidation of bond positions that would be appropriate for CCMA clients. In those cases, Michael Grady also manages his personal and his wife's accounts through CCMA within similar equity and fixed income portfolio structures, he will be purchasing many of the same securities as the other separately managed accounts. CCMA has an internal policy restricting the managing advisors from receiving short term benefits from short term price movements of securities caused by the activity of the separately managed accounts. Below is an abstract of CCMA's Internal Management policy regarding Short Swing Rule: The managing advisors will not purchase a security in order to benefit from the price impact* of the multiple individually managed accounts purchasing or selling one security. Any short swing profits will be contributed to the separately managed accounts in proportion to the assets in the account. *Price impact is defined as a movement of a stock of more than $0.25 caused by the demand/supply impact of the multiple accounts buying or selling a security. Personal Trading: Advisory Representatives must disclose personal securities accounts and report at least quarterly any reportable transactions in their personal accounts. Dan O’Halloran is designated to review all personal investment activity for employee's personal accounts; Employees must report to Michael Grady or Daniel O'Halloran all business, financial or personal relationships that may result in access to material, non-public information. CCMA has utilized average pricing in which, if either of the Managers Principals purchases or sells the same stock as any customers on the same day, at a price better than any customers, we will average price all the purchases that day so that the customers and the Manager will have the same price. CCMA permits its employees to engage in personal securities transactions, including transactions that may be contrary to the recommendations provided to clients. CCMA does not believe these activities present a conflict of interest or have a material impact on client accounts, as employees are required to adhere to our Code of Ethics, which includes policies designed to ensure that client interests are placed first and to monitor for potential conflicts. Copy of the Code of Ethics will be provided to any client or prospective client upon request. Chicago Capital Management Advisors, LLC 17  Part 2A of Form ADV: Brochure Item 12 Brokerage Practices Unless the client designates otherwise, CCMA currently recommends that investment accounts be maintained at National Financial Services. ("NFS"), RBC Correspondent Services ("RBC") , Goldman Sachs/Folio Institutional ("Folio"), Charles Schwab & Co (“SCHWAB”) or ETC Brokerage Servies (“ETAS”) . The broker dealer and certain CCMA's principals are affiliated with also uses NFS, RBC, Goldman Sachs/Folio, and ETAS as custodians. (Accounts held in custody at RBC will be executed through an affiliate of CCMA, American Trust Investment Services, Inc (“ATIS”) and ATIS may make a profit over clearing costs on each transaction). CCMA does not take or receive physical possession of the assets under management. Factors that CCMA considers in recommending NFS, RBC, Folio, and ETAS (or any other custodian) to clients include NFS’, RBC’s, Folio's and ETAS’ financial strength, reputation, execution, pricing, research, and services. NFS and RBC enables CCMA to obtain many no- load mutual funds without transaction charges and other no-load and load waived funds at nominal transaction charges. NFS, RBC, Folio, and ETAS charge transaction fees that are generally considered discounted from customary retail commission rates but may be greater than other clearing firms. CCMA may receive certain investment research products, allocation tools, financial planning tools assistance and/or services which assist CCMA in its investment decision-making and allocation process for the client, all of which transactions shall be in compliance with Section 28(e) of the Securities Exchange Act of 1934 in seeking best execution. The determinative factor is not the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into consideration the full range of a broker-dealer services, including the value of research provided, execution capability, allocation assistance, planning tools, income analysis tools, breath of product, and ease and familiarity of online access for the customer. CCMA may block trades where possible and when advantageous to clients. This blocking of trades permits the trading of aggregate blocks of securities composed of assets from multiple clients’ accounts so long as transaction costs are shared equally and on a pro-rated basis between all accounts included in any such block. Block trading allows CCMA to execute equity trades in a more timely and equitable manner. Our firm does not engage in soft dollar arrangements. This means we do not receive research or other brokerage-related services from broker-dealers in exchange for directing client transactions to them, and client commissions are not used to pay for soft dollar research. All client transactions are executed through broker-dealers based on factors such as the broker's ability to provide best execution, competitive commission rates, and the quality of services provided. Although we do not have soft dollar arrangements, because we request that client assets be held with certain custodian/broker-dealers, we may receive benefits that are not typically available to retail investors. These benefits may include access to trading platforms, reporting tools, educational resources, and other products or services that assist us in managing client accounts. We do not believe these benefits create a material conflict of interest, as they are designed to support our ability to provide services to clients, and we do not receive any direct compensation for recommending a particular custodian. We recommend broker-dealers and custodians based on several factors, including the quality of services provided to both the client and the firm. These factors may include the custodian’s online access tools and ease of use for clients, portfolio reporting and review capabilities, trading support for specific products, and the overall ability to help us manage and allocate client accounts in line with their investment objectives. Lower fees for comparable services may be available from other sources. Chicago Capital Management Advisors, LLC 18  Part 2A of Form ADV: Brochure Item 13 Review of Accounts Mr. Michael Grady (President and Chief Investment Officer), and Mr. Daniel O'Halloran (Chief Compliance Officer) review the performance of all accounts on a monthly basis. If the asset value of the portfolio changes more than 5% compared to its prior closing value, Mr. Grady and Mr. O'Halloran would review the account immediately. Monthly or quarterly statements will be provided from the clients’ custodians, reflecting all transactions, holdings, and account values. Clients are encouraged to review these statements carefully and contact us with any questions. These custodial statements should be considered the official record of the account and may differ from any reports provided by our firm or other third parties due to factors such as pricing methodologies, trade settlement timing, or data reconciliation processes. Held Away Assets accepted for ongoing advisory services are included in CCMA’s account-review process. CCMA conducts and documents a Held Away Asset-specific review of available issuer information. Item 14 Client Referrals and Other Compensation Promoter and Referral Arrangements under the Amended Marketing Rule (Rule 206(4)-1) In compliance with the SEC’s Amended Marketing Rule (Rule 206(4)-1), CCMA may establish referral arrangements with industry professionals, such as attorneys or accountants, to compensate them for client referrals. If such referral arrangements are established, CCMA will ensure that these arrangements are governed by written agreements, which will outline the terms of the referral compensation. The firm will also provide full disclosure to the referred client, including details about the referral arrangement and any compensation involved. This information will be disclosed at the time of the referral and will be reflected in the client’s advisory agreement. Additionally, CCMA will update its Form ADV to include disclosure of any referral arrangements paid to promoters. The referral fee paid to the promoter will not result in any increase to the advisory fee charged to the client, and no client will be charged a higher fee than another client based on how they were referred to the firm, ensuring all clients are treated equitably regardless of the referral arrangement. Currently, no referral fees have been paid. If a referral fee is paid in the future, it will not be based on a percentage of the advisory fee collected by CCMA. Rather, the fee will be flat or fixed, and full transparency will be provided to the client. Additionally, CCMA may receive referrals from other clients. However, the firm does not provide any cash or non-cash compensation to these clients for their referrals. Compensation to Employees Registered investment adviser representatives of CCMA_, who are employees or independent contractors of the firm, may be compensated based on a percentage of the gross investment advisory fee charged to the client. These individuals will be appropriately registered and licensed under applicable federal and/or state regulations, ensuring compliance with state and federal laws or any other relevant regulation still in effect. This compensation structure is distinct from any referral arrangements with external professionals or other promoters. CCMA (or related persons) currently does not compensate non-supervised persons for client referrals. Chicago Capital Management Advisors, LLC 19  Part 2A of Form ADV: Brochure Item 15 Custody Qualified Third-Party Custodians The Third-Party Custodians send statements at least quarterly or more frequently, as indicated in the custodian account opening documents. Clients are encouraged to review those statements carefully. When clients also receive reports from us at least annually, compare our reports to the custodian. On occasion, the reports may vary slightly from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. When clients have questions about their account statements or do not receive an account statement, they should contact CCMA or the custodian preparing the statement. 1. National Financial Services LLC (NFS) provides trade confirmations and statements to CCMA clients minimally monthly. Included in the statement is an advanced billing notice of the fees that will be debited from the account along with a calculation of how those fees were calculated. Fees are calculated by the custodian based the fees agreed in the Advisory contract signed by the client, in conjunction with opening an account with the custodian requesting fees be debited from the client's account monthly. 2. Goldman Sachs/Folio Institutional ("Folio") provides trade confirmations and statements monthly via e-mail or through electronic account access. Folio fees may be roughly .25% higher due to no transaction charges on window trades, although unsolicited trades & liquidation fees may be charged. FOLIO accounts with our firm are established with required internet access and emails of confirmations. Advanced billing statements are provided each month for each customer with a calculation of how those fees were calculated. Fees are calculated by the custodian based the fees agreed in the Advisory contract signed by the client, in conjunction with opening an account with the custodian requesting fees be debited from the client's account monthly. 3. RBC Correspondent Services ("RBC") provides trade confirmations and statements to CCMA clients minimally monthly. Advance billing statements are provided each quarter for each customer with a calculation of how those fees were calculated. Fees are calculated by a third party for the custodian based the fees agreed in the Advisory contract signed by the client, in conjunction with opening an account with the custodian requesting fees be debited from the client's account quarterly. 4. ETC Brokerage Services/Equity Trust ("ETAS") provides trade confirmations and statements monthly via e-mail or through electronic account access. ETAS accounts with our firm are established with required internet access and emails of confirmations. Advanced billing statements are provided quarterly for each customer with a calculation of how those fees were calculated. Fees are calculated by the custodian based the fees agreed in the Advisory contract signed by the client, in conjunction with opening an account with the custodian requesting fees be debited from the client's account quarterly. 5. Chales Schwab (“SCHWAB”) provides trade confirmations and statements monthly via e-mail or through electronic account access. SCHWAB accounts with our firm are established with required internet access and emails of confirmations. Advanced billing statements are provided quarterly for each customer with a calculation of how those fees were calculated. Fees are calculated by the custodian based the fees agreed in the Advisory contract signed by the client, in conjunction with opening an account with the custodian requesting fees be debited from the client's account quarterly. Standing Letters of Authorization CCMA is deemed to have custody of certain client assets under Rule 206(4)-2 of the Investment Advisers Act of 1940 because certain clients have established standing letters of authorization or other similar asset-transfer arrangements with Chicago Capital Management Advisors, LLC 20  Part 2A of Form ADV: Brochure their qualified custodians. Under these arrangements, CCMA is authorized to instruct the qualified custodian to transfer client funds to one or more third parties designated by the client. The Custody Rule defines custody to include an arrangement under which an investment adviser is authorized or permitted to withdraw client funds or securities maintained with a custodian upon the adviser’s instruction to the custodian. CCMA does not obtain an annual surprise examination in connection with these arrangements because CCMA believes that its third-party SLOA arrangements satisfy the seven conditions described in the SEC staff’s February 21, 2017 no-action letter to the Investment Adviser Association. Among other requirements, the client provides the transfer instructions and authorization in writing directly to the qualified custodian; the qualified custodian verifies the client’s authorization and provides required notices to the client; the client may terminate or change the instruction; CCMA cannot designate or change the third-party recipient or the recipient’s information; and the recipient is neither a related party of CCMA nor located at CCMA’s address. CCMA maintains records relating to these arrangements and includes the affected client assets in its custody reporting on Form ADV Part 1A. Fees are calculated by third-parties, in which you will receive or have access through your online accounts access an invoice for the amount of the calculated fees ten days prior to the funds being deducted. CCMA may also send the same invoice to the custodian. Clients must be provided written authorization permitting CCMA to be paid directly by the custodian. If this is the case, the custodian will also send the client an invoice or statement directly showing all disbursements through the custodian account including the amount of advisory fees. This fee is cumulative and in limited circumstances is negotiable. We base the management fee on the market value of your portfolio as determined by the custodian (or outside pricing service) at the end of the last trading day of the previous month. We charge the investment management fee each month at one-twelfth of the above annual rate and deduct this fee directly from your account for NFSC and Folio and quarterly at one-fourth of the above annual rate and deduct this fee directly from your account at RBC, SCHWAB and ETAS. The Investment Advisory Agreement may be terminated by either party immediately upon receipt of written notice from the other party. If you should terminate the relationship, we refund to you on a pro rata basis the fees which you have prepaid and which we will have not yet earned, using the days remaining in the month over the actual number of days in the month. Upon termination of the Client Agreement, we have no obligation to take any action with regard to investments in your account(s). Prior to engaging CCMA to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with CCMA setting forth the terms and conditions under which CCMA shall manage the client's assets. CCMA then will manage the account consistent with clients' stated investment objectives, and all applicable Federal laws, including The Investment Advisers Act of 1940, and the laws of the State in which the Client lives. Under CCMA's advisory agreement, CCMA has full trading discretionary authority to make investment decisions regarding the assets in all advisory accounts. This authority includes, but is not limited to, 1) buy, sell, exchange, convert, and otherwise trade in any and all stocks, bonds, derivatives and other securities as CCMA may select, and 2) establish, maintain, and deal on behalf of the client with one or more securities brokerage firms as may be selected by CCMA through a brokerage agreement signed by the customer. CCMA requests its clients to sign trading authority to grant limited trading discretionary authority to CCMA upon entering the contractual relationship. In rare cases we do manage clients on a non-discretionary basis which means that we will get the clients approval before executing the recommendations that we make. Clients may impose reasonable restrictions on the adviser's discretion to invest in certain securities or types of securities if a Chicago Capital Management Advisors, LLC 21  Part 2A of Form ADV: Brochure client provides clear, written directions to that effect. Clients may opt to have their account managed on a not-exclusively discretionary basis and may direct the investment of all or a portion of their account. The client allows the power of discretion to an adviser by means of a limited power of attorney, which the client may revoke at any time. Held-Away Held Away Assets Certain clients have Held-Away Assets maintained outside their primary managed brokerage accounts by third-party custodians, mutual fund companies, retirement-plan providers, insurance companies, issuers, transfer agents, or other recordkeepers. CCMA evaluates the custody treatment of each arrangement based on the type of asset and the authority granted to CCMA. Providing advisory services, monitoring an asset, or exercising authorized trading authority does not, by itself, give CCMA custody when CCMA does not possess the asset or have authority to withdraw or transfer it. Certain privately offered securities may not be maintained with a qualified custodian. CCMA will rely on the exception for a privately offered security only after confirming and documenting that the security was acquired directly from the issuer in a nonpublic offering, is uncertificated, is recorded only on the books of the issuer or its transfer agent in the client’s name, and can be transferred only with the prior consent of the issuer or the holders of the issuer’s outstanding securities. The applicable custodian, mutual fund company, retirement-plan provider, insurance company, issuer, transfer agent, or other recordkeeper provides official ownership or account records and available statements to the client. Clients should review those records carefully and compare them with any supplemental report provided by CCMA. Differences may result from valuation methods, reporting periods, transaction timing, accounting practices, or the date information was received and entered into CCMA’s system. Clients should contact both CCMA and the entity that prepared the applicable record or statement with questions or to report a discrepancy. Item 16 Investment Discretion Prior to engaging CCMA to provide investment management services, the client will be required to enter into a formal Investment Advisory Agreement with CCMA setting forth the terms and conditions under which CCMA shall manage the client's assets. CCMA then will manage the account consistent with clients' stated investment objectives, and all applicable Federal laws, including The Investment Advisers Act of 1940, and the laws of the State in which the Client lives. Under CCMA's advisory agreement, CCMA has full trading discretionary authority to make investment decisions regarding the assets in all advisory accounts. This authority includes, but is not limited to, 1) buy, sell, exchange, convert, and otherwise trade in any and all stocks, bonds, derivatives and other securities as CCMA may select, and 2) establish, maintain, and deal on behalf of the client with one or more securities brokerage firms as may be selected by CCMA through a brokerage agreement signed by the customer. CCMA requests its clients to sign trading authority to grant full trading discretionary authority to CCMA upon entering the contractual relationship. Clients may impose reasonable restrictions on the adviser's discretion to invest in certain securities or types of securities if a client provides clear, written directions to that effect. Clients may opt to have their account managed on a not-exclusively discretionary basis and may direct the investment of all or a portion of their account. The client allows the power of discretion to an adviser by means of a limited power of attorney, which the client may revoke at any time. Item 17 Voting Client Securities Our firm does not exercise voting rights for securities held in client accounts. Clients are responsible for voting their own proxies. During account setup, clients must instruct the custodian to send all proxies and related solicitations directly to them. Chicago Capital Management Advisors, LLC 22  Part 2A of Form ADV: Brochure Clients will receive their proxies and other solicitations directly from the custodian or transfer agent. If a client wishes to discuss a particular proxy solicitation or has questions regarding a voting matter, they may contact us at (630) 241-1122 or email us at ccma@chicagomanagement.com for further guidance. However, we will not vote on behalf of the client unless explicitly agreed upon in writing. In such cases, we would vote in the best interest of the client. In accordance with Rule 206-4-6, we will maintain policies and procedures in writing that will reasonably ensure: We vote in the best interest of each client Any material conflicts between our firm’s interests and those of our clients with respect to proxy voting will be managed to avoid harming the client. The proper maintenance of records on how the proxies were voted If we were to use a third-party proxy voting service, we would conduct ongoing due diligence of the vendor to ensure our proxy votes are processed and in the best interest of all of our clients. Clients can request the record of how he firm voted proxies on their behalf by contacting us at (630) 241-1122 or emailing us at ccma@chicagomanagement.com. Item 18 Financial Information CCMA has no obligation that would impair its ability to meet its obligations, which are contractual and fiduciary to its clients and has not been the subject of a bankruptcy proceeding. CCMA does not require prepayment of more than $1,200 in fees per client six months in advance. Item 19 - Social Media Policy Whether or not an employee chooses to create or participate in social media, or any other form of online publishing or discussion is his or her own decision, as long as it does not represent our company, industry, investment advice. However, we recognize that emerging online collaboration platforms are fundamentally changing the way individuals and organizations communicate, and this policy is designed to offer practical guidance for responsible, constructive communications via social media channels for employees. The same principles and guidelines that apply to the activities of personnel in general, as found in the Professional Conduct Policy, apply to employee activities in social media channels and any other form of online publishing. In regard to social media, our organization fully respects the legal rights of our employees, including their rights to engage in concerted and protected activities, and any part of this policy which interferes with or "chills" the legal rights of our employees will not be enforced. In general, what you do on your own time is your affair. However, activities in or outside of work that affect your job performance, the performance of others, clients, or our business interests are a proper focus for company policy. Our personnel will have to report or give access to all social media activities, for management review. Personnel will not use social media to promote our company, industry, or investments or face immediate disciplinary action or possible termination. Chicago Capital Management Advisors, LLC 23  Part 2A of Form ADV: Brochure Item 20 Business Continuity Plan (BCP) CCMA will maintain a written BCP available which includes: 1. Protection, backup and recovery of books and records. a. All new account information will be backed up to a secure server outside the main office. b. All accounts will be held by a qualified custodian. The Advisory will only use qualified custodians that will keep customer statements and information on its server for minimally the time mandated by FINRA and the SEC. 2. Alternate means of communication with customers a. In case phones go down at the main office, they will be routed to someone who can service the customer accounts. b. The customers will be provided with the main office number, the phone number of representative adviser, and the phone number of the office of the principal outside of the main office. 3. Office relocation in the event of temporary or permanent loss of the main office. a. Customer account information and managed accounts will be accessible at the branch office at 230 W. Monroe, Suite 300 Chicago, IL, 60606 in addition to the Main Office. 4. Assignment of duties to qualified responsible persons in the event of the death or unavailability of key personnel. a. A new Principal will be assigned in the event of the unavailability of one of the key personnel. Chicago Capital Management Advisors, LLC 24