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FORM ADV PART 2A - FIRM BROCHURE
Presidio Capital Management, LLC (CRD 304501), brochure dated October 19, 2026. Text extracted from the firm's SEC Form ADV Part 2 brochure.
View firm on SEC ↗ · Current Form ADV (PDF) ↗
Presidio Capital Management, LLC
Form ADV Part 2A – Disclosure Brochure
Effective: October 19, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of Presidio Capital Management, LLC (“Presidio” or the “Advisor”). If you have any questions about the content of
this Disclosure Brochure, please contact the Chief Compliance Officer at 858-461-4959 or by email at
george@presidiocm.com.
Presidio is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This Disclosure
Brochure provides information about Presidio to assist you in determining whether to retain the Advisor.
Additional information about Presidio and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 304501.
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Presidio.
Presidio believes that communication and transparency are the foundation of its relationship with clients and will
continually strive to provide you with complete and accurate information at all times. Presidio encourages all current
and prospective clients to read this Disclosure Brochure and discuss any questions you may have with the Advisor.
The following changes have been made to this Disclosure Brochure since the last filing and distribution to Clients:
• The Advisor has implemented a minimum relationship size requirement of $1,000,000 in order to establish
and maintain an advisory relationship, subject to certain discretionary exceptions. Please see Item 7 for
additional information.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices, changes
in regulations or routine annual updates as required by the securities regulators. This complete Disclosure Brochure
or a Summary of Material Changes shall be provided to you annually and if a material change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 304501. You may also
request a copy of this Disclosure Brochure at any time by contacting the Chief Compliance Officer at 858-461-4959
or by email at george@presidiocm.com.
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 2
Item 3 – Table of Contents
Item 1 – Cover Page ............................................................................................................................................... 1
Item 2 – Material Changes ..................................................................................................................................... 2
Item 3 – Table of Contents ..................................................................................................................................... 3
Item 4 – Advisory Services .................................................................................................................................... 4
A. Firm Information .............................................................................................................................................................. 4
B. Advisory Services Offered ............................................................................................................................................... 4
C. Client Account Management ........................................................................................................................................... 6
D. Wrap Fee Programs ........................................................................................................................................................ 6
E. Assets Under Management ............................................................................................................................................. 6
Item 5 – Fees and Compensation ......................................................................................................................... 7
A. Fees for Advisory Services.............................................................................................................................................. 7
B. Fee Billing........................................................................................................................................................................ 8
C. Other Fees and Expenses .............................................................................................................................................. 8
D. Advance Payment of Fees and Termination ................................................................................................................... 9
E. Compensation for Sales of Securities ............................................................................................................................. 9
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 9
Item 7 – Types of Clients ..................................................................................................................................... 10
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ......................................................... 10
A. Methods of Analysis ...................................................................................................................................................... 10
B. Risk of Loss ................................................................................................................................................................... 10
Item 9 – Disciplinary Information ........................................................................................................................ 12
Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 12
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 12
A. Code of Ethics ............................................................................................................................................................... 12
B. Personal Trading with Material Interest ......................................................................................................................... 13
C. Personal Trading in Same Securities as Clients ........................................................................................................... 13
D. Personal Trading at Same Time as Client .................................................................................................................... 13
Item 12 – Brokerage Practices ............................................................................................................................ 13
A. Recommendation of Custodian[s] ................................................................................................................................. 13
B. Aggregating and Allocating Trades ............................................................................................................................... 14
Item 13 – Review of Accounts ............................................................................................................................. 14
A. Frequency of Reviews ................................................................................................................................................... 14
B. Causes for Reviews ...................................................................................................................................................... 14
C. Review Reports ............................................................................................................................................................. 14
Item 14 – Client Referrals and Other Compensation ........................................................................................ 14
A. Compensation Received by Presidio ............................................................................................................................ 14
B. Compensation for Client Referrals ................................................................................................................................ 15
Item 15 – Custody ................................................................................................................................................. 15
Item 16 – Investment Discretion ......................................................................................................................... 16
Item 17 – Voting Client Securities ....................................................................................................................... 16
Item 18 – Financial Information ........................................................................................................................... 16
Privacy Policy ....................................................................................................................................................... 17
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 3
Item 4 – Advisory Services
A. Firm Information
Presidio Capital Management, LLC (“Presidio” or the “Advisor”) is a registered investment advisor with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC) under
the laws of the State of California. Presidio was founded in 2022 and is wholly owned by Absolute Wealth Advisors,
Inc., which is owned and operated by Dustin TenBroeck. This Disclosure Brochure provides information regarding
the qualifications, business practices, and the advisory services provided by Presidio.
For additional information regarding this Disclosure Brochure, please contact our Chief Compliance Officer, George
Mendoza at 858-461-4959.
B. Advisory Services Offered
Presidio offers investment advisory services to individuals, high net worth individuals, business owners, trusts,
estates, charitable organizations, and retirement plans (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary, the
Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential conflicts
of interest. Presidio's fiduciary commitment is further described in the Advisor’s Code of Ethics. For more information
regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in Client Transactions
and Personal Trading.
Investment Management Services
Presidio provides customized investment advisory solutions for its Clients. This is achieved through continuous
personal Client contact and interaction while providing discretionary investment management and related advisory
services. Presidio works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. Presidio will then construct an investment
portfolio, consisting of low-cost, diversified mutual funds and/or exchange-traded funds (“ETFs”) to achieve the
Client’s investment goals. The Advisor may also utilize individual stocks, bonds, structured products, alternative
investments, and options contracts to meet the needs of its Clients. The Advisor may retain other types of investments
from the Client’s legacy portfolio due to fit with the overall portfolio strategy, tax-related reasons, or other reasons as
identified between the Advisor and the Client.
Presidio’s investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate positions
that have been held for less than one year to meet the objectives of the Client or due to market conditions. Presidio
will construct, implement and monitor the portfolio to ensure it meets the goals, objectives, circumstances, and risk
tolerance agreed to by the Client. Each Client will have the opportunity to place reasonable restrictions on the types
of investments to be held in their respective portfolio, subject to acceptance by the Advisor.
Presidio evaluates and selects investments for inclusion in Client portfolios only after applying its internal due
diligence process. Presidio may recommend, on occasion, redistributing investment allocations to diversify the
portfolio. Presidio may recommend specific positions to increase sector or asset class weightings. The Advisor may
recommend employing cash positions as a possible hedge against market movement.
Presidio may recommend selling positions for reasons that include, but are not limited to, harvesting capital gains or
losses, business or sector risk exposure to a specific security or class of securities, overvaluation or overweighting
of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client needs, or any
risk deemed unacceptable for the Client’s risk tolerance.
At no time will Presidio accept or maintain custody of a Client’s funds or securities, except for the limited authority as
outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at the Custodian,
pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement accounts
or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the Employee
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 4
Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable, which are laws
governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will provide investment
advice to a Client regarding a distribution from an ERISA retirement account or to roll over the assets to an IRA, or
recommend a similar transaction including rollovers from one ERISA sponsored Plan to another, one IRA to another
IRA, or from one type of account to another account (e.g. commission-based account to fee-based account). Such a
recommendation creates a conflict of interest if the Advisor will earn a new (or increase its current) advisory fee as a
result of the transaction. No client is under any obligation to roll over a retirement account to an account managed by
the Advisor.
Use of Independent Managers
The Advisor may recommend that Clients utilize one or more unaffiliated investment managers, or turnkey asset
management program (collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio,
based on the Client’s needs and objectives. The Advisor will perform initial and ongoing oversight and due diligence
over each Independent Manager to ensure the strategy remains aligned with Client’s investment objectives and
overall best interests. The Advisor will also assist the Client in the development of the initial policy recommendations
and managing the ongoing Client relationship. The Advisor will ensure that each Independent Manager is properly
licensed, notice filed, or exempt from registration. The Client will be provided with the Independent Manager's Form
ADV Part 2A - Disclosure Brochure (or a brochure that makes the appropriate disclosures).
Third-Party Access Platforms
The Advisor may use third-party platforms to access, aggregate, or manage certain client accounts that are held
away from the Advisor’s primary custodians, such as employer-sponsored retirement plans or other externally
maintained accounts. These platforms allow clients to grant the Advisor authorized access to account information
and, where permitted, limited account management capabilities.
Access to such accounts is provided solely at the client’s direction and subject to the permissions granted by the
client through the third-party platform. Recommendations to have assets managed through a third-party platform
pose a conflict between the interests of the Advisor and the interests of the Client. Assets managed through a third-
party platform increases the level of investment assets with the Advisor, as it would increase the amount of advisory
fees paid to the Advisor. Clients are not obligated to have the Advisor manage held-away assets by the Advisor.
Financial Planning and Consulting Services
Presidio will typically provide a variety of financial planning and consulting services to Clients, pursuant to a written
financial planning or consulting agreement. Services are offered in several areas of a Client’s financial situation,
depending on their goals and objectives. Generally, such services involve preparing a formal financial plan or
rendering a specific financial consultation based on the Client’s financial goals and objectives. This planning or
consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example, recommendations
may be made that the Client start or revise their investment programs, commence or alter retirement savings,
establish education savings and/or charitable giving programs.
Presidio may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique situation.
The Advisor may also leverage Wealth.com, a third-party platform, to provide estate planning services. For certain
financial planning engagements, the Advisor will provide a written summary of the Client’s financial situation,
observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may not provide a written
summary. Plans or consultations are typically completed within six (6) months of contract date, assuming all
information and documents requested are provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor for
investment management services or to increase the level of investment assets with the Advisor, as it would increase
the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any recommendations made
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 5
by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects to act on any of the
recommendations made by the Advisor, the Client is under no obligation to implement the transaction through the
Advisor.
Retirement Plan Consulting Services
Presidio provides Retirement Plan Consulting on behalf of the retirement plans (each a “Plan”) and the company (the
“Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the Plan Sponsor in meeting
its fiduciary obligations to the Plan and its Plan Participants. Each engagement is customized to the needs of the
Plan and Plan Sponsor. Services generally include:
Investment Policy Statement (“IPS”) Design and Monitoring
Investment Due Diligence
Investment Oversight Services (ERISA 3(21))
Investment Management Services (ERISA 3(38))
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
•
•
•
•
• Performance Reporting
• Ongoing Investment Recommendation Assistance
These services are provided by Presidio serving in the capacity as a fiduciary under the Employee Retirement Income
Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan Sponsor is
provided with a written description of Presidio’s fiduciary status, the specific services to be rendered and all direct
and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging Presidio to provide investment advisory services, each Client is required to enter into one or more
agreements with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
• Establishing an Investment Strategy – Presidio, in connection with the Client, will develop a strategy that
seeks to achieve the Client’s goals and objectives.
• Asset Allocation – Presidio will develop a strategic asset allocation that is targeted to meet the investment
objectives, time horizon, financial situation and tolerance for risk for each Client.
• Portfolio Construction – Presidio will develop a portfolio for the Client that is intended to meet the stated goals
and objectives of the Client.
•
Investment Management and Supervision – Presidio will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Presidio does not manage or place Client assets into a wrap fee program. Investment management services are
provided directly by Presidio.
E. Assets Under Management
As of December 31, 2025, Presidio manages $498,887,848 in regulatory assets under management on a
discretionary basis and provides advisory services with respect to an additional $9,002,566 in assets under
advisement for a total of $507,890,414. Clients may request more current information at any time by contacting the
Advisor.
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 6
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into one or more
written agreements with the Advisor.
A. Fees for Advisory Services
Investment Management Services
Investment management fees are paid quarterly, in advance of each calendar quarter, pursuant to the terms of the
investment management agreement. Investment management fees are based on the market value of assets under
management at the end of the prior calendar quarter. Investment management fees are calculated using a tiered fee
schedule, in which the applicable annual rate is applied to the portion of assets within each asset tier, as set forth
below:
Annual Rate (%)
Assets Under Management ($)
First $0 to $999,999.99
Next $1,000,000 to $2,499,999.99
Next $2,500,000 to $4,999,999.99
Next $5,000,000 to $9,999,999.99
Over $10,000,000
1.15%
0.85%
0.75%
0.55%
0.35%
For example, a Client with $3,000,000 in assets under management would be charged an annual advisory fee calculated
as follows: 1.15% on the first $1,000,000; 0.85% on the next $1,500,000; and 0.75% on the remaining $500,000,
resulting in a blended annual fee of approximately $28,250.
Please Note: This fee schedule applies to Clients with more than $500,000 in assets under management with Presidio.
Clients with less than $500,000 in assets under management will be charged an annualized fee of 1.50%.
The investment management fee for the first quarter of service is prorated from the inception date of the account(s)
through the end of the first billing period. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fee
may take into consideration the aggregate assets under management with the Advisor. All securities held in accounts
managed by Presidio are independently valued by the Custodian; however, certain privately held investments are
valued in accordance with the applicable sponsor’s valuation policy, which is updated at least annually and available
upon request. Presidio conducts periodic reviews of Custodian valuations to ensure accurate billing.
For assets managed through a third-party platform, the Client is not charged any additional platform fees. The Advisor
bears the cost of the platform in order to service these Client assets. Advisory fees apply to assets accessed and
managed through the platform as part of the Client’s assets under management, as disclosed above.
The Advisor’s fee is exclusive of, and in addition to, securities transaction fees, custody fees, and other related costs
and expenses described in Item 5.C below. Presidio does not receive any portion of these commissions, fees, or costs.
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 management fee as described above. In certain
separately managed accounts, the Advisor may pass through an additional management fee charged by an
Independent Manager (e.g., specialty managers such as Legg Mason or Goldman); additional details regarding these
arrangements are described below. The total blended fee, including the Advisor’s fee and the Independent Manager’s
fee, will not exceed 2.00% annually.
Financial Planning and Consulting Services
Presidio offers financial planning and consulting services on an hourly, flat or recurring fee basis. Hourly fees will not
exceed $450 per hour. Flat or recurring fees range from $2,500 to $75,000, depending on the scope and complexity of
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 7
the engagement. An estimate for total hours and/or total costs will be provided to the Client prior to engaging for these
services.
Retirement Plan Consulting Services
Presidio offers retirement plan consulting for an annual asset-based fee or a flat fee. Asset-based fees are charged at
an annual rate of up to 1.00%. Flat fees are charged at annually up to $75,000. Fees are typically payable at the end of
billing period, pursuant to the terms of the retirement plan advisory agreements. Retirement plan advisory fees are
negotiable depending on the size and complexity of the Plan.
B. 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. At the beginning of each respective quarter, the Advisor will upload fee information to the Custodian
indicating the amount of advisory fees to be deducted from the Client’s account[s]. The amount due is calculated by
applying the quarterly rate (annual rate multiplied by days in the quarter divided by 365) to the total assets under
management with Presidio 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 management 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
Presidio to be paid directly from their account[s] held by the Custodian as part of the investment management
agreement and separate account forms provided by the Custodian.
With respect to unaffiliated non-custodial partnership/private fund investments, which are not held at the Custodian, the
Client shall be required to complete applicable private placement and/or account opening documents to establish these
investments. The Advisor will debit its fee for providing investment management services with respect to these
relationships directly from an account designated by the Client held at the Custodian. For certain non- custodial
partnership/private fund investments, the Advisor may not receive quarter- end investment valuations prior to its fee
billing calculation. In such instances, the Advisor will use the most recent month-end or quarter-end valuation available
for the calculation of investment management fees. The Advisor will recalculate its fee upon receipt of final valuations.
Adjustments are reflected in the fee calculations for the next quarterly period.
Use of Independent Managers
For Client accounts implemented through an Independent Manager, the Client’s overall fees may include the Advisor’s
investment management fee (as noted above) plus investment management fees and/or platform fees charged by the
Independent Manager[s], as applicable. In certain instances, the Independent Manager or the Advisor may assume
responsibility for calculating the Client’s fees and deduct all fees from the Client’s account[s].
Financial Planning and Consulting Services
Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon deliverable[s].
Retirement Plan Consulting Services
Retirement plan consulting fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, depending on the terms of the retirement plan consulting agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Presidio, in connection with investments
made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities execution fees
charged by the Custodian, as applicable. The Advisor's recommended Custodian does not charge securities
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. The fees charged by Presidio are separate and distinct from these custody and
execution fees.
In addition, all fees paid to Presidio 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
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 8
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 Presidio, but would
not receive the services provided by Presidio 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 Presidio to fully
understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Investment Management Services
Presidio may be compensated for its investment management services in advance of the calendar quarter in which
services are rendered. Either party may terminate the investment management agreement, at any time, by providing
advance written notice to the other party. The Client may also terminate the investment management agreement within
five (5) business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client
will incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
payable by the Client. Upon termination, the Advisor will refund any unearned, prepaid investment management fees
from the effective date of termination to the end of the calendar quarter. The Client’s investment management
agreement with the Advisor is non-transferable without the Client’s prior consent.
Use of Independent Managers
In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest,
the Advisor will have the discretion to terminate the relationship with the Independent Manager. The terms for
termination are set forth in the respective agreements between the Advisor and the Independent Managers.
Financial Planning and Consulting Services
Presidio is compensated for its financial planning and consulting services upon execution of the engagement. Either
party may terminate the financial planning agreement, at any time, by providing advance written notice to the other
party. The Client may also terminate the financial planning agreement within five (5) business days of signing the
Advisor’s agreement at no cost to the Client. After the five-day period, the Client will incur charges for bona fide
advisory services rendered to the point of termination and such fees will be due and payable by the Client. Upon
termination, the Client shall be billed for actual hours logged on the planning project times the contractual hourly rate
or in the case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The
Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.
Retirement Plan Consulting Services
Presidio is typically compensated for its retirement plan consulting services at the end of the billing period, after
retirement plan consulting services are rendered. Either party may terminate the retirement plan consulting
agreement, at any time, by providing advance written notice to the other party. The Client may also terminate the
retirement plan consulting agreement within five (5) business days of signing the Advisor’s agreement at no cost to
the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered to the point
of termination and such fees will be due and payable by the Client. The Client’s retirement plan consulting agreement
with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Presidio does not buy or sell securities to earn commissions and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
Presidio does not charge performance-based fees for its investment advisory services. The fees charged by Presidio
are as described in Item 5 above and are not based upon the capital appreciation of the funds or securities held by
any Client.
Presidio does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund or a
hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 9
Item 7 – Types of Clients
Presidio offers investment advisory services to individuals, high net worth individuals, business owners, trusts,
estates, charitable organizations, and retirement plans. Presidio generally requires a minimum relationship size of
$1,000,000 to establish and maintain an advisory relationship; however, the Advisor may, in its discretion, accept
accounts below this minimum in certain circumstances, such as for related family members, children of existing
Clients, or emerging wealth relationships.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Presidio primarily employs fundamental analysis in developing investment strategies for its Clients. Presidio’s
research and analysis are derived from numerous sources, including financial media, third-party research materials,
Internet sources, and a review of company and investment activities, including financial statements, offering
documents, prospectuses, and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria consists
generally of ratios and trends that may indicate the overall strength and financial viability of the entity being analyzed.
Assets are deemed suitable if they meet certain criteria to indicate that they are a strong investment with a value
discounted by the market. While this type of analysis helps the Advisor in evaluating a potential investment, it does
not guarantee that the investment will increase in value. Assets meeting the investment criteria utilized in the
fundamental analysis may lose value and may have negative investment performance. The Advisor monitors these
economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
As noted above, Presidio generally employs a long-term investment strategy for its Clients, as consistent with their
financial goals. Presidio will typically hold all or a portion of a security for more than a year, but may hold for shorter
periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times, Presidio may also
buy and sell positions that are more short-term in nature, depending on the goals of the Client and/or the fundamentals
of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients should
be prepared to bear the potential risk of loss. Presidio will assist Clients in determining an appropriate strategy based
on their tolerance for risk and other factors noted above. However, there is no guarantee that a Client will meet their
investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment strategies as well as general
risks of investing.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that the
investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis may
lose value and may have negative investment performance. The Advisor monitors these economic indicators to
determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s review process are
included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the Client
or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals or
other factors that may affect this analysis.
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 10
The risks associated with a particular strategy are provided to each Client in advance of investing Client accounts.
The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio construction process.
Following are some of the risks associated with the Advisor’s investment strategies:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of the
mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a mutual
fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the same price
as a mutual fund purchased later that same day.
Equity (stock) Market Risk
Common stocks are susceptible to general stock market fluctuations and to volatile increases and decreases in value
as market confidence in and perceptions of their issuers change. If you held common stock, or common stock
equivalents, of any given issuer, you would generally be exposed to greater risk than if you held preferred stocks and
debt obligations of the issuer.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs will
fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading risk based
on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs has a large bid-ask spread
and low trading volume. The price of an ETF fluctuates based upon the market movements and may dissociate from
the index being tracked by the ETF or the price of the underlying investments. An ETF purchased or sold at one point
in the day may have a different price than the same ETF purchased or sold a short time later.
Bond Risks
Bonds are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices will fall
if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the coupon rate
of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower rate than was
previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at a rate that exceeds
the income investment thereby decreasing the investor’s rate of return, (4) credit default risk, i.e. the risk associated
with purchasing a debt instrument which includes the possibility of the company defaulting on its repayment
obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of the company’s rating
which impacts the investor’s confidence in the company’s ability to repay its debt and (6) Liquidity Risks, i.e. the risk
that a bond may not be sold as quickly as there is no readily available market for the bond.
Independent Manager Risks
The Advisor may select certain Independent Managers to manage a portion of the Client’s portfolio. The Advisor will
conduct due diligence, monitor the performance and adherence to the investment mandates and objectives on the
selected Independent Managers. However, the Advisor will not have an active role in the day-to-day management of
this portion of the Client’s portfolio. A failure by an Independent Manager’s ability to successfully implement its model,
strategies and/or management of assets could result in a negative impact on the Client’s overall investment portfolio.
The performance may also be impacted by market conditions. Legal and compliance risk may also impact the
independent manager and its ability to manage client assets.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) can be volatile and may have limited liquidity. An
investor could lose all or a portion of their investment. Such investments often have concentrated positions and
investments that may carry higher risks. Client should only have a portion of their assets in these investments.
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 11
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if securities
pledged to brokers to secure a Client's margin accounts decline in value, the Client could be subject to a "margin
call", pursuant to which it must either deposit additional funds with the broker or be the subject of mandatory
liquidation of the pledged securities to compensate for the decline in value.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are
leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This
leverage can compound gains or losses.
Structured Products
Structured products are securities derived from another asset, such as a security or a basket of securities, an index,
a commodity, a debt issuance, or a foreign currency. Structured products frequently limit the upside participation in
the reference asset. Structured products are senior unsecured debt of the issuing bank and subject to the credit risk
associated with that issuer. This credit risk exists whether or not the investment held in the account offers principal
protection. The creditworthiness of the issuer does not affect or enhance the likely performance of the investment
other than the ability of the issuer to meet its obligations. Any payments due at maturity are dependent on the issuer’s
ability to pay. In addition, the trading price of the security in the secondary market, if there is one, may be adversely
impacted if the issuer’s credit rating is downgraded. Some structured products offer full protection of the principal
invested, others offer only partial or no protection. Investors may be sacrificing a higher yield to obtain the principal
guarantee. In addition, the principal guarantee relates to nominal principal and does not offer inflation protection. An
investor in a structured product never has a claim on the underlying investment, whether a security, zero coupon
bond, or option. There may be little or no secondary market for the securities and information regarding independent
market pricing for the securities may be limited. This is true even if the product has a ticker symbol or has been
approved for listing on an exchange. Tax treatment of structured products may be different from other investments
held in the account (e.g., income may be taxed as ordinary income even though payment is not received until
maturity). Structured CDs that are insured by the FDIC are subject to applicable FDIC limits.
Past performance is not a guarantee of future returns. Investing in securities and other investments involve
a risk of loss that each Client should understand and be willing to bear. Clients are reminded to discuss
these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Presidio or its management persons. Presidio
values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite due diligence
on any advisor or service provider that the Client engages. The backgrounds of the Advisor or Advisory Persons are
available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with the
Advisor’s firm name or CRD# 304501.
Item 10 – Other Financial Industry Activities and Affiliations
The sole business of Presidio and its Advisory Persons is to provide investment advisory services to its Clients.
Neither Presidio nor its Advisory Persons are involved in other business endeavors. Presidio does not maintain any
affiliations with other firms, other than contracted service providers to assist with the servicing of its Client’s accounts.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Presidio has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to each
Client. This Code applies to all persons associated with Presidio (“Supervised Persons”). The Code was developed
to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to each Client. Presidio
and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client. It is the obligation of
Presidio’s Supervised Persons to adhere not only to the specific provisions of the Code, but also to the general
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 12
principles that guide the Code. The Code covers a range of topics that address employee ethics and conflicts of
interest. To request a copy of the Code, please contact the Advisor at 858-461-4959 or via email at
info@presidiocm.com.
B. Personal Trading with Material Interest
Presidio allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Presidio does not act as principal in any transactions. In addition, the Advisor does
not act as the general partner of a fund, or advise an investment company. Presidio does not have a material interest
in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Presidio allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell) to Clients
presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities. The
fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is mitigated
by Presidio requiring reporting of personal securities trades by its Supervised Persons for review by the CCO or
delegate. The Advisor has also adopted written policies and procedures to detect the misuse of material, non-public
information.
D. Personal Trading at Same Time as Client
While Presidio allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded afterwards. At no
time will Presidio, or any Supervised Person of Presidio, transact in any security to the detriment of any
Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Presidio does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets and
authorize Presidio to direct trades to the Custodian as agreed upon in the investment advisory agreement. Further,
Presidio does not have the discretionary authority to negotiate commissions on behalf of Clients on a trade-by-trade
basis.
Where Presidio does not exercise discretion over the selection of the Custodian, it may recommend the Custodian
to Clients for custody and execution services. Clients are not obligated to use the Custodian recommended by the
Advisor and will not incur any extra fee or cost associated with using a custodian not recommended by Presidio.
However, the Advisor may be limited in the services it can provide if the recommended Custodian is not engaged.
Presidio may recommend the Custodian based on criteria such as, but not limited to, reasonableness of commissions
charged to the Client, services made available to the Client, and its reputation and/or the location of the Custodian’s
offices.
Presidio will generally recommend that Clients establish their account[s] at Charles Schwab & Co., Inc. (“Schwab”),
a FINRA-registered broker-dealer and member SIPC. Schwab will serve as the Client’s “qualified custodian”. Presidio
maintains an institutional relationship with Schwab, whereby the Advisor receives economic benefits from Schwab
Please see Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 13
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an advisor enters
into an agreement to place security trades with a broker-dealer/custodian in exchange for research and other
services. Presidio does not participate in soft dollar programs sponsored or offered by any broker-dealer/custodian.
However, the Advisor receives certain economic benefits from the Custodian. Please see Item 14 below.
2. Brokerage Referrals - Presidio does not receive any compensation from any third party in connection with the
recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Presidio will place trades
within the established account[s] at the Custodian designated by the Client. Further, all Client accounts are traded
within their respective account[s]. The Advisor will not engage in any principal transactions (i.e., trade of any security
from or to the Advisor’s own account) or cross transactions with other Client accounts (i.e., purchase of a security
into one Client account from another Client’s account[s]). Presidio will not be obligated to select competitive bids on
securities transactions and does not have an obligation to seek the lowest available transaction costs. These costs
are determined by the Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of execution,
4) confidentiality and 5) skill required of the Custodian. Presidio will execute its transactions through the Custodian
as authorized by the Client. Presidio may aggregate orders in a block trade or trades when securities are purchased
or sold through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot
be executed in full at the same price or time, the securities actually purchased or sold by the close of each business
day must be allocated in a manner that is consistent with the initial pre-allocation or other written statement. This
must be done in a way that does not consistently advantage or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by either the Portfolio Manager or a
Wealth Manager of Presidio. Formal reviews are generally conducted at least annually or more frequently depending
on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least annually.
Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a result of major
changes in economic conditions, known changes in the Client’s financial situation, and/or large deposits or
withdrawals in the Client’s account[s]. The Client is encouraged to notify Presidio if changes occur in the Client’s
personal financial situation that might adversely affect the Client’s investment plan. Additional reviews may be
triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage statements
are sent directly from the Custodian to the Client. The Client may also establish electronic access to the Custodian’s
website so that the Client may view these reports and their account activity. Client brokerage statements will include
all positions, transactions and fees relating to the Client’s account[s]. The Advisor may also provide Clients with
periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Presidio
Presidio is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment product.
Presidio does not receive commissions or other compensation from product sponsors, broker-dealers or any un-
related third party. Presidio may refer Clients to various unaffiliated, non-advisory professionals (e.g. attorneys,
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 14
accountants, estate planners) to provide certain financial services necessary to meet the goals of its Clients. Likewise,
Presidio may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform
Presidio has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like Presidio. As a registered investment advisor
participating on the Schwab Advisor Services platform, Presidio receives access to software and related support
without cost because the Advisor renders investment management services to Clients that maintain assets at
Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but not all services provided
by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests
of its Clients first. Clients should be aware, however, that the receipt of economic benefits from a custodian creates
a potential conflict of interest since these benefits may influence the Advisor's recommendation of this custodian over
one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be able
to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds and
other investments without having to adhere to investment minimums that might be required if the Client were to
directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to technology,
research, discounts and other services. In addition, the Advisor receives duplicate statements for Client accounts,
the ability to deduct advisory fees, trading tools, and back-office support services as part of its relationship with
Schwab. These services are intended to assist the Advisor in effectively managing accounts for its Clients, but may
not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and support to Presidio that may not
benefit the Client, including: educational conferences and events, consulting services and discounts for various
service providers. Access to these services creates a financial incentive for the Advisor to recommend Schwab, which
results in a conflict of interest. Presidio believes, however, that the selection of Schwab as Custodian is in the best
interests of its Clients.
B. Compensation for Client Referrals
Certain Clients may be referred to the Advisor by either an affiliated or unaffiliated party (herein "Promoter") and
receive, directly or indirectly, compensation for the Client referral. In such instances, the Advisor will compensate the
Promoter a fee in accordance with Rule 206(4)-1 of the Advisers Act and any corresponding state securities
requirements. Any such compensation shall be paid solely from the investment advisory fees earned by the Advisor,
and shall not result in any additional charge to the Client.
Item 15 – Custody
Presidio does not accept or maintain custody of any Client accounts, except for the authorized deduction of the
Advisor’s fees. All Clients must place their assets with a “qualified custodian”. Clients are required to engage the
Custodian to retain their funds and securities and direct Presidio to utilize that Custodian for the Client’s security
transactions. Clients should review statements provided by the Custodian and compare to any reports provided by
Presidio to ensure accuracy, as the Custodian does not perform this review. For more information about custodians
and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may have
custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor have
adopted safeguards to ensure that the money movements are completed in accordance with the Client’s instructions.
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 15
Item 16 – Investment Discretion
Presidio generally has discretion over the selection and amount of securities to be bought or sold in Client accounts
without obtaining prior consent or approval from the Client. However, these purchases or sales may be subject to
specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed to by Presidio.
Discretionary authority will only be authorized upon full disclosure to the Client. The granting of such authority will be
evidenced by the Client's execution of an investment advisory agreement containing all applicable limitations to such
authority. All discretionary trades made by Presidio will be in accordance with each Client's investment objectives
and goals.
Item 17 – Voting Client Securities
Presidio does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly from
the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains the sole
responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Presidio, nor its management, have any adverse financial situations that would reasonably impair the ability
of Presidio to meet all obligations to its Clients. Neither Presidio, nor any of its Advisory Persons, have been subject
to a bankruptcy or financial compromise. Presidio is not required to deliver a balance sheet along with this Disclosure
Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be performed six months or
more in the future.
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 16
Privacy Policy
Effective: October 19, 2026
Our Commitment to You
Presidio Capital Management, LLC (“Presidio” or the “Advisor”) is committed to safeguarding the use of personal
information of our Clients (also referred to as “you” and “your”) that we obtain as your Investment Advisor, as
described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your private
information, and we do everything that we can to maintain that trust. Presidio (also referred to as "we", "our" and
"us”) protects the security and confidentiality of the personal information we have and implements controls to
ensure that such information is used for proper business purposes in connection with the management or servicing
of our relationship with you.
Presidio does not sell your non-public personal information to anyone. Nor do we provide such information to others
except for discrete and reasonable business purposes in connection with the servicing and management of our
relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set forth
in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal information
and have policies over the transmission of data. Our associates are trained on their responsibilities to protect
Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they receive
from us.
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 17
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
No
Not Shared
Yes
Yes
No
Not Shared
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
Marketing Purposes
Presidio does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where Presidio or the
client has a formal agreement with the financial institution. We will only
share information for purposes of servicing your accounts, not for
marketing purposes.
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Information About Former Clients
Presidio does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients.
State-specific Regulations
California
In response to a California law, to be conservative, we assume accounts with California addresses do not want us to
disclose personal information about you to non-affiliated third parties, except as permitted by California law. We also limit
the sharing of personal information about you with our affiliates to ensure compliance with California privacy laws.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public personal
information other than as described in this notice unless we first notify you and provide you with an opportunity to
prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by contacting
the Chief Compliance Officer at 858-461-4959 or via email at george@presidiocm.com.
Presidio Capital Management, LLC
12626 High Bluff Drive, San Diego, CA 92130
Phone: 858-461-4959 * Fax: 858-461-4958
https://presidiocm.com/
Page 18