CALIFORNIA CAPITAL MANAGEMENT

Form ADV Part 2A Appendix 1 – Wrap Fee Program Brochure Item 1: Cover Page February 2026 California Capital Management Wrap Program Sponsored By: 2520 West Olive Avenue Suite 300 Burbank, CA 91505 Firm Contact: Khrysten Baltazar Chief Compliance Officer www.calcapmgt.com This brochure provides information about the qualifications and business practices of Consolidated Capital Management, LLC dba California Capital Management. If you have any questions about the contents of this brochure, please contact our firm by telephone at 818-766- 0660 or by email at kbaltazar@calcapmgt.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. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees. Please note that the use of the term “registered investment advisor” or being “registered” does not imply a certain level of skill or training.  Additional information about California Capital Management also is available on the SEC’s website at www.advisorinfo.sec.gov by searching CRD# 130734. Item 2: Material Changes California Capital Management is required to advise you of any material changes to our Wrap Fee Program Brochure (“Brochure”) from our last annual update. We must state clearly that we are only discussing material changes since the last annual update of our Brochure, and we must also provide the date of the last annual update. Since our last annual amendment filed on 02/27/2025, we have the following material change(s) to disclose: • We have designated Khrysten Baltazar as our firm’s new Chief Compliance Officer. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 2 California Capital Management  Item 3: Table of Contents Section: Page(s): Item 1: Cover Page ....................................................................................................................... 1 Item 2: Material Changes .............................................................................................................. 2 Item 3: Table of Contents .............................................................................................................. 3 Item 4: Services, Fees & Compensation ....................................................................................... 4 Item 5: Account Requirements & Types of Clients ....................................................................... 6 Item 6: Portfolio Manager Selection & Evaluation ......................................................................... 6 Item 7: Client Information Provided to Portfolio Manager(s) ......................................................... 9 Item 8: Client Contact with Portfolio Manager(s) ........................................................................ 10 Item 9: Additional Information ..................................................................................................... 10 ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 3 California Capital Management  Item 4: Services, Fees & Compensation We pay an asset-based fee to our custodian, Charles Schwab & Co., Inc. (“Schwab”), based on the total value of client assets custodied on their platform. It is common in the industry for wrap fee advisers to pay a transaction-based fee to their custodian for executing transactions in client accounts. However, wrap fee advisers that pay transaction-based compensation have a financial incentive to trade as little as possible to minimize expenses. Wrap fee advisers that pay asset- based compensation, like our firm, have the opposite financial incentive. Nevertheless, our firm seeks to adhere to our fiduciary duty to act in our clients’ best interest by placing their interests above our own and by trading when appropriate for our clients’ financial circumstances and objectives. We do not charge our clients higher advisory fees based on their trading activity. By participating in a wrap fee program, you may end up paying more or less than you would through a non-wrap fee program where trade execution costs are passed directly to you by the executing broker. Our Wrap Advisory Services Our Wrap Comprehensive Portfolio Management service encompasses asset management as well as providing financial planning/financial consulting to clients. It is designed to assist clients in meeting their financial goals through the use of financial investments. We conduct at least one, but sometimes more than one meeting (in person if possible, otherwise via telephone or video conference) with clients in order to understand their current financial situation, existing resources, financial goals, and tolerance for risk. Based on what we learn, we propose an investment approach to the client. We may propose an investment portfolio, consisting of exchange traded funds (“ETFs”), mutual funds, individual stocks or bonds, fee-based annuities, or other securities. Upon the client’s agreement to the proposed investment plan, we work with the client to establish or transfer investment accounts so that we can manage the client’s portfolio. Once the relevant accounts are under our management, we review such accounts on a regular basis and at least annually. We may periodically rebalance or adjust client accounts under our management. If the client experiences any significant changes to his/her financial or personal circumstances, the client must notify us so that we can consider such information in managing the client’s investments. Fee Schedule Assets Under Management Annual Percentage of Assets Charge: $0 to $249,999.99 $250,000 to $499,999.99 Over $500,000 2.95% 2.50% 2.00% Our firm’s fees are billed on a prorated annualized basis, quarterly in advance based on the value of your account on the last day of the previous quarter, which is typically the end of January, April, July and October. Adjustments will be made for deposits and withdrawals of cash and securities during the billing period for amounts of $1,000 or greater. For example, if a client withdraws cash or securities from their account exceeding $1,000 mid-billing period, they would receive a prorated fee refund based on the amount of the withdrawal and the remaining days in the billing period. The fee refund would be applied at the next quarterly billing and would reduce that billing period’s fee. If a client deposits cash or securities into their account exceeding $1,000 mid-billing period, a prorated fee would be assessed based on the amount of the deposit and the remaining days in the billing period. The prorated fee would be applied at the next quarterly billing and would increase that billing period’s fee. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 4 California Capital Management  Fees generally are negotiable at the discretion of our firm and will be automatically deducted from your managed account. As part of the fee deduction process, you understand and acknowledge the following: a) Your independent custodian sends statements at least quarterly to you showing the market values for each security included in the Assets and all disbursements in your account including the amount of the advisory fees paid to us; b) You provide authorization permitting us to be directly paid by these terms; and c) If we send a copy of our invoice to you, it will include a legend urging you to compare information provided in our statement with those from the qualified custodian. Please note the first advisory fee charged to new client accounts includes the fee charged on the regular billing date in advance for the first full quarter as well as a one-time prorated advisory fee in arrears for services rendered between the date of receipt of assets and the end of the previous quarter. We do not permit check writing or debt card use within investments accounts under our management where we trade securities (stocks, bonds, etc.). Any withdrawals from an investment account would need to be requested directly from our office or set up via automatic payment. If agreed upon in the signed advisory agreement, our firm will manage client account(s) that are held at a custodian that is not directly accessible by our firm using the Pontera Order Management System (“Pontera”). Pontera enables our firm to view and manage held away accounts. Our firm will charge an advisory fee of up to 1.50% for managed held away accounts. If a client’s advisory fee is below 1.50%, we will charge an advisory fee in accordance with their current advisory fee rate. The advisory fee payable for any held away accounts will be deducted directly from another client account. If there are insufficient funds available in another client account or our firm believes that deducting the advisory fee from another client account would be prohibited by applicable law, our firm will invoice the client directly. Other Types of Fees & Expenses: You may pay custodial fees, charges imposed directly by a mutual fund, index fund, or exchange traded fund which shall be disclosed in the fund’s prospectus (i.e., fund management fees, 12b- 1 fees, and other fund expenses), mark-ups and mark-downs, spreads paid to market makers, wire transfer fees and other fees and taxes on brokerage accounts and securities transactions. These fees are not included within the wrap-fee you are charged by our firm. Please note, we do not recommend or offer the wrap program services of other providers. You will also be charged fees for trades executed away from our recommended custodian. Our recommended custodian, Schwab, does not charge transaction fees for U.S. listed equities, exchange traded funds, and options (subject to $0.65 per contract fee). This means that, in most cases, when we buy and sell these types of securities, we will not have to pay any commissions to Schwab. We encourage you to review Schwab’s pricing to compare the total costs of entering into a wrap fee arrangement versus a non-wrap fee arrangement. If you choose to enter into a wrap fee arrangement, your total cost to invest could exceed the cost of paying for brokerage and advisory services separately. To see what you would pay for transactions in a non-wrap account please refer to Schwab’s most recent pricing schedules available at schwab.com/aspricingguide. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 5 California Capital Management  Item 5: Account Requirements & Types of Clients We have the following types of clients: • Individuals and High Net Worth Individuals; • Trusts, Estates or Charitable Organizations; • Pension and Profit Sharing Plans; • Corporations, limited liability companies and/or other business types. We generally require a minimum household account balance of $500,000 for the Wrap Comprehensive Portfolio Management service. This minimum is negotiable and generally required throughout the course of the client’s relationship with our firm. We may waive the account minimum for family members of current clients and for clients who will likely accumulate enough assets to exceed the account balance minimum. Item 6: Portfolio Manager Selection & Evaluation Our firm does not utilize outside portfolio managers. All accounts are managed by our in-house professionals. Advisory Business: See Item 4 for information about our wrap fee advisory program. We offer individualized investment advice to clients utilizing our Wrap Comprehensive Portfolio Management service. Each client has the opportunity to place reasonable restrictions on the types of investments to be held in the portfolio. Restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Restrictions would be limited to our Wrap Comprehensive Portfolio Management service. We do not manage assets through our other services. Participation in Wrap Fee Programs: We only offer wrap fee accounts to our clients, which are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. We do not manage non-wrap fee accounts. Performance-Based Fees & Side-By-Side Management: We do not charge performance fees to our clients. Methods of Analysis, Investment Strategies & Risk of Loss: We customize portfolios based on the individual client timeframe, risk tolerance and financial goals. We do not primarily recommend any particular method of analysis or strategy or any particular type of security. Methods of Analysis: • Charting • Fundamental ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 6 California Capital Management  • Technical • Cyclical Investment Strategies we use: • Long term purchases (securities held at least a year) • Short term purchases (securities sold within a year) • Trading (securities sold within 30 days) • Margin Transactions • Option writing, including covered options, uncovered options or spreading strategies CCM specializes in the following areas: • • • • Investment management process that seeks to create a balance between potential investment return and risk over the target investment time frame. This typically involves using a mix of the securities described immediately above. Investment management approach that employs quantitative analysis, technical analysis, fundamental analysis, and other disciplines, which are considered together to make decisions. Investment management focusing on multiple time frames, i.e. long-term strategies, intermediate-term strategies and short-term strategies. Depending on the specific situation, this may involve having CCM employ a variety of risk-management strategies, including short-term trading, stop orders, index options, option writing (protective put options, covered options, uncovered options or spreading strategies) and holding above- normal cash balances. CCM feels that the variety of risk-management tools it has at its disposal, and its dedication to considering them as needed, is one of CCM’s differentiating features in the investment advisory marketplace. Investment Management specializing in selection of mutual funds, Exchange Traded Funds (ETFs), Closed-End Funds, equities, fixed income instruments, options, cash equivalents. Other investments, available presently or created at a later date, may also be used in accounts and funds managed or sub-advised by CCM. CCM typically prefers to invest in securities that offer daily liquidity for the majority of the client portfolio investments. Illiquid investments, such as non-traded REITS and non-traded BDC’s, if used at all, do not exceed more than thirty percent of a typical client investment portfolio. Types of Investments: Based upon the request of an entity or individual who is a Wrap Comprehensive Portfolio Management client, CCM will utilize or offer advice on all types of securities, provided that CCM believes it can offer a reasonable opinion based on its investment experience and acumen. The following are some of the general categories of securities CCM can advise. • Exchange-listed securities • Securities traded over-the-counter • Exchange Traded Funds (ETFs) • Foreign issues • Warrants • Corporate debt securities (other than commercial paper) • Commercial paper • Certificates of deposit • Municipal securities ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 7 California Capital Management  • Asset Allocation among investments offered within Variable Annuities (but not the evaluation of any non-investment management aspects of annuities or other insurance products) Interests in partnerships investing in real estate, and oil and gas interests • Mutual fund shares • United States government securities • Options contracts on securities and commodities • Futures contracts on tangibles and intangibles • • Managed futures When providing Wrap Comprehensive Portfolio Management Services, it is not CCM’s typical investment strategy to attempt to time the market (which we define as moving from a fully invested position to a 100% cash position) but we may increase cash holdings modestly as deemed appropriate, based on your risk tolerance and our expectations of market behavior. Risk of Loss: Clients must understand that past performance is not indicative of future results. Therefore, current and prospective clients should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. Clients and prospective clients should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, CCM is unable to represent, guarantee, or even imply that its services and methods of analysis or other unaffiliated, third-party investment advisors can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated when investing in securities through CCM’s investment management programs or other unaffiliated third-party investment advisors. Market Risk: Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. 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. Company Risk: When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. ETF and Mutual Fund Risk: When the client is invested in an ETF or mutual fund, it will bear additional expenses based on its prorated share of the ETFs or mutual fund’s operating expenses, ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 8 California Capital Management  including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Management Risk: Your investment with our firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. Foreign Investment Risk: Foreign investing involves risks not typically associated with U.S. investments, including adverse fluctuations in foreign currency values, adverse political, social and economic developments, less liquidity, greater volatility, less developed or less efficient trading markets, political instability and differing auditing and legal standards. Investing in emerging markets imposes risks different from, or greater than, risks of investing in foreign developed countries. Foreign Currency Risk: Currency market risk results from the price movement of foreign currency values in response to shifting market supply and demand. Interest rate risk arises whenever a country changes its stated interest rate target associated with its currency. Country risk arises because virtually every country has interfered with international transactions in its currency. Interference has taken the form of regulation of the local exchange market, restrictions on foreign investment by residents or limits on inflows of investment funds from abroad. Restrictions on the exchange market or on international transactions are intended to affect the level or movement of the exchange rate. This risk could include the country issuing a new currency, effectively making the "old" currency worthless. Interest Rate Risk: Debt securities have varying levels of sensitivity to changes in interest rates. In general, the price of a debt security may fall when interest rates rise. Securities with longer maturities may be more sensitive to interest rate changes. Certain corporate bonds and mortgage- backed securities may be significantly affected by changes in interest rates. Some mortgage- backed securities may have a structure that makes their reaction to interest rates and other factors difficult to predict, making their value highly volatile. Because zero coupon securities do not make interest payments, they are considered more volatile than bonds making periodic payments. When interest rates rise, zero coupon securities fall more sharply than interest paying bonds. However, zero coupon securities rise more rapidly in value when interest rates drop. Options (Derivatives Risk): Even a small investment in options may give rise to leverage risk, and can have a significant impact on the accounts’ performance. Derivatives are subject to credit risk and liquidity risk. Voting Client Securities: We do not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 7: Client Information Provided to Portfolio Manager(s) We are required to describe the information about you that we communicate to your portfolio manager(s), and how often or under what circumstances we provide updated information. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 9 California Capital Management  Because we do not utilize outside portfolio managers, and all accounts are managed by our in- house professionals, we do not share any of your personal information with outside portfolio managers. Item 8: Client Contact with Portfolio Manager(s) Clients are always free to directly contact their portfolio manager(s) with any questions or concerns they have about their portfolios or other matters. Item 9: Additional Information Disciplinary Information We have no legal or disciplinary events to disclose that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Financial Industry Activities & Affiliations Certain representatives of our firm are registered representatives with Purshe Kaplan Sterling Investments, Inc. In such capacity, they may offer securities and receive normal and customary commissions as a result of securities transactions. This presents a conflict of interest to the extent that they recommend that a client invest in a security which results in a commission being paid to them. Bradley J. Salo is a licensed insurance agent through numerous insurance companies. In such a capacity, he may offer insurance products and receive normal and customary commissions as a result of such a purchase. This presents a conflict of interest to the extent that he recommends the purchase of an insurance product which results in a commission being paid to him as an insurance agent. He spends 10% of their time on these activities. Code of Ethics, Participation or Interest in Client Transactions & Personal Trading We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts1. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment advisor is considered a fiduciary. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying 1 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 10 California Capital Management  principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. Review of Accounts We review accounts on at least an annual basis for our clients subscribing to our Wrap Comprehensive Portfolio Management service. The nature of these reviews is to determine whether clients’ accounts are in line with their investment objectives, appropriately positioned based on market conditions, and investment policies, if applicable. Only our Financial Advisors or Portfolio Managers will conduct reviews. We may review client accounts more frequently than described above. Among the factors which may trigger an off-cycle review are major market or economic events, the client’s life events, requests by the client, etc. We provide performance reporting to clients. Verbal reports to clients take place on at least an annual basis when we meet with clients who subscribe to our Wrap Comprehensive Portfolio Management service. Client Referrals & Other Compensation We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described within I tem 12 – Brokerage Practices of the Form ADV Part 2A – Firm Brochure. The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Such compensation arrangements will not result in higher costs to the referred client. In this regard, our firm maintains a written agreement with each unaffiliated person that is compensated for testimonials or endorsements in an aggregate amount of $1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following information will be disclosed clearly and prominently to referred prospective clients at the time of each testimonial or endorsement: • Whether or not the unaffiliated person is a current client of our firm, • A description of the cash or non-cash compensation provided directly or indirectly by our firm to the unaffiliated person in exchange for the referral, if applicable, and • A brief statement of any material conflicts of interest on the part of the unaffiliated person giving the referral resulting from our firm’s relationship with such unaffiliated person. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 11 California Capital Management  Financial Information We are not required to provide financial information in this Brochure because: • We do not require the prepayment of more than $1,200 in fees and six or more months in advance. • We do not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. • We have never been the subject of a bankruptcy proceeding. ADV Part 2A, Appendix 1 – Wrap Fee Brochure Page 12 California Capital Management 

Form ADV Part 2A: Firm Brochure Item 1: Cover Page February 2026 2520 West Olive Avenue Suite 300 Burbank, CA 91505 Firm Contact: Khrysten Baltazar Chief Compliance Officer www.calcapmgt.com This brochure provides information about the qualifications and business practices of Consolidated Capital Management, LLC dba California Capital Management. If you have any questions about the contents of this brochure, please contact us by telephone at 818-766-0660 or by email at kbaltazar@calcapmgt.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. You are encouraged to review this Brochure and Brochure Supplements for our firm’s associates who advise you for more information on the qualifications of our firm and our employees. Please note that the use of the term “registered investment advisor” or being “registered” does not imply a certain level of skill or training. Additional information about California Capital Management also is available on the SEC’s website at www.advisorinfo.sec.gov by searching CRD# 130734. ADV Part 2A – Firm Brochure Page 1 California Capital Management  Item 2: Material Changes California Capital Management is required to advise you of any material changes to our Firm Brochure (“Brochure”) from our last annual update. We must state clearly that we are only discussing material changes since the last annual update of our Brochure, and we must also provide the date of the last annual update. Since our last annual amendment filed on 02/27/2025, we have the following material change(s) to disclose: • We have designated Khrysten Baltazar as our firm’s new Chief Compliance Officer. ADV Part 2A – Firm Brochure Page 2 California Capital Management  Item 3: Table of Contents Section: Page(s): Item 1: Cover Page ....................................................................................................................... 1 Item 2: Material Changes .............................................................................................................. 2 Item 3: Table of Contents .............................................................................................................. 3 Item 4: Advisory Business ............................................................................................................ 4 Item 5: Fees and Compensation .................................................................................................. 5 Item 6: Performance-Based Fees and Side-By-Side Management ............................................. 6 Item 7: Types of Clients and Account Requirements ................................................................... 6 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ....................................... 7 Item 9: Disciplinary Information .................................................................................................. 10 Item 10: Other Financial Industry Activities and Affiliations ....................................................... 10 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading 10 Item 12: Brokerage Practices ..................................................................................................... 12 Item 13: Review of Accounts ..................................................................................................... 17 Item 14: Client Referrals and Other Compensation ................................................................... 17 Item 15: Custody ........................................................................................................................ 18 Item 16: Investment Discretion .................................................................................................. 18 Item 17: Voting Client Securities ................................................................................................ 19 Item 18: Financial Information .................................................................................................... 19 ADV Part 2A – Firm Brochure Page 3 California Capital Management  Item 4: Advisory Business A. Description of our advisory firm, including how long we have been in business and our principal owner(s). We are dedicated to providing individuals and other types of clients with a wide array of investment advisory services. Our firm was initially formed as a corporation in the State of California and later reorganized as a limited liability company in 2019. We have been in business as an investment advisor since 2004. Our firm is owned by Gregory J. Zedlar through his holding company (44%), Bradley Salo (44%), Emily Logan (5%), Alexis Cole through her holding company (5%), and Khrysten Baltazar (2%). B. Description of the types of advisory services we offer. Our Comprehensive Portfolio Management service is provided through our Wrap Fee Program. Retirement Plan Consulting: Our firm provides retirement plan consulting services to employer plan sponsors on an ongoing basis. Generally, such consulting services consist of assisting employer plan sponsors in establishing, monitoring and reviewing their company's participant-directed retirement plan. As the needs of the plan sponsor dictate, areas of advising may include: • Establishing an Investment Policy Statement – Our firm may assist in the development and/or review of a statement that summarizes the investment goals and objectives along with the broad strategies to be employed to meet the objectives. • Investment Options – Our firm will work with the Plan Sponsor to evaluate existing investment options and make recommendations for appropriate changes. • Asset Allocation and Portfolio Construction – Our firm may develop strategic asset allocation models to aid Participants in developing strategies to meet their investment objectives, time horizon, financial situation and tolerance for risk. • Investment Monitoring – Our firm will monitor the performance of the investments and notify the client in the event of over/underperformance and in times of market volatility. • Participant Education – Our firm will provide opportunities to educate plan participants about their retirement plan offerings, different investment options, and general guidance on allocation strategies. In providing services for retirement plan consulting, our firm does not provide any advisory services with respect to the following types of assets: employer securities, real estate (excluding real estate funds and publicly traded REITS), participant loans, non-publicly traded securities or assets, other illiquid investments, or brokerage window programs (collectively, “Excluded Assets”). All retirement plan consulting services shall be in compliance with the applicable state laws regulating retirement consulting services. This applies to client accounts that are retirement or other employee benefit plans (“Plan”) governed by the Employee Retirement Income Security Act of 1974, as amended (“ERISA”). If the client accounts are part of a Plan, and our firm accepts appointment to provide services to such accounts, our firm acknowledges its fiduciary standard within the meaning of Section 3(21) or 3(38) of ERISA as designated by the Retirement Plan Consulting Agreement with respect to the provision of services described therein. ADV Part 2A – Firm Brochure Page 4 California Capital Management  C. Explanation of whether (and, if so, how) we tailor our advisory services to the individual needs of clients, whether clients may impose restrictions on investing in certain securities or types of securities. (i) Individual Tailoring of Advice to Clients: We offer individualized investment advice to all of our clients. (ii) Ability of Clients to Impose Restrictions on Investing in Certain Securities or Types of Securities: Clients have the opportunity to place reasonable restrictions on the types of investments to be held in their portfolio. However, restrictions on investments in certain securities or types of securities may not be possible due to the level of difficulty this would entail in managing the account. Restrictions would be limited to our Wrap Fee Program. D. Participation in wrap fee programs. We offer a wrap fee program as further described in Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”) of our Brochure. Our wrap fee accounts are managed on an individualized basis according to the client’s investment objectives, financial goals, risk tolerance, etc. E. Disclosure of the amount of client assets we manage on a discretionary basis and the amount of client assets we manage on a non-discretionary basis as of December 31, 2025. We managed $358,371,683 on a discretionary basis and $0 on a non-discretionary basis. Item 5: Fees and Compensation We are required to describe our brokerage, custody, fees and fund expenses so you will know how much you are charged and by whom for our advisory services provided to you. Our fees are generally negotiable at the discretion of our firm. Wrap Comprehensive Portfolio Management Fees Wrap fee clients will receive our Form ADV, Part 2A, Appendix 1 (the “Wrap Fee Program Brochure”). Wrap fee clients will not incur transaction costs for trades. More information about this is disclosed in our separate Wrap Fee Program Brochure. Retirement Plan Consulting Fees Our Retirement Plan Consulting services are billed based on a percentage of Plan assets under management. Fees will not exceed 1.50%. The fee-paying arrangements will be determined on a case-by-case basis and will be detailed in the signed consulting agreement. ADV Part 2A – Firm Brochure Page 5 California Capital Management  Termination & Refunds We charge our advisory fees quarterly in advance. In the event that you wish to terminate our services, we will refund the unearned portion of our advisory fee to you. Upon receipt of your notice of termination, we reserve the option to liquidate your assets prior to the transfer in order to protect our proprietary investment strategies and decisions. An exception would be made for any legacy investments the client brought with them. We would then proceed to close out your account(s) and process a prorated refund of any unearned advisory fees. Commissionable Securities Sales Certain representatives of our firm sell securities for a commission. In order to sell securities for a commission, some of our supervised persons are registered representatives of Purshe Kaplan Sterling Investments, Inc., member FINRA/SIPC. Our supervised persons may accept compensation for the sale of securities or other investment products, including distribution or service (“trail”) fees from the sale of mutual funds. You should be aware that the practice of accepting commissions for the sale of securities: 1) Presents a conflict of interest and gives our firm and/or our supervised persons an incentive to recommend investment products based on the compensation received, rather than on your needs. We generally address commissionable sales conflicts that arise: a) when explaining to clients that commissionable securities sales creates an incentive to recommend products based on the compensation we and/or our supervised persons may earn and may not necessarily be in the best interests of the client; b) when recommending commissionable mutual funds, explaining that “no-load” funds are available through our firm if the client wishes to become an investment advisory client. 2) In no way prohibits you from purchasing investment products recommended by us through other brokers or agents which are not affiliated with us. Item 6: Performance-Based Fees and Side-By-Side Management We do not charge performance fees to our clients. Item 7: Types of Clients and Account Requirements We have the following types of clients: • Individuals and High Net Worth Individuals; • Trusts, Estates or Charitable Organizations; • Pension and Profit Sharing Plans; • Corporations, Limited Liability Companies and/or Other Business Types. Please see our Wrap Fee Program Brochure for our requirements for opening and maintaining accounts or otherwise engaging us. ADV Part 2A – Firm Brochure Page 6 California Capital Management  Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss We customize portfolios based on the individual client time horizon, risk tolerance and financial goals. We do not primarily recommend any particular method of analysis or strategy or any particular type of security. Methods of Analysis: • Charting • Fundamental • Technical • Cyclical Investment Strategies we use: • Long term purchases (securities held at least a year) • Short term purchases (securities sold within a year) • Trading (securities sold within 30 days) • Option writing, including covered options, uncovered options or spreading strategies CCM specializes in the following areas: • An Investment management process that seeks to create a balance between potential investment return and risk over the target investment time frame. This typically involves using a mix of the securities described immediately above. • • • An Investment management approach that employs quantitative analysis, technical analysis, fundamental analysis, and other disciplines, which are considered together to make decisions. Investment management focusing on multiple time frames, i.e. long-term strategies, intermediate-term strategies and short-term strategies. Depending on the specific situation, this may involve having CCM employ a variety of risk-management strategies, including short-term trading, stop orders, index options, option writing (protective put options, covered options, uncovered options or spreading strategies), and holding above- normal cash balances. CCM feels that the variety of risk-management tools it has at its disposal, and its dedication to considering them as needed, is one of CCM’s differentiating features in the investment advisory marketplace. Investment Management specializing in selection of mutual funds, Exchange Traded Funds (ETFs), Closed-End Funds, equities, fixed income instruments, options, cash equivalents. Other investments, available presently or created at a later date, may also be used in accounts and funds managed or sub-advised by CCM. CCM typically prefers to invest in securities that offer daily liquidity for the majority of the client portfolio investments. Illiquid investments, such as non-traded REITS and non-traded BDC’s, if used at all, do not exceed more than thirty percent of a typical client investment portfolio. Types of Investments: Based upon the request of an entity or individual who is a Wrap Comprehensive Portfolio Management client, CCM will utilize or offer advice on all types of securities, provided that CCM believes it can offer a reasonable opinion based on its investment experience and acumen. The following are some of the general categories of securities CCM can advise. • Exchange-listed securities • Securities traded over-the-counter ADV Part 2A – Firm Brochure Page 7 California Capital Management  • Exchange Traded Funds (ETFs) • Foreign issues • Warrants • Corporate debt securities (other than commercial paper) • Commercial paper • Certificates of deposit • Municipal securities • Asset Allocation among investments offered within Variable Annuities (but not the evaluation of any non-investment management aspects of annuities or other insurance products) Interests in partnerships investing in real estate, and oil and gas interests • Mutual fund shares • United States government securities • Options contracts on securities and commodities • Futures contracts on tangibles and intangibles • • Managed futures When providing Wrap Comprehensive Portfolio Management Services, it is not CCM’s typical investment strategy to attempt to time the market (which we define as moving from a fully invested position to a 100% cash position), but we may increase cash holdings modestly as deemed appropriate, based on your risk tolerance and our expectations of market behavior. Risk of Loss: Clients must understand that past performance is not indicative of future results. Therefore, current and prospective clients should never assume that future performance of any specific investment or investment strategy will be profitable. Investing in securities (including stocks, mutual funds, and bonds) involves risk of loss. Further, depending on the different types of investments there may be varying degrees of risk. Clients and prospective clients should be prepared to bear investment loss including loss of original principal. Because of the inherent risk of loss associated with investing, CCM is unable to represent, guarantee, or even imply that its services and methods of analysis or other unaffiliated, third- party investment advisors can or will predict future results, successfully identify market tops or bottoms, or insulate you from losses due to market corrections or declines. There are certain additional risks associated when investing in securities through CCM’s investment management programs or other unaffiliated third-party investment advisors. Market Risk: Either the stock market as a whole, or the value of an individual company, goes down resulting in a decrease in the value of client investments. This is also referred to as systemic risk. 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. Company Risk: When investing in stock positions, there is always a certain level of company or industry specific risk that is inherent in each investment. This is also referred to as ADV Part 2A – Firm Brochure Page 8 California Capital Management  unsystematic risk and can be reduced through appropriate diversification. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. For example, if a company’s employees go on strike or the company receives unfavorable media attention for its actions, the value of the company may be reduced. ETF and Mutual Fund Risk: When the client is invested in an ETF or mutual fund, it will bear additional expenses based on its prorated share of the ETFs or mutual fund’s operating expenses, including the potential duplication of management fees. The risk of owning an ETF or mutual fund generally reflects the risks of owning the underlying securities the ETF or mutual fund holds. Management Risk: Your investment with our firm varies with the success and failure of our investment strategies, research, analysis and determination of portfolio securities. If our investment strategies do not produce the expected returns, the value of the investment will decrease. Foreign Investment Risk: Foreign investing involves risks not typically associated with U.S. investments, including adverse fluctuations in foreign currency values, adverse political, social and economic developments, less liquidity, greater volatility, less developed or less efficient trading markets, political instability and differing auditing and legal standards. Investing in emerging markets imposes risks different from, or greater than, risks of investing in foreign developed countries. Foreign Currency Risk: Currency market risk results from the price movement of foreign currency values in response to shifting market supply and demand. Interest rate risk arises whenever a country changes its stated interest rate target associated with its currency. Country risk arises because virtually every country has interfered with international transactions in its currency. Interference has taken the form of regulation of the local exchange market, restrictions on foreign investment by residents or limits on inflows of investment funds from abroad. Restrictions on the exchange market or on international transactions are intended to affect the level or movement of the exchange rate. This risk could include the country issuing a new currency, effectively making the "old" currency worthless. Interest Rate Risk: Debt securities have varying levels of sensitivity to changes in interest rates. In general, the price of a debt security may fall when interest rates rise. Securities with longer maturities may be more sensitive to interest rate changes. Certain corporate bonds and mortgage-backed securities may be significantly affected by changes in interest rates. Some mortgage-backed securities may have a structure that makes their reaction to interest rates and other factors difficult to predict, making their value highly volatile. Because zero coupon securities do not make interest payments, they are considered more volatile than bonds making periodic payments. When interest rates rise, zero coupon securities fall more sharply than interest paying bonds. However, zero coupon securities rise more rapidly in value when interest rates drop. Options (Derivatives Risk): Even a small investment in options may give rise to leverage risk, and can have a significant impact on the accounts’ performance. Derivatives are subject to credit risk and liquidity risk. ADV Part 2A – Firm Brochure Page 9 California Capital Management  Item 9: Disciplinary Information We have no legal or disciplinary events to disclose that are material to a client’s or prospective client’s evaluation of our advisory business or the integrity of our management. Item 10: Other Financial Industry Activities and Affiliations A. Our firm or our management persons are registered, or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. The details are as follows: Certain representatives of our firm are registered representatives with Purshe Kaplan Sterling Investments, Inc. In such capacity, they may offer securities and receive normal and customary commissions as a result of securities transactions. This presents a conflict of interest to the extent that they recommend that a client invest in a security which results in a commission being paid to them. B. Description of any relationship or arrangement that is material to our advisory business or to our clients, that we or any of our management persons have with any related person1 listed below. Furthermore, we are required to identify the related person and describe whether the relationship or arrangement creates a material conflict of interest with clients. Bradley J. Salo is a licensed insurance agent through numerous insurance companies. In such a capacity, he may offer insurance products and receive normal and customary commissions as a result of such a purchase. This presents a conflict of interest to the extent that he recommends the purchase of an insurance product which results in a commission being paid to him as an insurance agent. He spends 10% of his time on these activities. C. If we recommend or select other investment advisors for our clients and we receive compensation directly or indirectly from those advisors, or we have other business relationships with those advisors, we are required to describe these practices and discuss the conflicts of interest these practices create and how we address them. We have determined we have nothing to disclose in this regard. Item 11: Code of Ethics, Participation or Interest in Client Transactions, and Personal Trading A. Brief description of our Code of Ethics adopted pursuant to SEC rule 204A-1 and offer to provide a copy of our Code of Ethics to any client or prospective client upon request. 1 Our Related Persons are any advisory affiliates and any person that is under common control with our firm. Advisory Affiliate: Our advisory affiliates are (1) all of our officers, partners, or directors (or any person performing similar functions); (2) all persons directly or indirectly controlling or controlled by us; and (3) all of our current employees (other than employees performing only clerical, administrative, support or similar functions). Person: A natural person (an individual) or a company. A company includes any partnership, corporation, trust, limited liability company (“LLC”), limited liability partnership (“LLP”), sole proprietorship, or other organization. ADV Part 2A – Firm Brochure Page 10 California Capital Management  We recognize that the personal investment transactions of members and employees of our firm demand the application of a high Code of Ethics and require that all such transactions be carried out in a way that does not endanger the interest of any client. At the same time, we believe that if investment goals are similar for clients and for members and employees of our firm, it is logical and even desirable that there be common ownership of some securities. Therefore, in order to prevent conflicts of interest, we have in place a set of procedures (including a pre-clearing procedure) with respect to transactions effected by our members, officers and employees for their personal accounts2. In order to monitor compliance with our personal trading policy, we have a quarterly securities transaction reporting system for all of our associates. Furthermore, our firm has established a Code of Ethics which applies to all of our associated persons. An investment advisor is considered a fiduciary. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest of each of our clients at all times. We have a fiduciary duty to all clients. Our fiduciary duty is considered the core underlying principle for our Code of Ethics which also includes Insider Trading and Personal Securities Transactions Policies and Procedures. We require all of our supervised persons to conduct business with the highest level of ethical standards and to comply with all federal and state securities laws at all times. Upon employment or affiliation and at least annually thereafter, all supervised persons will sign an acknowledgement that they have read, understand, and agree to comply with our Code of Ethics. Our firm and supervised persons must conduct business in an honest, ethical, and fair manner and avoid all circumstances that might negatively affect or appear to affect our duty of complete loyalty to all clients. This disclosure is provided to give all clients a summary of our Code of Ethics. However, if a client or a potential client wishes to review our Code of Ethics in its entirety, a copy will be provided promptly upon request. B. If our firm or a related person invests in the same securities (or related securities, e.g., warrants, options or futures) that our firm or a related person recommends to clients, we are required to describe our practice and discuss the conflicts of interest this presents and generally how we address the conflicts that arise in connection with personal trading. See Item 11A of this Brochure. Related persons of our firm may buy or sell securities and other investments that are also recommended to clients. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. C. If our firm or a related person recommends securities to clients, or buys or sells securities for client accounts, at or about the same time that you or a related person buys or sells the same securities for our firm’s (or the related person's own) account, we are required to describe our practice and discuss the conflicts of interest it presents. We are also required to describe generally how we address conflicts that arise. See Item 11A of this brochure. Related persons of our firm may buy or sell securities for themselves at or about the same time they buy or sell the same securities for client accounts. In order to minimize this conflict of interest, our related persons will place client interests ahead of their own interests and adhere to our firm’s Code of Ethics, a copy of which is available upon request. 2 For purposes of the policy, our associate’s personal account generally includes any account (a) in the name of our associate, his/her spouse, his/her minor children or other dependents residing in the same household, (b) for which our associate is a trustee or executor, or (c) which our associate controls, including our client accounts which our associate controls and/or a member of his/her household has a direct or indirect beneficial interest in. ADV Part 2A – Firm Brochure Page 11 California Capital Management  Item 12: Brokerage Practices A. Description of the factors that we consider in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). We do not maintain custody of your assets on which we advise (although we may be deemed to have custody of your assets if you give us third party money movement authority or the authority to withdraw assets from your account (see Item 15 below). Your assets must be maintained in an account at a “qualified custodian,” generally a broker-dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a FINRA-registered broker-dealer, member SIPC, as the qualified custodian. We are independently owned and operated and not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as custodian/broker, you will decide whether to do so and open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you. Even though your account is maintained at Schwab, we can still use other brokers to execute trades for your account, as described in the next paragraph. We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are overall most advantageous when compared to other available providers and their services. It is noted that clients may pay higher or lower commissions than another qualified broker dealer might charge to effect similar transactions where we determine in good faith that the commission is reasonable in relation to the value of the brokerage and research services received. 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’s services, including the value of research provided, execution capability, commission rates, and responsiveness. Accordingly, although we will seek competitive rates, to the benefit of all clients, we may not necessarily obtain the lowest possible commission rates for specific client account transactions. We consider a wide range of factors, including, among others, these: • combination of transaction execution services along with asset custody services (generally without a separate fee for custody) • capability to execute, clear and settle trades (buy and sell securities for your account) • capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • breadth of investment products made available (stocks, bonds, mutual funds, exchange traded funds (ETFs), etc.) • availability of investment research and tools that assist us in making investment decisions • quality of services • competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them reputation, financial strength and stability of the provider their prior service to us and our other clients • • • availability of other products and services that benefit us, as discussed below in Item 12A1(b) ADV Part 2A – Firm Brochure Page 12 California Capital Management  For our clients’ accounts it maintains, Schwab may charge you separately for custody services but will not charge you commissions or other fees on trades that it executes or that settle into your Schwab account. In addition to commissions, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. 1. Research and Other Soft Dollar Benefits. If we receive research or other products or services other than execution from a broker-dealer or a third party in connection with client securities transactions (“soft dollar benefits”), we are required to disclose our practices and discuss the conflicts of interest they create. Please note that we must disclose all soft dollar benefits we receive, including, in the case of research, both proprietary research (created or developed by the broker-dealer) and research created or developed by a third party. Schwab offers to independent investment Advisors non-soft dollar services which include custody of securities, trade execution, clearance and settlement of transactions. We receive some non-soft dollar benefits from Schwab through our participation in the program. a. Explanation of when we use client brokerage commissions (or markups or markdowns) to obtain research or other products or services, and how we receive a benefit because our firm does not have to produce or pay for the research, products or services. As part of the arrangement described in Item12A1, Schwab also makes certain research and brokerage services available at no additional cost to our firm. These services include certain research and brokerage services, including research services obtained by Schwab directly from independent research companies, as selected by our firm (within specific parameters). Research products and services provided by Schwab to our firm may include research reports on recommendations or other information about, particular companies or industries; economic surveys, data and analyses; financial publications; portfolio evaluation services; financial database software and services; computerized news and pricing services; quotation equipment for use in running software used in investment decision-making; and other products or services that provide lawful and appropriate assistance by Schwab to our firm in the performance of our investment decision-making responsibilities. The aforementioned research and brokerage services are used by our firm to manage accounts for which we have investment discretion. Without this arrangement, our firm might be compelled to purchase the same or similar services at our own expense. b. Incentive to select or recommend a broker-dealer based on our interest in receiving the research or other products or services, rather than on our clients’ interest in receiving best execution. Schwab Advisor Services™ (formerly called Schwab Institutional) is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to its institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or ADV Part 2A – Firm Brochure Page 13 California Capital Management  administer our clients’ accounts while others help us manage and grow our business. Schwab’s support services described below are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us as long as we keep a total of at least $50 million of the assets of our firm’s advisory clients in accounts at Schwab. The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. As described below, however, the availability to us of some third party products and services is contingent on our clients placing a specified amount of assets in accounts at Schwab. Here is a more detailed description of Schwab’s support services: Services that Benefit You. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that May Not Directly Benefit You. Schwab also makes available to us other products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: • provide access to client account data (such as duplicate trade confirmations and • account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; facilitate payment of our fees from our clients’ accounts; and • provide pricing and other market data; • • assist with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: technology, compliance, legal, and business consulting; • educational conferences and events; • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, it will arrange for third- party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment of our personnel. The availability of the services described above from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services so long as we keep a total of at least $50 million of client assets in accounts at Schwab. ADV Part 2A – Firm Brochure Page 14 California Capital Management  This required amount of client assets may give us an incentive to require that you maintain your account with Schwab based on our interest in receiving Schwab’s and the third parties’ services that benefit our business rather than based on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a potential conflict of interest. We believe, however, that our selection of Schwab as custodian and broker is in the best interests of our clients. It is primarily supported by the scope, quality and price of Schwab’s services and not Schwab’s or third parties’ services that benefit only us or may only indirectly benefit you. c. Causing clients to pay commissions (or markups or markdowns) higher than those charged by other broker-dealers in return for soft dollar benefits (known as paying-up). We do not recommend other brokers or dealers to execute trades and transactions for client accounts. With the exception of fixed income and fixed income alternative transactions, all trades and transactions are executed through Schwab. For fixed income and fixed income alternative trades, our firm participates in prime brokerage services provided by PKS. As the introducing broker-dealer, PKS shall transmit orders to National Financial Services, LLC (“NFS”) for the execution of trades pursuant to Prime Brokerage Services with Schwab. Pursuant to the Prime Brokerage Services Agreement with Schwab, we will transmit to Schwab and PKS all the details of each prime brokerage transaction to be cleared by NFS for our account, including, but not limited to, the contract amount, the security involved, and the number of shares or number of units. d. Disclosure of whether we use soft dollar benefits to service all of our clients’ accounts or only those that paid for the benefits, as well as whether we seek to allocate soft dollar benefits to client accounts proportionately to the soft dollar credits the accounts generate. Although the investment research products and services that may be obtained by our firm will generally be used to service all of our clients, a brokerage commission paid by a specific client may be used to pay for research that is not used in managing that specific client’s account. e. Description of the types of products and services our firm or any of our related persons acquired with client brokerage commissions (or markups or markdowns) within our last fiscal year. We do not acquire client brokerage commissions (or markups or markdowns). f. Explanation of the procedures we used during our last fiscal year to direct client transactions to a particular broker-dealer in return for soft dollar benefits we received. We do not receive any soft dollar relationships and do not direct client transactions to a particular broker-dealer in return for soft dollar benefits. 2. Brokerage for Client Referrals. If we use client brokerage to compensate or otherwise reward brokers for client referrals, we must disclose this practice, the conflicts of interest it creates, and any procedures we used to direct client brokerage to referring brokers during the last fiscal year (i.e., the system of controls used by us when allocating brokerage). ADV Part 2A – Firm Brochure Page 15 California Capital Management  Our firm does not receive brokerage for client referrals. 3. Directed Brokerage. a. If we routinely recommend, request or require that a client directs us to execute transactions through a specified broker-dealer, we are required to describe our practice or policy. Further, we must explain that not all advisors require their clients to direct brokerage. If our firm and the broker-dealer are affiliates or have another economic relationship that creates a material conflict of interest, we are further required to describe the relationship and discuss the conflicts of interest it presents by explaining that through the direction of brokerage we may be unable to achieve best execution of client transactions, and that this practice may cost our clients more money. In certain instances, clients may seek to limit or restrict our discretionary authority in making the determination of the brokers with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are effected. Any such client direction must be in writing (often through our advisory agreement), and may contain a representation from the client that the arrangement is permissible under its governing laws and documents, if this is relevant. We provide appropriate disclosure in writing to clients who direct trades to particular brokers, that with respect to their directed trades, they will be treated as if they have retained the investment discretion that we otherwise would have in selecting brokers to effect transactions and in negotiating commissions and that such direction may adversely affect our ability to obtain best price and execution. In addition, we will inform you in writing that your trade orders may not be aggregated with other clients’ orders and that direction of brokerage may hinder best execution. b. If we permit a client to direct brokerage, we are required to describe our practice. If applicable, we must also explain that we may be unable to achieve best execution of your transactions. Directed brokerage may cost clients more money. For example, in a directed brokerage account, you may pay higher brokerage commissions because we may not be able to aggregate orders to reduce transaction costs, or you may receive less favorable prices on transactions. We generally do not allow client-directed brokerage. B. Discussion of whether, and under what conditions, we aggregate the purchase or sale of securities for various client accounts in quantities sufficient to obtain reduced transaction costs (known as bunching). If we do not bunch orders when we have the opportunity to do so, we are required to explain our practice and describe the costs to clients of not bunching. We perform investment management services for various clients. There are occasions on which portfolio transactions may be executed as part of concurrent authorizations to purchase or sell the same security for numerous accounts served by our firm, which involve accounts with similar investment objectives. Although such concurrent authorizations potentially could be either advantageous or disadvantageous to any one or more particular accounts, they are affected only when we believe that to do so will be in the best interest of the effected accounts. When such concurrent authorizations occur, the objective is to allocate the executions in a manner which is deemed equitable to the accounts involved. In any given situation, we attempt to allocate trade executions in the most equitable manner possible, taking into consideration client objectives, ADV Part 2A – Firm Brochure Page 16 California Capital Management  current asset allocation and availability of funds using price averaging, proration and consistently non-arbitrary methods of allocation. Item 13: Review of Accounts Investment advisor representatives perform reviews of investment advisory accounts no less than annually. Accounts are reviewed for consistency with the investment strategy and performance among other things. Reviews may be triggered by changes in an account holder’s personal, tax, or financial status. Please reference our Wrap Fee Program Brochure for further information regarding reviews of accounts. Retirement Plan Consulting clients receive reviews of their retirement plans for the duration of the service. Our firm also provides ongoing services where clients are met with upon their request to discuss updates to their plans, changes in their circumstances, etc. Retirement Plan Consulting clients do not receive written or verbal updated reports regarding their plans unless they choose to engage our firm for ongoing services. Item 14: Client Referrals and Other Compensation A. If someone who is not a client provides an economic benefit to our firm for providing investment advice or other advisory services to our clients, we must generally describe the arrangement. For purposes of this Item, economic benefits include any sales awards or other prizes. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors that have their clients maintain accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12 – Brokerage Practices). The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. B. If our firm or a related person directly or indirectly compensates any person who is not our employee for client referrals, we are required to describe the arrangement and the compensation. that is compensated for In accordance with Rule 206 (4)-1 of the Investment Advisers Act of 1940, our firm provides cash or non-cash compensation directly or indirectly to unaffiliated persons for testimonials or endorsements (which include client referrals). Such compensation arrangements will not result in higher costs to the referred client. In this regard, our firm maintains a written agreement with each unaffiliated person testimonials or endorsements in an aggregate amount of $1,000 or more (or the equivalent value in non-cash compensation) over a trailing 12-month period in compliance with Rule 206 (4)-1 of the Investment Advisers Act of 1940 and applicable state and federal laws. The following information will be disclosed clearly and prominently to referred prospective clients at the time of each testimonial or endorsement: • Whether or not the unaffiliated person is a current client of our firm, • A description of the cash or non-cash compensation provided directly or indirectly by our firm to the unaffiliated person in exchange for the referral, if applicable, and ADV Part 2A – Firm Brochure Page 17 California Capital Management  • A brief statement of any material conflicts of interest on the part of the unaffiliated person giving the referral resulting from our firm’s relationship with such unaffiliated person. Item 15: Custody All of our clients receive at least quarterly account statements directly from their custodians. Upon opening an account with a qualified custodian on a client's behalf, we promptly notify the client in writing of the qualified custodian's contact information. If we decide to also send account statements to clients, such notice and account statements include a legend that recommends that the client compare the account statements received from the qualified custodian with those received from our firm. The SEC issued a no‐action letter (“Letter”) with respect to the Rule 206(4)‐2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our custodian, Schwab: • The client provides an instruction to the qualified custodian, in writing, that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed. • The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time. • The client’s qualified custodian performs appropriate verification of the instruction, such as a signature review or other method to verify the client’s authorization, and provides a transfer of funds notice to the client promptly after each transfer. • The client has the ability to terminate or change the instruction to the client’s qualified custodian. • The investment adviser has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction. • The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser. • The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Item 16: Investment Discretion We maintain discretion over certain client accounts. Our clients need to sign a discretionary investment advisory agreement with our firm for the management of their account. This type of agreement only applies to our Wrap Comprehensive Portfolio Management clients. We do not take or exercise discretion with respect to our other clients. ADV Part 2A – Firm Brochure Page 18 California Capital Management  Item 17: Voting Client Securities We do not accept the proxy authority to vote client securities. Clients will receive proxies or other solicitations directly from their custodian or a transfer agent. In the event that proxies are sent to our firm, we will forward them on to you and ask the party who sent them to mail them directly to you in the future. Clients may call, write or email us to discuss questions they may have about particular proxy votes or other solicitations. Item 18: Financial Information We are not required to provide financial information in this Brochure because: • We do not require the prepayment of more than $1,200 in fees and six or more months in advance. • We do not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients. • We have never been the subject of a bankruptcy proceeding. ADV Part 2A – Firm Brochure Page 19 California Capital Management