CAMBRIDGE CAPITAL MANAGEMENT, LLC

Item 1 – Cover Page Part 2A of Form ADV: Firm Brochure CAMBRIDGE CAPITAL MANAGEMENT, LLC 781 Sunset Blvd., Suite 100 O’Fallon, IL 62269 Telephone: (618) 206-3262 Facsimile: (618) 589-8989 E-mail: nklitzing@camcapmgt.com Web: www.camcapmgt.com August 28, 2025 This brochure provides information about the qualifications and business practices of Cambridge Capital Management, LLC (hereinafter “CCM” or “firm”). If you have any questions about the contents of this brochure, please contact us at (618) 206-3262 or at nklitzing@camcapmgt.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. information about CCM is available on Additional the SEC’s website at www.adviserinfo.sec.gov . You can search this site by a unique identifying number, known as a CRD number. The CRD number for CCM is 110932. 1  Item 2. Summary of Material Changes Material Changes Annual Update The Material Changes section of this brochure will be updated when material changes occur since the previous release of the Firm Brochure. Material Changes since the Last Update There have been no material changes since the Firm’s last annual update amendment of February 14, 2025; however, the Firm has elected to no longer vote proxies for any clients as of August 15, 2025. Full Brochure Available We will ensure that you receive a summary of material changes, if any, to this and subsequent disclosure brochures within 120 days after our fiscal year ends. If you would like to receive a complete copy of our Firm Brochure, please contact us by telephone at: 618-206-3262 or by email at: nklitzing@camcapmgt.com. We may also provide other ongoing disclosure information about material changes as necessary. 2  Item 3. Table of Contents Item 1 Cover Page ...................................................................................................................... 1 Item 2. Summary of Material Changes ........................................................................................ 2 Item 3. Table of Contents ............................................................................................................ 3 Item 4. Advisory Business ........................................................................................................... 4 Item 5. Fees and Compensation ................................................................................................... 8 Item 6. Performance-Based Fees and Side-By-Side Management ............................................ 11 Item 7. Types of Clients............................................................................................................. 11 Item 8. Methods of Analysis, Investment Strategies and Risk of Loss ..................................... 11 Item 9. Disciplinary Information ............................................................................................... 13 Item 10. Other Financial Industry Activities and Affiliations ..................................................... 13 Item 11. Code of Ethics, Participation in Client Transactions and Personal Trading ................. 13 Item 12. Brokerage Practices ....................................................................................................... 14 Item 13. Review of Accounts ...................................................................................................... 16 Item 14. Client Referrals and Other Compensation..................................................................... 16 Item 15. Custody .......................................................................................................................... 16 Item 16. Investment Discretion ................................................................................................... 17 Item 17. Voting Client Securities ................................................................................................ 17 Item 18. Financial Information .................................................................................................... 17 3  Item 4. Advisory Business Cambridge Capital Management, LLC (hereinafter referred to as "CCM") has been in business since 1999. We are an investment adviser registered with the SEC. Our principal place of business is in O’Fallon, Illinois. We also hold client meetings by appointment only at a St. Louis, Missouri office. Nathaniel W. Klitzing is the Managing Member and sole owner of the Firm. As of December 31, 2024, CCM managed $354,353,966 in assets on a discretionary basis and $30,808,311 on a non-discretionary basis for a total of $385,162,277 in assets under management. Investment Management Services CCM is in the business of managing individually tailored investment portfolios. Our firm provides continuous advice to a client regarding the investment of client funds based on the individual needs of the client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, we develop a client's personal investment policy or an investment plan with an asset allocation target and create and manage a portfolio based on that policy and allocation target. During our data-gathering process, we determine the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. We may also review and discuss a client’s prior investment history, as well as family composition and background. We manage advisory accounts on a discretionary basis. Meaning, for these accounts, we implement transactions without seeking prior client consent. When CCM is providing investment management services to an account held at a client’s employer sponsored retirement plan we exercise non-discretionary authority only. In these circumstances, we obtain the consent of the client before conducting a transaction in the account. In the event that CCM’s investment management services include assets held at a client’s employer sponsored retirement plan, CCM’s management is limited to the scope of the plan’s selections and restrictions. For assets in these “Held Away Account(s)” CCM does not accept discretionary authority to effect transactions and will not have, nor will it accept, any authority to make or effect any disbursements or transfers of assets. The client is solely responsible for implementing CCM’s recommendations for assets in a Held Away Account. Account supervision is guided by the stated objectives of the client (i.e., Capital Preservation, Conservative, Conservative Growth, Moderate, Moderate Growth, Growth, Full Growth), as well as tax considerations. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. Financial Planning/Consulting Services We also provide general financial planning to you as part of our Investment Management service if requested. Normally this service is provided to investment management clients without any additional fees. 4  The focus of financial planning is to assist the client in defining personal financial planning goals and objectives to be pursued in the areas of business planning, children’s education, retirement planning, estate planning, tax planning, and investments, and to supply an analysis and recommendations as to the actions and investment strategies necessary to attain these goals and objectives. The client is not obliged to follow recommendations made during the financial planning process, it is solely up to the client to implement any advice, strategy, or recommendation made in a financial plan. For individuals wishing to receive financial planning not a part of investment management the Firm may be engaged to provide a comprehensive evaluation of a client’s current and future financial state by using currently known variables to predict future cash flows, asset values and withdrawal plans. The key defining aspect of this service is that through the process, all questions, information, and analysis will be considered as they impact and are impacted by the entire financial and life situation of the client. Clients will receive a written or an electronic report, providing the client with a detailed financial plan designed to achieve his or her stated financial goals and objectives. This service is subject to a flat fee based upon the scope and complexity of the engagement. The fee will be disclosed in the agreement signed by the Client prior to the start of the engagement. Clients can also receive investment advice on a more limited basis. This may include advice on asset allocation to participants in self-directed retirement plans or an isolated area(s) of concern such as investment strategy, estate planning, retirement planning, or any other specific topic. Retirement Plan Consulting Services We offer services to both plan sponsors and participants of retirement benefit plans. Plan Design and Provider Consulting. We may assist with various aspects of the plan design. We evaluate bundled or unbundled retirement plan service providers, including record keepers, third party administrators, trustees, custodians, investment companies and legal and accounting professionals. Investment Services. We offer assistance in creating and establishing a plan’s asset allocation and in evaluating, and monitoring investment options. This may include reviewing appropriate investment options for the plan, asset classes and investment styles, evaluating and recommending investment managers, types, and selection of investment options. We may also conduct periodic reviews of the plan’s investments to evaluate performance, risk characteristics and expenses and recommend changes where appropriate. Employee Education Services. We provide services to help plan participants choose an appropriate deferral rate and investment selection by holding enrollment meetings and providing online or printed educational materials to encourage participation and help employees choose appropriate deferral rates and investment elections. We may also work directly with plan 5  participants to help them evaluate their retirement savings goals and implement appropriate contribution amounts and investments available in the plan. In the event a client contracts with CCM for one-on-one consulting services such as, providing education or information on plan options and benefits to plan participants, those services are consultative in nature and do not involve CCM implementing recommendations in individual participant accounts and are not fiduciary in nature. It is the responsibility of each participant to implement changes in the participant’s individual accounts. We can also meet with individual participants to discuss their specific investment risk tolerance, investment time frame and investment selections. Fiduciary Services. To assist plan sponsors in fulfilling their ERISA fiduciary responsibilities, we may compare a plan’s services, investments, features and fees against those of comparable plans in similar-sized organizations, provide educational resources to help plan sponsors understand and meet their fiduciary obligations and provide detailed listings and explanations of all fees paid by the plan and participants to service providers and identify appropriate opportunities for cost savings. The following services are considered fiduciary consulting services: Investment Policy Statement Development and Refinement Investment Reviews • Plan Design Consulting • • Asset Allocation • Manager Evaluation and Selection • Performance Monitoring and Reporting • Qualified Default Investment Alternative Evaluation and Recommendation • • Participant Advisory Services • Model Portfolios CCM acknowledges that in performing the fiduciary consulting services listed above that it is acting as a “fiduciary” as such term is defined under Section 3(21)(A)(ii) of the Employee Retirement Income Security Act of 1974 (“ERISA”) for purposes of providing non-discretionary investment advice only. Advisor acts in a manner consistent with the requirements of a fiduciary under ERISA if, based upon the facts and circumstances, such services cause Advisor to be a fiduciary as a matter of law. However, in providing the fiduciary consulting services, Advisor (a) has no responsibility and does not (i) exercise any discretionary authority or discretionary control respecting management of the client’s retirement plan, (ii) exercise any authority or control respecting management or disposition of assets of the client’s retirement plan or (iii) have any discretionary authority or discretionary responsibility in the administration of the client’s retirement plan or the interpretation of retirement plan documents, (b) is not an “investment manager” as defined in Section 3(38) of ERISA and does not have the power to manage, acquire or dispose of any plan assets and (c) is not the “Administrator” of the client’s retirement plan as defined in ERISA. 6  The following services are considered non-fiduciary services: • Plan Provider Consulting • Employee Enrollment Meetings • Participant Education • Plan Benchmarking • Fiduciary Education • Fee Reporting and Analysis All recommendations of investment options and portfolios are submitted to the client for ultimate approval or rejection. Therefore, it is always the client’s responsibility to make changes to the plan itself. CCM does not serve as administrator or trustee of the plan. CCM does not act as custodian for any client account or have access to client funds or securities (with the exception of some accounts having written authorization from the client to deduct our fees). In addition, we do not implement any transactions in a retirement plan or participant’s account. For retirement plan consulting services, the retirement plan or the plan participant who elects to implement any recommendations made by us is solely responsible for implementing all transactions. CCM will disclose to you, to the extent required by ERISA Regulation Section 2550.408b-2(c), any change to the information that we are required to disclose under ERISA Regulation Section 2550.408b-2(c)(1)(iv) as soon as practicable, but no later than sixty (60) days from the date on which we are informed of the change (unless such disclosure is precluded due to extraordinary circumstances beyond our control, in which case the information will be disclose as soon as practicable). Services in General CCM hereby acknowledges that it is a "fiduciary" when the firm’s services are subject to the provisions of ERISA of 1974, as amended. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Our investment, financial planning and consulting recommendations are not limited to any specific product or service offered by a broker dealer or insurance company. While we reserve the right to offer advice on any product that may be suitable for each client’s specific circumstances, needs, goals and objectives, our advice primarily involves the following instruments: • Exchange-listed securities 7  • Exchange traded funds (ETFs) • “No-load” or “load-waived” mutual funds • Corporate debt securities Occasionally, we may also recommend or advise on investments in the following instruments: • Certificates of deposit • Municipal securities • Commercial paper • United States government securities • Variable Annuities We tailor our investment management and consulting recommendations to the individual needs of each client. All such recommendations are tailored based on information gathered through client questionnaires, electronic communications, telephone and in-person discussions. We believe in dollar-cost averaging, which means spreading the purchase of securities over time to achieve the lowest average cost. Termination of Agreements Clients have five (5) business days from the date of signing an advisory agreement with CCM to unconditionally rescind the agreement and receive a full refund of all fees. Thereafter, the client may terminate an agreement by providing written notice to our principal place of business. Upon termination, any prepaid unearned fees are promptly refunded, and any earned, unpaid fees are due and payable. CCM will typically pro rate the investment management services fee from date of termination for the time remaining in the current quarter. CCM has a right to terminate any agreement upon reasonable notice to the client. Upon termination, any unearned prepaid fees will be promptly refunded to the client, and any earned unpaid fees are immediately due and payable. Item 5. Fees and Compensation Investment Management Services Our fees for Investment Management Services are based upon a percentage of assets under management, in accordance with the following fee schedule: Assets Under Management ($) Annual Fee (%) First $250,000 Next $500,000 $750,000 to $2,000,000 1.25% 1.00% 0.75% 8  $2,000,000 to $7,500,000 Above $7,500,000 0.50% 0.40% For investment management services on assets held at an employer sponsored retirement plan CCM charges an annual fee of 0.40%. Investment management fees are charged, in advance, at the beginning of each quarter, based upon the net value of the assets in the client’s account(s) on the last business day of the previous quarter. Depending on the arrangement with each client, we either invoice clients or directly debit their custodial accounts for investment management fees. If fees are deducted from the account, the client must provide the account custodian with written authorization to have the fees deducted and paid to us. Prior to any fees being deducted (and at the same time a billing statement is sent to the custodian), we send the client a fee billing notice showing the amount deducted, how the fee is calculated and any adjustments to the fee with an explanation of any such adjustments. At least quarterly, the custodian sends clients a statement showing all disbursements from the account, including advisory fees deducted. If fees are paid directly, payment is due upon receipt of our billing statement. Retirement Plan Consulting Services The annual fee for retirement plan consulting services will be charged as a percentage of the total plan assets. Fees are negotiable based on criteria such as plan size, number of plan participants, average participant account balance, number of business locations, etc. When a client contracts with CCM for one-on-one consulting services such as, providing education or information on plan options and benefits to plan participants, those services are charged on an hourly fee basis. In most of the time the fee is not expected to be higher than 1.00% of the total plan assets. Plan sponsors can elect to pay any or all of the fees for services provided to plan participants. Clients can elect to have fees billed directly or deducted from the plan assets. If the client is billed directly, fees are billed in advance and a detailed billing invoice is sent quarterly. Fees are calculated based on the plan asset value as of the beginning of each quarter. If fees are deducted from the plan account, the client must provide written authorization to the plan custodian for fees to be deducted from the account and paid directly to us. Prior to any fees being deducted (and at the same time a billing statement is sent to the custodian), we send the client a fee billing notice showing the amount deducted, the manner in which the fee is calculated, any adjustments to the fee and an explanation of any such adjustments. Fees are calculated on a daily accrual basis and billed monthly in arrears. If fees are paid directly, payment is due upon receipt of our billing statement. 9  Financial Planning/Consulting Services For clients receiving only our financial planning services, we charge on a flat fee basis. Fees vary based on the complexity of the plan or project and the range of services we are retained to provide. Before services are rendered, we will provide the client with the amount of the fee which is specified in the Client agreement. We may require an advance deposit before the work begins with the balance of the fee due and payable upon completion of the service. The deposit amount is noted in the agreement the client signs. Typically, we present a financial plan to the client within 90 days of the contract date, provided that all information needed to prepare the plan has been promptly provided to us by the client. Fees in General Fees for investment management and financial planning/consulting services are negotiable based upon certain criteria (i.e., anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be managed, related accounts, account composition, negotiations with client, etc.). Discounts, not generally available to our advisory clients, may be offered to family members. We may group certain related client accounts for the purposes of determining the account size and/or annualized fee. Certain legacy client agreements may be governed by fee schedules different from those listed above. Under no circumstances will we require fees be paid in excess of $1,200 and more than six months in advance of services rendered. Account Termination Clients have a period of five (5) business days from the date of signing the agreement to unconditionally rescind the agreement and receive a full refund of all fees. Thereafter, the client may terminate the agreement by providing us written notice at our principal place of business. Upon termination of any account, any prepaid, unearned fees are promptly refunded, and any earned, unpaid fees are due and payable. Mutual Fund and ETF Fees and Expenses: All fees paid to our firm for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. These fees and expenses are described in each fund's prospectus. These fees generally include a management fee, other fund expenses, and a possible distribution fee. A client could invest in a mutual fund or an ETF directly, without the services of our firm. In that case, the client would not receive the services provided by us which are designed, among other things, to assist the client in determining which mutual fund or funds or ETFs are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and ETFs and the fees charged by us to fully understand 10  the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Brokerage and Custodial Fees In addition to advisory fees paid to our firm, clients are also responsible for all transaction, brokerage, trade-away and custodial fees incurred as part of their account management. Please see Item 12 of this Brochure for important disclosures regarding our brokerage practices. Item 6. Performance-Based Fees and Side-By-Side Management We do not charge any fees based on a share of capital gains on or capital appreciation of the assets of a client. Item 7. Types of Clients Our firm generally provides advisory services to individuals, pension and profit-sharing plans, trusts, estates, charitable organizations, corporations, and other business entities. We require a minimum of $500,000 in assets under management to establish an account with us. However, at our sole discretion, we may grant an exception to this minimum based upon a client’s history and relationship with Advisor as well as other current or anticipated advisory services provided by us to the client. Item 8. Methods of Analysis, Investment Strategies and Risk of Loss Our firm employs the following types of analysis to formulate client recommendations: Asset Allocation: Rather than focusing primarily on securities selection, we attempt to identify an appropriate ratio of securities, fixed income and cash suitable to the client’s investment goals and risk tolerance. A risk of asset allocation is that the client may not participate in sharp increases in a particular security, industry or market sector. Another risk is that the ratio of securities, fixed income, and cash changes over time due to stock and market movements and, if not corrected, may no longer be appropriate for the client’s goals. Model Asset Allocation in Portfolio Construction We use model asset allocations in our portfolio management that represent different levels of risk. Seven model asset allocations have been established using sectors and subsets of asset types and investment vehicles. Each asset allocation portfolio consists of mutual funds and exchange traded funds that are both actively and passively managed. Mutual funds and exchange traded funds are selected on their ability to fulfill a role in the portfolio and to some extent, their cost. Fundamental Analysis: Fundamental analysis of a business involves analyzing its income statement, financial statements and health, its management and competitive advantages, and its 11  competitors and markets. Fundamental analysis school of thought maintains that markets may misprice a security in the short run but that the "correct" price is eventually reached. Profits can be made by trading the mis-priced security and then waiting for the market to recognize its "mistake" and re-price the security. However, fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market regardless of the economic and financial factors considered in evaluating the stock. Therefore, unforeseen market conditions and/or company developments may result in significant price fluctuations that can lead to investor losses. Mutual fund and/or ETF analysis: We look at the experience and track record of the manager of the mutual fund or ETF to determine if that manager has demonstrated an ability to invest over a period of time and in different economic conditions. We also look at the underlying assets in a mutual fund or ETF to determine if there is significant overlap in the underlying investments held in other funds in the client’s portfolio. We also monitor the funds or ETFs to determine if they are continuing to follow their stated investment strategy. Technical analysis. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and to potentially predict future price movement. Charting: In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when how long the trend may last and when that trend might reverse. Cyclical analysis: In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of the security. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may underperform regardless of market movement. Our firm employs the following investment strategy to implement investment advice given to clients: Long-term purchases: We mostly purchase securities with the idea of holding them in the clients account for a year or longer. We may do this because we believe the securities to be currently undervalued. We may do this because we want exposure to a particular asset class over time, regardless of the current projection for this class. Risks: Risks for all forms of analysis: Our securities analysis method relies on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. 12  A risk of mutual fund and/or ETF analysis is that, as in all securities investments, past performance does not guarantee future results. A manager who has been successful may not be able to replicate that success in the future. In addition, as we do not control the underlying investments in a fund or ETF, managers of different funds held by the client may purchase the same security, increasing the risk to the client if that security were to fall in value. There is also a risk that a manager may deviate from the stated investment mandate or strategy of the fund or ETF, which could make the fund or ETF less suitable for the client’s portfolio. A risk in a long-term purchase strategy is that, by holding the security for this length of time, we may not take advantage of short-term gains that could be profitable to a client. Moreover, if our predictions are incorrect, a security may decline sharply in value before we make the decision to sell. Dollar-cost averaging may miss out on low points in buying in favor of a long-term approach. Clients should understand that investing in any securities, including mutual funds and ETFs, involves a risk of loss of both income and principal that they should be prepared to bear. Item 9. Disciplinary Information Our firm has no reportable disciplinary events to disclose. Item 10. Other Financial Industry Activities and Affiliations Neither CCM nor any of its management persons are registered or have an application pending to register, as a broker-dealer or a registered representative of a broker-dealer. Neither CCM nor any of its management persons are registered or applying to become registered as a futures commission merchant, commodity pool operator, a commodity trading advisor, or an associated person of such. CCM does not recommend or select other investment advisers for its clients. Item 11. Code of Ethics, Participation in Client Transactions and Personal Trading Code of Ethics Disclosure Our firm has adopted a Code of Ethics which sets forth high ethical standards of business conduct that we require of our employees, including compliance with applicable federal and state securities laws. Our Code of Ethics includes policies and procedures for the review of quarterly securities transactions reports and provides for oversight, enforcement and recordkeeping provisions. A copy of our Code of Ethics is available to our advisory clients and prospective clients upon request to Nathaniel Klitzing, Chief Compliance Officer, at the firm’s principal office address. 13  Our firm or individuals associated with our firm may buy or sell securities identical to those recommended to or purchased for customers for their personal accounts. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. This practice results in a potential conflict of interest, as we may have an incentive to manipulate the timing of such purchases to obtain a better price or more favorable allocation in rare cases of limited availability. To mitigate these potential conflicts of interest and ensure the fulfillment of our fiduciary responsibilities, we have established the following restrictions: 1. No principal or employee of our firm may buy or sell securities for their personal portfolio(s) where their decision is substantially derived, in whole or in part, by reason of his or her employment unless the information is also available to the investing public on reasonable inquiry. No principal or employee of our firm may prefer his or her own interest to that of the advisory client. 2. It is the expressed policy of our firm that no person employed by us may purchase or sell any security prior to a transaction(s) being implemented for an advisory account, and therefore, preventing such employees from benefiting from transactions placed on behalf of advisory accounts. 3. We do not aggregate employee trades with client trades. 4. We maintain a list of all securities holdings for our firm, and anyone associated with this advisory practice with access to advisory recommendations. 5. We emphasize the unrestricted right of the client to decline to implement any advice rendered, except in situations where our firm is granted discretionary authority. 6. All our principals and employees must act in accordance with all applicable Federal and State regulations governing registered investment advisory practices; and 7. Any individual not in observance of the above may be subject to disciplinary action or termination. Item 12. Brokerage Practices We do not have any formal soft-dollar arrangements. However, our firm participates in the Schwab Institutional (SI) services program offered to independent investment advisers by Charles Schwab & Company, Inc. (“Schwab”), a FINRA-registered broker dealer. We recommend Schwab to clients needing brokerage and custodial services. While there is no direct linkage between the investment advice given and participation in the SI program, economic benefits are received which would not be received if our firm did not give investment advice to clients. These benefits include: receipt of duplicate client confirmations and bundled duplicate statements; access to a trading desk 14  serving SI participants exclusively; access to block trading which provides the ability to aggregate securities transactions and then allocate the appropriate shares to client accounts; ability to have investment advisory fees deducted directly from client account; access, for a fee, to an electronic communication network for client order entry and account information; receipt of compliance publications; and access to mutual funds which generally require significantly higher minimum initial investments or are generally available only to institutional investors. The benefits received through participation in the SI program may or may not depend upon the amount of transactions directed to, or the amount of assets held at Schwab. Participation in the SI program results in a potential conflict of interest for our firm, as the receipt of the above benefits creates an incentive for us to use Schwab for the execution of client trades. Nonetheless, we have reviewed the services of Schwab and recommend the services based on a number of factors. These factors include the professional services offered, commission rates, and the custodial platform provided to clients. We periodically attempt to negotiate lower commission rates for our clients with Schwab. If we decide to use another broker dealer to execute a client trade due to better availability, liquidity, or pricing, Schwab charges an additional trade-away fee for each such trade. Therefore, we only use this trade-away ability in situations with compelling financial reasons. We do not request or accept the discretionary authority to determine the broker dealer to be used for client accounts. Clients must direct us to the broker dealer to be used for all client securities transactions. In directing the use of a particular broker or dealer, it should be understood that we will not have authority to negotiate commissions among various brokers, and best execution may not be achieved, resulting in higher transaction costs for clients. Not all advisers require their clients to direct brokerage. When undertaking an advisory relationship with our firm, if a client already has a pre-established relationship with a broker and instructs us to execute all transactions through that broker, it should be understood that under those circumstances we do not have the authority to negotiate commissions, obtain volume discounts and best execution may not be achieved. In addition, under these circumstances a disparity in commission charges may exist between the commissions charged to other clients since our firm may not be able to aggregate orders to reduce transaction costs or the client may receive less favorable prices. We reserve the right to decline acceptance of any client account for which the client directs the use of a broker if we believe that this choice would hinder its fiduciary duty to the client and/or its ability to service the account. Trade Aggregation In some instances, an adviser may be able to obtain better prices and lower execution costs for its clients if it aggregates (also known as bunching or block trading) multiple smaller orders into one large order. Most client trades are in mutual funds and ETFs where trade aggregation does not garner the client a material benefit. We will aggregate client trades when doing so is materially 15  advantageous to our clients. If we determine that aggregating trades in a certain situation is beneficial to our clients, transactions are averaged as to price and are allocated among our clients in proportion to the purchase and sale orders placed from each client account on any given day. Any exceptions from the pro-rata allocation procedure are carefully explained and documented. Such exceptions may occur due to varying cash availability across accounts, divergent investment objectives and existing concentrations, and desire to avoid “odd lots,” (an amount of a security that is less than the normal unit of trading for that particular security). Item 13. Review of Accounts Investment Management Services We continuously monitor the underlying securities in client accounts and perform regular reviews of account holdings for all clients. Accounts are reviewed for consistency with client investment strategy, asset allocation, risk tolerance and performance relative to the appropriate benchmark. More frequent reviews may be triggered by changes in an account holder’s personal, tax or financial status. Political, geopolitical, and macroeconomic specific events may also trigger reviews. Clients receive monthly or quarterly statements and confirmations of transactions from their broker dealer and/or custodian. Our firm sends additional quarterly reports showing portfolio positions, cost basis and performance compared to relevant index benchmarks. Financial Planning/Consulting Services We also review these client relationships as contracted for at the inception of the relationship. We provide Financial Planning clients with a completed financial plan and do not typically provide additional reports unless otherwise contracted for at the inception of the advisory relationship. For those clients engaging us for consulting services, we do not provide any ongoing reviews or reports beyond those specifically outlined in the advisory agreement(s). Item 14. Client Referrals and Other Compensation Our firm does not receive any additional compensation from third parties for providing investment advice to its clients. Item 15. Custody Custody is defined as any legal or actual ability by our firm to access client funds or securities. Since we directly debit client fees from their custodial accounts, our firm is deemed to have constructive custody of client funds. The client approves the custodian to be used and the commission rates paid to the custodian. All assets are held at qualified custodians, which means 16  the custodians provide account statements directly to clients at their address of record at least quarterly. We urge all our management clients to carefully review and compare their quarterly reviews of account holdings and/or performance results received from us to those account statements they receive from their account custodian. Should you notice any discrepancies, please notify us and/or your custodian as soon as possible. Due to the use of Standing Letters of Authorization (“SLOA’s”), the firm is deemed to have constructive custody of assets. The Firm follows the SEC guidance set forth in the SEC’s No Action Letter of February 21, 2017, and maintains records required to avoid the additional audit requirements for advisers with custody. The firm does not accept physical custody of client funds or securities as a matter of policy and practice. Item 16. Investment Discretion For clients granting us discretionary authority to determine which securities and the amounts of securities that are to be bought or sold for their account(s), such authority must be granted in writing, typically in the executed investment management agreement. Should the client wish to impose reasonable limitations on this discretionary authority, such limitations will be included in this written authority statement. Clients may change/amend these limitations as desired. Such amendments must be submitted to us by the client in writing. Item 17. Voting Client Securities Cambridge Capital Management does not accept proxy voting responsibility for any client. Clients retain the sole responsibility for all proxy decisions and voting. Clients will receive proxy statements directly from their custodian(s). Cambridge Capital Management will have no power, authority, responsibility, or obligation to take any action with regard to any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise, or monitor class action or other litigation involving client assets Item 18. Financial Information Under no circumstances do we require prepayment of fees in excess of $1,200 and for more than six months in advance of services rendered. 17