Cape Investment Advisory, Inc.

Cape Investment Advisory, Inc. Cape Investment Advisory Wrap Fee Program Part 2A Appendix 1of Form ADV: Wrap Fee Disclosure Brochure 1600 Pennsylvania Ave. McDonough, GA 30253 (678) 583-1120 March 31, 2026 This wrap fee program brochure provides information about the qualifications and business practices of Cape Investment Advisory, Inc. If you have any questions about the contents of this brochure, please contact us at (678) 583-1120. The information contained in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Cape Investment Advisory also is available on the SEC’s website at www.adviserinfo.sec.gov. 1  Item 2: Material Changes Statement provider • Wrap Fee Billing, who bills and frequencies • Custodians • • Ability to use MF’s in a portfolio • Removed info related to financial planning services Item 3: Table of Contents Item 1 : Cover Page ....................................................................................................................................................................... p. 1 Item 2 : Material Changes…………………………………………………………………………….……………...……………p. 2 Item 3: Table of Contents………………………………………………………………………………………………………p. 2 Item 4: Services, Fees, and Compensation……………………………………………………………………………………p. 3 Item 5: Account Requirements and Types of Clients……………………………………………………………………….….p. 5 Item 6: Portfolio Manager Selection and Evaluation……………………………………………………………………........p. 5 Item 7: Client Information Provided to Portfolio Managers…………………………………………………………….…….p. 7 Item 8: Client Contact with Portfolio Managers………………………………………………………………………….... p. 7 Item 9: Additional Information…………………………………………………………………………………………………p. 8 Item 10: Requirements for State Registered Advisers…………………………………………………………………………p.11 2  ITEM 4: SERVICES, FEES, AND COMPENSATION CAPE INVESTMENT ADVISORY WRAP PROGRAM CIA (“Sponsor”) offers a wrap-fee program to investment advisor representative (“IAR”) clients who use “Sponsor” as an RIA and an approved custodian (broker/dealer) for their managed assets. The program, known as the Cape Investment Advisory Wrap Program, is presented by Sponsor and IAR to the client. CIA Investment Advisory Representatives (“IAR”) act as portfolio manager to the Cape Investment Advisory Wrap Program. IAR’s work with clients to identify their investment goals and objectives as well as risk tolerance in order to create an initial portfolio allocation designed to complement the client’s financial situation and personal circumstances. Accounts are managed based on each client’s individual needs. The process begins through personal discussions between the IAR and the client to establish investment goals and gather information pertaining to the client’s financial situation, objectives, time horizon and risk tolerance. This information becomes the basis for determining and constructing the investment plan/asset allocation plan which the IAR and/or Advisor believe best meets the client’s long term stated goals. The investment plan contains assets in classes that CIA believes (based on historical data) will have attractive combinations of return, risk and correlation. In addition, CIA offers clients the opportunity to use services offered by third party money managers. Product recommendations under this platform may include but are not limited to, equities, corporate debt securities, municipals bonds, mutual funds, government securities, options, and alternative investments. Restrictions and guidelines imposed by clients effect the composition and performance of portfolios. For this reason, performance of portfolios within the same investment objective may differ. Advisory client assets are held and processed at an approved custodian (broker/dealer), Charles Schwab, , Hilltop Securities (HTS), and SEI. FEES Clients in the CIA Wrap Program pay an all-inclusive fee. Fee remittance is as described in the Advisory and/or Sub-Advisory agreement. Fees are generally billed by the Sub-Manager with a portion being remitted to CIA, or CIA and the Sub-Manager may bill their respective portions separately. Fees charged are calculated as an annual percentage of assets based on the market value of the account at the end of the calendar month or quarter. Fees are billed either monthly or quarter, in advance or in arrears, based on the number of days managed for that period. The level of the fee will vary with the amount of assets under management in the program and the particular investment style and investment alternatives chosen or recommended. Clients should note that the same or similar services may be available elsewhere at a lower or higher cost to the client. Clients should consider that depending upon the level of wrap fee charged, the amount of portfolio activity in their account(s), the value of services provided, and other factors, a wrap fee may exceed the aggregate cost of services if they were to be provided separately. A non-wrapped pricing arrangement may be more cost effective for accounts that do not experience frequent trading activity. CIA requires a minimum account of $25,000 for clients seeking investment management services; however, at the sole discretion of management, the minimum account value requirement may be waived. Below is the schedule of fees charged by CIA in connection with the Cape Investment Advisory Wrap Program. The fee charged is on the value of the funds in the advisory client’s account. All fees are negotiable at the discretion of CIA management. The annual fees are negotiable and based on assets under management as follows: Wrap Fee Option Wrap fee structures allow you to pay an all-inclusive fee which includes: 1. investment management fees shared by our firm, your advisory representatives, and, in some instances, the broker dealer of the advisory representative who is also a registered representative of the broker-dealer; 3  execution and clearing costs; transaction costs – if applicable – which may be paid to purchase and sell securities in your account; and custody fees. 2. 3. 4. The annual fees for the CIA Wrap Fee Program are negotiable and based on assets under management as follows: Asset Amount Execution, Clearing Fee* Up to 250K $250K --- $500K $500K --- $1M $1M --- $2M $2M--- $5M Above $5M Max. Client Fee 2.75% 2.50% 2.25% 1.95% 1.65% 1.35% .30 .30 .25 .20 .20 .15 Investment Management Fee (TPAM or AAM) 0---2.45% 0---2.20% 0---2.00% 0---1.75% 0---1.45% 0---1.20% *Minimum fee of $350. Execution, custodial, and clearing fee is included in Total Annual Advisory Fee. In certain circumstances the execution, custodial, and clearing fees may be negotiable at the discretion of CIA management. The asset-based fee is calculated at the end of the calendar month or quarter. The fee is based upon the value of the account as calculated by the custodian. Fees for the initial quarter will be adjusted pro-rata based upon the number of calendar days in the calendar quarter that the adviser agreement goes into effect. Any deposits or withdrawal of funds or securities within a billing period exceeding $25,000 are subject to the same billing process. As authorized in the Advisory Agreement, the account custodian withdraws advisory fees directly from the client’s account according to the custodian’s policies, practices and procedures. The custodian sends the client a statement, at least quarterly, indicating all the amounts disbursed from the account, including the amount of advisory fees. It is the client’s responsibility, not the custodian’s, to verify the accuracy of the billing amount. Advisor does not hold customer funds or securities. CIA will not have the authority to withdraw funds or take custody of client funds or securities other than where the client has authorized the deduction of investment advisory fees via a qualified custodian or at the request of Client to have money withdrawn from there brokerage account and sent to the address of record or an existing bank account registered to Client. OTHER ISSUES RELATING TO FEES The cost of investment advisory services provided through the programs may be more or less than the cost of purchasing similar services separately. Among the factors impacting the relative cost of the program to a particular Client are the choice of custodian, the size of the account, the type of account (i.e., equity or fixed income), the size of the assets devoted to a particular strategy, and the Sub-Managers selected. The minimum account size varies depending on the selected investment strategy. The program fee does not cover, and the Client will be additionally responsible and charged for: (i) (ii) (iii) (iv) (v) (vi) (vii) commissions, markups, markdowns, spreads and other transactional charges on securities transactions effected through, or with, brokers and dealers other than their custodian. interest on debit account balances, where applicable. the entire public offering price (including underwriting commissions or discounts) on securities purchased from an underwriter of dealer (including Charles Schwab) involved in a distribution of securities; bid-ask spreads. odd lot differentials. exchange fees, transfer taxes and other fees required by law; Individual Retirement Account fees, qualified retirement plan account fees and other account maintenance fees: and (viii) other fees that may be assessed by custodian in its capacity as broker and custodian upon notice to the Client. 4  (ix) Some portfolio strategies may invest in American Depository Receipts (“ADRs”) or foreign stocks listed on an U.S. stock exchange. ADRs are typically created, organized and administered by a U.S. bank. Generally, these banks charge a fee for their services (e.g., custody) and may deduct these fees from the dividends and other distributions generated from the ADR shares. In addition, banks incur expenses, such as converting foreign currency into U.S. dollars, and as a result may pass those expenses associated with the foreign stocks (such as foreign taxes) may also passed along to the shareholder. These fees and expenses are in addition to the above-mentioned Total Fee and Clearing Fees. ITEM 5: ACCOUNT REQUIREMENTS AND TYPES OF CLIENTS CIA provides discretionary and nondiscretionary investment advisory services for individuals, businesses, qualified pension and profit- sharing plans, individual retirement accounts, trusts, and other entities. CONDITIONS FOR MANAGING ACCOUNTS CIA generally requires a minimum relationship of $25,000 for clients seeking investment management services. This minimum may be waived based upon a pre-existing relationship or special client circumstances at the discretion of management. ITEM 6: PORTFOLIO MANAGER SELECTION AND EVALUATION The factors we consider when selecting TPAMs to recommend to clients include the TPAM’s: • management style, • performance record, • reputation, • pricing, and • reporting capabilities. TPAMs are evaluated using data and information from several sources, including the manager and independent databases. We also review the manager’s Form ADV Part 2, as well as portfolio holdings reports that help demonstrate the manager’s securities selection process. However, neither we nor a third party verifies the accuracy of performance information or compliance with performance standards. In recommending a TPAM to you, we consider your financial situation, risk tolerance, investment horizon, liquidity needs, tax considerations, investment objectives, and any other issues important to your state of affairs. Please notify us promptly if there are any changes in your financial situation or investment objectives or if you wish to impose any reasonable restrictions upon the management of your account. Our IARs can act as a portfolio manager for the CIA managed account program. We do not evaluate these portfolio managers in the same manner that we evaluate TPAMs as described above. You decide whether you want your IAR to manage your assets directly or whether your assets are managed by a third party. We do supervise your IAR as described in the brochure supplement we have provided to you. CIA offers and provides a combination of the following advisory services for individuals, businesses, qualified pension and profit-sharing plans, individual retirement accounts, trusts and other entities on a fee-only basis. Investment monitoring services • Discretionary Investment Management • Non discretionary investment management • The process begins through personal discussions between the Investment Advisor Representative (“IAR”) and pertaining to the client’s financial situation, the client to establish investment goals and gather information objectives, time horizon and risk tolerance. This information becomes the basis for determining and constructing the investment plan/asset allocation plan which the Advisor believes best meets the client’s long term stated goals. The client reserves the right to impose restrictions on investing in certain securities or types of securities so long as these restrictions are communicated to the Advisor in writing. The investment plan will contain assets in classes that CIA believes (based on historical data) will have attractive combinations of return, risk, and correlation. In addition, CIA offers clients the opportunity to use services offered by third party money managers as well as affiliated IAR’s. Discretionary Investment Management 5  We can provide discretionary portfolio management services to clients using a variety of standard and customized investment models. Each portfolio is designed to meet a particular investment objective. We can use this discretionary authority to buy and sell securities on your behalf per client agreements. We may also enter non-solicited trades at the client’s request. Nondiscretionary Investment Management CIA provides nondiscretionary portfolio management services to clients. IARs use the client’s investment objectives and risk tolerance when making recommendations to clients. Trades are entered only with the consent and approval of the client. We may also enter non-solicited trades at the client’s request. Investment Monitoring Services CIA offers monitoring services to both individual and institutional clients for both qualified and non-qualified accounts. We review asset allocation, the overall performance and that of the individual managers. Reviews are generally conducted on a quarterly basis, although the only requirement is for an annual review. Documentation and communication of the review will be determined between IAR and client. Broker Dealer Affiliation Disclosure CIA is affiliated with American Global Wealth Management, Inc.(“AGWM”), a registered broker/dealers Global Investment Advisory (GIA). Therefore, it may be common for the CIA representative to also serve as the AGWM registered representative for clients’ account(s). Third Party Asset Management and Affiliate Asset Management Advisor may recommend that clients engage certain Third Party Asset Managers (“TPAM”) or Affiliate Asset Managers (“AAM”) to manage all or a portion of their assets. Advisor will provide individualized advisory services to their clients through the selection of a suitable TPAM or AAM. Factors considered in the selection of a TPAM or AAM include but may not be limited to: i) the management style, performance, reputation, pricing and reporting capabilities of the AAM or TPAM; ii) the client’s risk tolerance, goals and objectives, as well as investment experience; and, iii) the amount of client assets available for investment. In order to assist clients in the selection of a TPAM or AAM, the IAR will typically gather information from the client about the client’s financial situation, investment objectives, and reasonable restrictions the client wants imposed on the management of the account. Advisor will contact the client at least annually, or more often as agreed upon with each client, to review the client’s financial situation and objectives, communicate information to the TPAM or AAM managing the account as warranted, and to assist the client in understanding and evaluating the services provided by the TPAM or AAM. Clients will be expected to notify their Advisor of any changes in their financial situation, investment objectives, or account restrictions. A complete description of the programs and services provided, the amount of total fees, the payment structure, termination provisions and other aspects of each program are detailed and disclosed in: i) the TPAM’s or AAM’s Form ADV Part II; ii) the program wrap brochure (if applicable) or other applicable disclosure documents; iii) the disclosure documents of the portfolio manager or managers selected; or, iv) the TPAM’s or AAM’s account opening documents. A copy of all relevant disclosure documents of the TPAM or AAM and of the individual portfolio manager(s) will be provided to anyone interested in these programs/managers. Compensation generally, consists of three elements: i) management and advisory fees shared by the TPAMs or AAMs, CIA, and its IARs; ii) transaction costs – if applicable – which may be paid to purchase and sell such securities; and iii) custody fees. Fees are assessed by the TPAM or AAM who in turn may pay a portion of the fee to CIA for services provided. The amount and timing of these fees varies depending on the TPAM or AAM. The client may elect to participate in a wrap fee account. The account will be managed similarly to non-wrap fee accounts. The primary difference in between a wrap account and non-wrap account is in the manner that the account is billed to the client. In a wrap fee account, clients are billed one inclusive fee that includes the cost of the advisor fee, portfolio management fee, platform fee, ticket charges, postage and handling charges. In a non-wrap account, the foregoing charges are assessed as separate charges. If a client elects to participate in a wrap fee account, an additional Wrap Fee Disclosure Brochure, Part 2A Appendix I, will be provided to the client. Please Note: When investing in mutual funds and variable annuities, clients are strongly encouraged to review the applicable prospectus. Mutual funds and variable annuities may impose certain restrictions on the frequency, 6  timing and dollar amount of transactions and may impose penalty fees based upon short-term trading patterns. Such restrictions may impact the services provided by a TPAM or AAM. INVESTMENT MANAGEMENT PROCESS CIA’s Portfolio Management team uses a number of analytical tools and commercially available optimization software applications in developing its asset allocation strategies. Among the factors considered in designing these strategies are historical rates of risk and return for various asset classed, correlation across asset classes and risk premiums. In some cases, CIA will use Sub-managers to construct a model portfolio that Advisor will use to invest Client assets. In some cases, Sub-Managers construct a model portfolio that CIA will use to invest Client assets. CIA may recommend investments in certain mutual funds or alternative investments, such as hedge funds and private equity funds, depending on an individual Client’s investment objectives and available assets for investment. The CIA Wrap Program is intended to comply with Rule 3a-4 under the investment Company Act of 1940. Each Client’s account is managed on the basis of the Client’s individual financial situation. Each Client has the opportunity to select the account’s investment objective and impose reasonable restrictions on the management of the assets in the account. In addition, Clients will be contacted annually and notified quarterly by their Advisor, in order to confirm the accuracy of this information. TYPES OF INVESTMENTS CIA selects and monitors the investment managers who make investment decisions. Through the Wrap Program, CIA evaluates Sub-Managers specializing in each of the asset categories listed, including equities (both domestic and foreign), ETF corporate debt, commercial paper, certificates of deposit, municipal securities, mutual funds, government securities, options and futures. CIA will recommend an asset allocation (and Sub-Managers within an asset category) based upon the Client’s needs and objectives. In some cases, Sub-Managers will supply CIA with a model portfolio and CIA will invest Client assets accordingly. PROXY VOTING & CLASS ACTION SUITS Client agrees that Advisor or Sub-Manager, as applicable, will not vote or advise you how to vote proxies for securities held in your account. The Custodian should promptly send you all proxies and related shareholder communications for the securities held in your account. If you are a plan fiduciary in the case of an account subject to the provisions of the Employee Retirement Income Security Act of 1974 [“ERISA”], you expressly retain the authority and responsibility for the voting of proxies. We are expressly precluded from rendering any advice or taking any action with respect to the voting of proxies. In addition, CIA will not take any action or render any advice with respect to any securities held in any accounts that are named in or subject to class action lawsuits. CIA will, however, forward to Client any information received by CIA regarding class action legal matters involving any security held in the account. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT CIA does not use Performance-Based Fees and Side-by-Side Management. Therefore, Item 6 is not applicable to CIA’s business model. ITEM 7: CLIENT INFORMATION PROVIDED TO PORTFOLIO MANAGERS Portfolio Managers may be provided with full disclosure of all client information that CIA has in its files. This information is updated as the client informs CIA of any changes to such information and may be given to Portfolio Managers accordingly. ITEM 8: CLIENT CONTACT WITH PORTFOLIO MANAGERS CIA places no restrictions on Client contact with portfolio managers. Clients have full access to RIA, IAR & it’s portfolio managers. 7  ITEM 9: ADDITIONAL INFORMATION DISCIPLINARY ACTIONS Two instances of inaccurately completing insurance applications: CIA has no Disciplinary Actions. But certain IAR’s have actions that are required to be disclosed, including: • Assault on a Peace Officer, a third-degree felony, which was dismissed at the hearing. • o o failure to disclose a felony conviction when a minor – Insurance license was issued with a twelve month probationary period and payment of a $150 fine; submission of two insurance applications with different responses – the inaccurate application was denied and the accurate one was issued. • Failure to supervise while a control person at an unaffiliated broker-dealer which resulted in being prohibited from serving in a Principal capacity at any broker-dealer for six months; and • A Civil Court order to repay credit card debt to the card issuer. Please review your IAR’s Form CRS that documents these situations and feel free to ask your IAR to discuss their background. BROKERAGE SERVICES Client authorizes Sponsor’s custodians as the broker of Client’s choice (“Broker”) for the Accounts to provide trade execution services as indicated in the Client Investment Advisory Agreement and Fee Disclosure. Broker will also be appointed to serve as custodian of the client assets. Services provided by Broker in this capacity are provided pursuant to a separate agreement between Client and Broker. Client acknowledges that by directing brokerage, Client may not receive best execution on transactions for the Accounts. Sub-Managers will have the authority to effect transactions for the Accounts with or through another broker, dealer, or bank if Advisor or Sub-Manager believes that “best execution” of transactions may be obtained through such other broker, dealer, or bank, including any broker/dealer that is affiliated with Advisor, Sponsor or Sub-Manager. Client acknowledges that it may be responsible for additional fees for portfolio transactions executed away from Sponsor’s custodian. Client agrees to furnish any such broker, dealer or bank such authorizations as any of them or Advisor may request to implement the provisions of the Agreement. instructs Broker to accept instructions from CIA and Sub-Managers to whom Advisor has delegated Client investment discretion by providing notice to the Broker in the form of the Broker/custodian application. Client authorizes CIA to open broker/dealer credit accounts at applicable executing brokers, and Client authorizes CIA as attorney- in-fact to give instructions to an appropriate broker. All transactions effected by Sub-Managers for Client’s Accounts shall be cleared and settled with the Broker. Sub-Managers may execute transactions through brokers, dealers and banks that have certain arrangements with Advisor, Sponsor and/or Sub-Managers pursuant to which Advisor, Sponsor or Sub- Managers receive credit (toward acquisition of research products and services) for brokerage placed with such firms by Advisor or Sub-Managers. When CIA or a Sub-Manager deems a transaction to be in the best interests of the Client, as well as other clients of CIA, Advisor or Sub-Manager, to the extent permitted by applicable law and regulation, Sponsor or Sub-Manager is permitted to aggregate multiple client orders to obtain what Sponsor, or Sub-Manager believes will be the most favorable price and/or lower execution costs at the time of execution. Neither Advisor, Sponsor nor any Sub-Manager will be responsible for any action or inaction taken by any third- party broker, dealer or bank, or any loss incurred by reason of any action or inaction of any broker, dealer or bank. Client authorizes Sponsor or Sub-Managers to instruct all brokers, dealers, and banks that effect transactions for or with the Accounts to forward confirmations of transactions for Client’s Accounts to the Sub-Managers, Platform Manager or Advisor. INVESTMENT OR BROKERAGE DISCRETION Clients who participate in Wrap programs may or may not grant discretionary trading authority to CIA. 8  REPORTS AND REVIEW OF ACCOUNTS CIA does not provide customized Client statements. These statements will come from the Client’s respective custodian. IARs are responsible for reviewing them with the Client at least annually and as market conditions warrant. It is recommended to clients that consistent periodic reviews be made to continually update client information and investment strategies as conditions warrant. The reviews focus on consistency of portfolio investments with investment objectives and risk tolerances. Other factors that may trigger a review include, but are not limited to, changes in market and economic conditions, known changes in the client’s financial situation and large deposits and/or withdrawals from the account. Clients receive confirmations on all transactions, as well as monthly (or quarterly if there is no account activity) statements from the custodian, which outline the clients’ current positions and current market value. TERMINIATION Client has the right to cancel this Agreement within five business days of the later of Advisor’s, Sponsor’s or Sub Manager’s acceptance by giving written notice of such cancellation to Advisor. In such event, any Fees paid by Client shall be refunded to Client, but Client shall be responsible for any transactions executed prior to Advisor’s receipt of the written cancellation notice. Thereafter, either party may cancel this Agreement at any time, for any reason, upon receipt of 30 days’ prior written notice. Clients will receive a pro-rated refund of any pre-paid quarterly Program Fee, based upon the number of days remaining in the quarter after the termination date. BUSINESS AFFILIATIONS AND CONFLICTS OF INTEREST Cape Insurance Solutions, Inc. (“CIS”) is a state licensed insurance agency which is under common ownership with CIA and is also directly owned by James R Webb. CIS sells life and fixed annuity products which may be offered to CIA clients. When doing so, this relationship may create a conflict of interest as IARs of CIA, as insurance agents, may also receive a sales-based commission as a CIS agent of the insurance product recommended. Advisory Clients are under no obligation to purchase insurance products through CIS. American Global Wealth Management, Inc. (“AGWM”) is a general securities broker/dealer registered with the SEC, FINRA, and various state regulatory agencies. AGWM is owned by American Global Wealth Services, Inc. (a holding company controlled by James R. Webb). In this capacity, AGWM executes trades (as agent) for a commission in mutual funds, EFT’s, equities, bonds, options, variable annuities and other investment products on behalf of clients, who may or may not have an Advisory Agreement with CIA. Key principals of CIA also function as officers and/or registered principals of AGWM. This relationship may create a conflict of interest, as AGWM may also be receiving commissions as the broker- dealer for effecting securities transactions which they may have recommended by IAR’s to Advisory Clients. IAR’s, as registered representatives of AGWM, may also earn brokerage commission from transactions generated from other brokerage account activity, including other brokerage accounts maintained for the Client. Advisory Clients are under no obligation to effect securities transactions through AGWM. 9  Global Investment Advisory, Inc. (GIA) is a state registered advisory firm and currently does not have any clients or assets under management. GIA is under sole control and owned by Jim R. Webb. CIA has certain arrangements with TPAMs whereby the TPAM provides CIA with remuneration for using their services which may present a conflict of interest in relation to the Client relationship. CIA addresses these conflicts of interest by only selecting qualified TPAMs that will competently manage Client assets regardless of the compensation CIA may receive. These arrangements are fully disclosed by CIA to the Client in the contract between CIA, Client, and TPAM. CIA may recommend Clients establish brokerage accounts with Hilltop Securities, Inc. (“HTS”), Charles Schwab & Co., Inc. (“Schwab”), ,, SEI, or another licensed custodian or FINRA registered broker-dealer, to maintain custody of Clients’ assets and to effect trades for their accounts. Although CIA may recommend Clients establish accounts at HTS, Schwab, TD, PMR, or SEI it is the client’s decision to custody assets at a broker-dealer of their choice. CIA is independently owned and operated and not affiliated with HTS, Schwab, or SEI. CIA and its investment personnel may give advice and take action in the performance of their duties to the wrap program clients, which differ from advice given, or the timing and nature of action taken, with respect to other clients’ accounts. In addition, CIA Representatives have an interest in minimizing transactions in Cape Investment Advisory Wrap Program as the advisory representative pays the transaction costs paid to the custodian. Advice offered by related persons of CIA may involve investments in mutual funds. Load and no-load mutual funds may pay annual distribution charges, sometimes referred to as 12b-1 fees. These fees come from fund assets, and thus, indirectly from the client’s assets. These 12b-1 fees may be initially paid to the broker-dealer who maintains your account with a portion being allocated to related persons who are also registered affiliates of the firm. The receipt of these funds could represent an incentive for Advisory Representatives to recommend funds with 12b-1 fees or higher fees over funds with no fees or lower fees, therefore creating a potential conflict of interest. As a matter of best execution, MF’s that pay a 12b-1 will be discouraged, as they are rarely in the best interest of the client. Advisor may recommend a broker/dealer and/or custodian. Advisor considers the full range and quality of services in placing accounts, including promptness and accuracy of execution, commission rate, operational capabilities, and the firm’s financial condition to ensure compliance with Advisor’s best execution policy. For clients assets held at Hilltop Securities, Inc. (HTS) a registered broker/dealer, the trades will be executed through HTS. For assets held at Charles Schwab a registered broker/dealer the trades will be executed through Charles Schwab. For assets held at SEI, trades will be executed according to their procedures. Neither Hilltop Securities, Charles Schwab nor SEI are affiliated with CIA. This applies to other custodians as well, such as mutual fund and insurance companies. PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS IARs of CIA may also be registered representatives with AGWM a affiliated broker/dealer. Clients are under no obligation to purchase or sell securities through any affiliated broker-dealer. Fees and commissions won’t be charged for the same services or transactions. The receipt of commissions for recommended products could represent an incentive for the IAR to recommend products that pay a commission over other products, therefore creating a conflict of interest. Commissions earned may be higher or lower at AGWM than commissions earned at other broker/dealers. Employees and advisors of CIA may buy or sell securities that are also held by clients thus creating a potential conflict of interest. These individuals may not enter trades for a security in their own personal account before entering trades in client accounts. CODE OF ETHICS Our Code of Ethics holds CIA IAR’s to a high ethical standard. IARs must place the interest of the client above their own interest. Advisor will provide a copy of our Code of Ethics to any client or prospective client upon request. EDUCATION & BUSINESS STANDARDS CIA requires IARs to have a college degree or relevant experience in a business similar or related to investment management and/or planning. In addition, IARs will be registered as required by applicable state law or statute. The IARs may also be required to obtain appropriate insurance education and licensing. Additional consideration will be given to those candidates with advance industry designations (e.g., CFP™, ChFC, PFS, etc.) 10  CLIENT REFFERALS AND ADDITIONAL COMPENSATION Employees of CIA may receive commissions from the sale of insurance products and services, working with various insurance companies. Sales transactions will be completed only by licensed agents. Clients are under no obligation to purchase any insurance products and/or services through agents affiliated with CIA. The recommended broker/dealers and custodians also makes available to CIA other products and services that benefit CIA but may not benefit its clients’ accounts. Some of these other products and services assist CIA in managing and administering clients’ accounts. These include software and other technology that provide access to client account data (such as trade confirmations and account statements); facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts); provide research, pricing information and other market data; facilitate payment of CIA’s fees from its clients’ accounts; and assist with back-office functions, recordkeeping, client reporting and/or assist in increased client communication. SOLICITATION ARRANGEMENTS CIA is party to written agreements with certain Third-Party Asset Managers (TPAMs) under which its IARs provide personal advisory services to their clients. Such personal advisory services include: qualifying clients for a particular TPAM as well as determining client’s goals and objectives (determining risk tolerance and investment styles). In doing so, CIA may be acting as a solicitor for that TPAM. CIA and its IARs receive compensation pursuant to these agreements for introducing clients to the TPAM and for providing the aforementioned personal advisory services. This compensation is typically equal to a percentage of the investment advisory fee charged by the TPAM. Because such compensation may differ depending on the individual agreement with each TPAM, the IARs may have an incentive to recommend a particular TPAM over other TPAMs with which CIA has less favorable compensation arrangements or alternative advisory programs. Any solicitation or referral arrangements will comply with applicable laws that govern the nature of the service, fees to be paid, disclosures to clients and any necessary client consents. CIA may enter into a solicitor agreement with a real-estate agent, mortgage broker, accountant, or other professional where the solicitor can receive a percentage of the client asset management fee. We pay these persons a percentage of the fee paid to us by client that are determines to have become clients as a result of such individual’s direct or indirect efforts. These payments are a portion of the fee charges buy use and does not result in an increase in the amount of the fee paid by clients. CIA and its IARs may also be paid by other Investment Advisors for the referral of clients. Any solicitation or referral arrangements will complete with applicable laws that govern: Fees to be paid, • The nature of the service, • • Disclosures to clients and • Any necessary client consents. FINANCIAL INFORMATION We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to you and we have not been the subject of a bankruptcy proceeding. Additionally, CIA does not require or solicit prepayment of client fee more than six months in advance, thus a balance sheet is not required to be provided. ITEM 10: REQUIREMENTS FOR STATE-REGISTERED ADVISERS CIA is an SEC-Registered Investment Adviser. 11 

Cape Investment Advisory, Inc. An SEC Registered Investment Adviser ADV 2A Disclosure Brochure March 31, 2026 1600 Pennsylvania Avenue McDonough, GA 30253 Phone: (678) 583-1120 Fax: (678) 583-1258 This brochure provides information about the qualifications and business practices of Cape Investment Advisory, Inc. If you have any questions about the contents of this brochure, please contact us at (678) 583‐1120 or RIACompliance@capesecurities.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. Additional information about Cape Investment Advisory, Inc. also is available on the SEC’s website at www.adviserinfo.sec.gov. Being registered as an SEC Registered Investment Adviser does not imply a certain level of skill or training.  Item 2 - Material Changes There have been no material changes to this brochure since the last annual update. 2  Item 3: Table of Contents Item Number Item Page 1 Cover Page .................................................................................................................. 1 2 Material Changes ........................................................................................................ 2 3 Table of Contents ........................................................................................................ 3 4 Advisory Business ...................................................................................................... 4 5 Fees and Compensation .............................................................................................. 7 6 Performance-Based Fees and Side-By-Side Management ........................................ 10 7 Type of Clients .......................................................................................................... 10 8 Methods of Analysis, Investment Strategies and Risk of Loss .................................. 10 9 Disciplinary Actions . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .11 10 Other Financial Industry Activities and Affiliations ................................................. 12 11 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading13 12 Brokerage Practices ................................................................................................... 13 13 Review of Accounts ................................................................................................... 14 14 Client Referrals and Other Compensation ................................................................. 15 15 Custody ...................................................................................................................... 15 16 Investment Discretion ................................................................................................ 16 17 Voting Client Securities ............................................................................................. 16 18 Financial Information ................................................................................................ 16 3  Item 4: Advisory Business Firm Description CIA provides investment advisory services as a fiduciary under the Investment Advisers Act of 1940, which requires the firm to act in the best interest of its clients at all times. Cape Investment Advisory, Inc. (“CIA” or “Adviser” or “Sponsor”), solely owned by James R. Webb, is an SEC Registered Investment Adviser that has been in business since March 2008. CIA has filed notices in 34 States and provides investment management and financial planning services primarily to individuals, trusts, and corporations. CIA offers investment management services on both a discretionary and non-discretionary basis. As of December 31, 2025, the amount of discretionary assets under management was approximately $466,172,236 and non-discretionary assets under management were approximately $7,572.292. Our business model is based on a network of Investment Adviser Representatives (“IARs”) with offices in various locations each having significant flexibility to provide tailored individualized investment advice to clients. While all Cape IARs are registered with, and subject to oversight and supervision by Cape, they operate their businesses independently with some offices working under and providing client services utilizing a separate business name or “DBA.” A list of approved DBA names can be found on our Schedule D, Section 1.B which is available on the SEC’s Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov. CIA offers and provides a combination of the following advisory services for individuals, businesses, qualified retirement plans, individual retirement accounts, trusts, and other entities on a fee-only basis. • Discretionary investment management • Nondiscretionary investment management • Financial planning services • Retirement plan advisory services Note that 401(k) Counseling Services are provided using the information and education exception which does not constitute providing investment advice. As such, those assets are not included as assets under management, but represent a significant revenue stream for the entity. The process begins through personal discussions between the Investment Adviser Representative (“IAR”) and the client. This interview establishes investment goals, determines suitability, and gathers information pertaining to the client’s financial situation, objectives, time horizon and risk tolerance. This information becomes the basis for determining and constructing the investment plan/asset allocation plan which the IAR believes is in the best interest of the client’s stated goals. The investment plan will contain assets in classes that CIA and the IAR believe meets client’s investment objectives. CIA also offers clients the opportunity to utilize the services provided by third party money managers. Discretionary Investment Management We provide discretionary portfolio management services to clients using a variety of standard and customized investment strategies. Each portfolio is designed to meet a particular investment objective. As granted in our Advisory Agreement, we can use this discretionary authority to buy and sell securities on our clients’ behalf. Nondiscretionary Investment Management Clients may request to be informed of and approve trade recommendations prior to execution. In such cases, CIA provides advisory recommendations and the client retains final decision-making authority. These accounts remain advisory accounts and are not brokerage accounts. Compensation is based on advisory fees and not transaction-based commissions. 4  Financial Planning Services Financial planning services are provided to both individual and institutional clients. These plans may be comprehensive in nature or focus on specific areas of interest, at the request of the client. Throughout the time of engagement, clients are obligated to notify Adviser promptly if they experience a change in financial conditions in order to provide Adviser the opportunity to make changes in advice or strategies. CIA may offer an hourly rate for a limited plan related to a specific need such as estate planning only or college funding only. The client may choose to implement any portion, or none of the plan, at their sole discretion. Adviser will not provide ongoing investment management under a Financial Planning Agreement; however, clients will be able to engage Adviser to conduct a review of investment accounts on a periodic or annual basis for an hourly rate. CIA and its IARs do not practice law or accounting as officers, directors, managers, employees, or independent contractors of CIA. It is the client’s responsibility to understand the need to secure the services of other professionals in these areas when necessary. Retirement Plan Advisory Services Investment advisory services provided to a company for their retirement plan vary depending on the scope of the agreement. The scope of the services provided are discussed and agreed upon at the time the agreement is signed, and typically include some or all of the following: • Retirement Plan Investment Services Investment recommendations o Advise the plan sponsors investment committee o Preparation of an Investment Policy Statement o Investment review and monitoring o o Education services to the plan committee • Plan Participant Services o Participant enrollment and education o One-on-one participant meetings o Development and communication of model portfolios • Plan Design and Construction o Plan design consulting o Plan search coordination o Vendor Search o Provider review Note that 401(k) Counseling Services are provided using the information and education exception which does not constitute providing investment advice. As such, a separate agreement must be obtained to document the services performed and the fee agreed. When engaged, these assets are not included as assets under management. Broker Dealer Affiliation Disclosure Cape Securities, Inc. (“CSI”) is an affiliated broker-dealer under common ownership with CIA; however, CSI 5  is no longer actively conducting new brokerage business and is limited to administrative or legacy account activity as part of an orderly wind-down. It is common for a CIA representative to also serve as a registered representative for AGWM. Some registered representatives have insurance licenses and may recommend insurance products that pay commissions through these firms as well. Investment Advisory Affiliation Disclosure CIA is affiliated with Global Investment Advisory, LLC (“GIA”), an SEC-registered investment adviser, through common ownership and control. This relationship creates a conflict of interest. In certain circumstances, GIA may be engaged to provide sub-advisory or portfolio management services to CIA clients. In such arrangements, CIA remains responsible for the overall relationship with the client, including oversight of GIA’s services, while GIA provides investment management services pursuant to a sub-advisory agreement. Certain investment adviser representatives of CIA are also registered with GIA. This dual registration creates a conflict of interest because such representatives may have an incentive to recommend GIA’s services. CIA addresses this conflict through policies and procedures designed to ensure that recommendations are made in the best interest of clients, along with full disclosure of these relationships. Clients will be provided with appropriate disclosures regarding any sub-advisory arrangement, including the services to be provided and applicable fees, and where required, client consent will be obtained. Third Party Asset Management Adviser may recommend that clients engage certain Third-Party Asset Managers (“TPAM”) to manage all or a portion of their assets. Advisers will provide individualized advisory services to their clients through the selection of a suitable TPAM. Factors considered in the selection of a TPAM include, but may not be limited to: the management style, performance, reputation, pricing and reporting capabilities of the TPAM; i) the client’s risk tolerance, goals and objectives, as well as investment experience; and, ii) iii) the amount of client assets available for investment. To assist clients in the selection of a TPAM, the IAR will typically gather information from the client about the client’s financial situation, investment objectives, and reasonable restrictions the client wants imposed on the management of the account. Adviser will review the client’s situation at least annually, or more often as needed or agreed upon with each client, to review the client’s financial situation and objectives, communicate information to the TPAM managing the account as warranted, and to assist the client in understanding and evaluating the services provided by the TPAM. Clients will be expected to notify their Adviser of any changes in their financial situation, investment objectives, risk tolerance, or account restrictions. A complete description of the programs and services provided, the total fees, the payment structure, termination provisions and other aspects of each program are detailed and disclosed in: the TPAM’s Form ADV Part 2A; i) the program wrap brochure (if applicable) or other applicable disclosure document(s); ii) the disclosure document(s) of the portfolio manager or managers selected; or, iii) the TPAM’s account opening documents. iv) 6  A copy of all relevant disclosure documents of the TPAM and the individual portfolio manager(s) will be provided to anyone interested in these programs/managers. Programs include, but are not limited to: • 401k Generation • Alphastar Capital Management • American Funds • AssetMark • Armis Advisers • Auour Advisory • Beacon Capital • Betterment • BTS Management • Cardea Capital • CLS • Envestnet • Flexible Plan Investments James Alpha • • Morningstar • Nationwide Jackson National • • Midland • Security Benefit Life • Protective Life • Orion • Pacific-Life • Lincoln Financial • SEI • 55IP Fees generally include: Management and advisory fees shared by the TPAMs, CIA, and its IARs. i) i) Transaction costs, if applicable, which may be paid to purchase and sell such securities; and iii) Custody fees The amount and timing of these fees vary depending on the TPAM. 7  Wrap Fee Program The client may elect to participate in a wrap fee account. The account will be managed similarly to non-wrap fee accounts. The primary difference between a wrap account and non-wrap account is in the manner that the account is billed to the client. In a wrap fee account, clients are billed one inclusive fee that includes the cost of the advisor fee, portfolio management fee, platform fee, ticket charges, some service fees, and postage and handling charges. In a non-wrap account, the foregoing charges are assessed as separate charges. Please see the separate Wrap Fee Brochure for more information. Please Note: When investing in mutual funds and variable annuities, clients are strongly encouraged to review the applicable prospectus. Mutual funds and variable annuities may impose additional fees as well as certain restrictions on the frequency, timing and dollar amount of transactions and may impose penalty fees based upon short-term trading patterns. Such restrictions may impact the services provided by a TPAM. Item 5: Fees and Compensation General Fee Information Fees and compensation charged depend on the type and depth of services provided. All advisory services can be terminated within 5 days of signing the Advisory Agreement without penalty (full refund or no fees due) or when Adviser’s Form ADV Part II is not delivered at least 48 hours prior to the time of engagement. Otherwise, services can be terminated at any time with written notice. Fees will be deducted directly from client assets and may be billed monthly or quarterly in arrears or in advance depending on the terms of the agreement. Fees are negotiable subject to the approval of CIA management. i. Billing In Arrears Most clients are billed in arrears. The first payment for billing in arrears is due the next quarter or month following the deposit into the account and will be based on the account value at that time. The fee will be assessed on a pro-rata basis calculated from the opening date of the account to the nearest quarter or month of the billing cycle. Thereafter, the fee will be based on the Account value on the last business day of the calendar month or quarter as applicable. Portfolio Adviser will be paid a portion of the fee collected by Cape in accordance with a written agreement between Portfolio Adviser and Cape. In the event the Client Advisory Services Agreement is terminated Client will be billed for any partial month or quarterly fee incurred on a pro- rata basis. IARs may liquidate assets to cover fees. ii. Billing In Advance The first payment for billing in advance is due immediately upon opening and funding the account, as specified in the Advisory Agreement. The fee will be assessed on a pro-rata basis calculated from the opening date of the account to the nearest month or quarter of the billing cycle. Thereafter, the fee will be based on the Account Value on the first business day of the calendar month or quarter. Portfolio Adviser will be paid a portion of the fee collected by Cape in accordance with the written agreement between Portfolio Adviser and Cape. In the event of termination of the Client Advisory Services Agreement, Client will be refunded fees on a pro-rata basis calculated on the number of days left in the billing cycle. Additional General Information Additional deposits and withdrawals/liquidations to the account in excess of $25,000 may be subject to the same fee procedures. A withdrawal/liquidation in excess of $25,000 will be included in the fee collected on a pro-rata basis. Notwithstanding the foregoing, no advisory fee will be charged on any A or B share mutual fund, unit investment trust or annuity transferred into the account that were purchased within five years if a commission was paid to the IAR in their role as a registered representative at an affiliated or unaffiliated broker/dealer. No advisory fee will be charged on a C share mutual fund transferred into the account that was purchased within 8  one year if a commission was paid to the IAR in their role as a registered representative at an affiliated or unaffiliated broker-dealer. According to the firm’s best execution requirement, any in an advisory relationship must be converted into an appropriate share class or investment type upon a management fee being assessed. As authorized in the Advisory Agreement, the account custodian withdraws advisory fees directly from the client’s account according to the custodian’s policies, practices, and procedures. The custodian sends the client a statement at least quarterly, indicating all the amounts disbursed from the account including the amount of advisory fees. It is the client’s responsibility, not the custodians, to verify the accuracy of the fee deduction. Since IARs of CIA can also be registered affiliates of AGWM, the broker/dealer has certain supervisory and administrative duties that it is obligated to perform. The custodian of the account holds all customer assets. CIA does not hold customer funds or securities. Fees are never based upon the performance of the account. Advisers may be licensed as Registered Representatives with AGWM or another broker/dealer. This arrangement may present a conflict of interest in recommending investment products based on the compensation received, rather than on a client’s needs. It is against the policy of CIA and AGWM to allow an IAR or Representative to put personal interests ahead of client interests. In any transaction that presents a conflict of interest, the client’s interest is always the primary interest. In the event a conflict of interest arises, the client will not be billed twice for the same service or transaction. Any investment product recommended by Adviser may be purchased through other brokers and agents unaffiliated with AGWM if the client desires. Clients should note that the same or similar advisory services may be available elsewhere at a lower or higher cost to the client. Clients should consider that depending upon the level of wrap fee charged, the amount of portfolio activity in their account(s), the value of services provided, and other factors, a wrap fee may exceed the aggregate cost of services if they were to be provided separately. A non-wrapped pricing arrangement may be more cost effective for accounts that do not experience frequent trading activity. The annual fees may be negotiable and based on assets under management as follows: Asset Amount Up to 250K $251K - $500K $501K - $1M Above $1M Max. Advisor Fee 2.75% 2.50% 2.25% 2.00% The asset-based fee is based upon the value of the account as calculated by the custodian. Tiered Fee Structure The Adviser Fee is computed using a tiered fee structure when applicable. This means that the entire account balance is broken up into the applicable tiers and the corresponding fee is applied to each sub-balance of the account. For example, a $2,000,000 account with the fee schedule shown above would result in a Total Annual Client Fee of $44,375, computed as follows: Client Fee: ($250,000 x 2.75%) + ($250,000 x 2.50%) + ($500,000 x 2.25%) + ($1,000,000 x 2.00%) = $44,375 Client is responsible for all commissions and other transaction charges (on non-wrap accounts) and any charge relating to the custody of securities in the account. In addition, all fees paid to CIA for investment advisory 9  services are separate and distinct from fees and expenses that may be charged by the mutual fund companies or TPAMs. The mutual fund fees and expenses are described in the fund’s prospectus. Clients will also incur brokerage and other transaction costs; please see Item 12 in this brochure for further information. In certain arrangements with TPAMs, the client may be billed directly by the TPAM. In these situations, CIA will receive a solicitation fee for its services. Notwithstanding this arrangement, the client will not be billed more than the maximum annual fee amount listed and agreed upon in the fee schedule above. All fee arrangements are subject to approval by CIA management. Financial Planning Fees CIA’s Adviser Representatives may offer personal financial planning services on an hourly or fixed fee basis. Financial planning services can be offered for a fixed fee or on an hourly basis. The client may choose to implement any portion or none of the plan at their sole discretion. Adviser will not provide ongoing investment management under the Financial Planning Agreement; however, clients will be able to engage Adviser to conduct a review of investment accounts on a periodic or annual basis for the hourly rate noted above. Consulting, Retirement Plan Services and Other Fees Fees will be charged either at an hourly rate or by other agreed-upon method. The fee will depend on the nature and complexity of the client’s consulting needs. All fees are agreed upon prior to entering into a contract. The client will be invoiced at the conclusion of the project, or on a monthly basis, for hourly fees. An upfront deposit may be requested. ITEM 6: Performance-Based Fees and Side-by-Side Management CIA does not use Performance-Based Fees and Side-by-Side Management. Therefore, Item 6 is not applicable to CIA’s business model. ITEM 7: Types of Clients CIA provides discretionary and investment advisory, financial planning, and consulting services on a fee- only basis for individuals, businesses, qualified retirement plans, individual retirement accounts, trusts, and other entities. CONDITIONS FOR MANAGING ACCOUNTS CIA generally requires a minimum relationship of $25,000 for clients seeking investment management service, which may be waived based upon a pre-existing householding relationship or special client circumstances at the discretion of management. ITEM 8: Methods of Analysis, Investment Strategies and Risk of Loss CIA utilizes a combination of fundamental, technical, and macroeconomic analysis in providing portfolio consulting and management services. Product recommendations may include, but are not limited to, equities, ETFs, corporate debt securities, municipal bonds, mutual funds, government securities, alternative investments, and options. We select specific investments for your portfolio through the analysis of: 1. Fundamental data 2. Technical considerations 3. Macro-Economic and Geo-political factors IARs directly manage and diversify Clients’ portfolios based upon the Client’s: 10  risk profile • time horizon • financial goals • income (current and potential) • cash flow and liquidity needs • tax considerations • • portfolio size • net worth, and • other various suitability factors Restrictions and guidelines imposed by Clients affect the composition and performance of portfolios. For this reason, portfolio performance within the same investment objective may differ. RISK OF LOSS CIA does not offer performance guarantees on any security or investment strategy. Consult your IAR on questions related to your risk analysis. All investments involve risks that can result in loss, including: • Loss of principal • A reduction in earnings • Loss of future earnings Additionally, these risks may include but are not limited to: • Market risk Interest rate risk • Issuer risk • Inflation risk • • Currency risk • Political risk • And general economic risk Frequent trading can affect portfolio performance, particularly through increased brokerage and other transactional costs (if applicable) and taxes. Additionally, you should be aware that the use of margin, options, and short sales are higher risk strategies. It is possible to lose all the principal you invest, and sometimes more. In a cash account, your risk is limited to the amount of money that you have invested. In a margin account, your risk includes the amount of money invested plus the amount that has been loaned to you. When you sell a security short, your losses can be infinite. Past performance is not indicative of future results. Cybersecurity Risk: CIA relies on digital technologies, systems, and third-party service providers to conduct its business and maintain client information. These systems may be subject to cyber-attacks, unauthorized access, data breaches, or other disruptions. While CIA takes reasonable measures designed to protect client information and maintain operational continuity, no system is entirely secure. A cybersecurity incident could result in the loss of confidential client information, delays in account access, or other service disruptions that may negatively impact clients. 11  Technology and Third-Party Systems Risk: CIA utilizes various technology platforms and third-party systems in the delivery of its advisory services, including portfolio management, trading, reporting, and client relationship management systems. These may include systems used directly by CIA as well as those used by affiliated or third-party service providers. These systems may rely on data feeds, integrations, and automated processes that are subject to errors, delays, or system outages. In addition, disruptions to these systems could impact trading, reporting accuracy, or the timeliness of client information. While CIA takes reasonable steps to evaluate and oversee these systems, it does not control all aspects of third-party technology providers and cannot guarantee the accuracy, completeness, or uninterrupted operation of such systems. ITEM 9: Disciplinary Actions CIA has not been the subject of any material disciplinary events required to be disclosed under this Item. Certain Investment Adviser Representatives of CIA may have reportable disciplinary history. Additional information regarding such individuals is available in their respective Form CRS and Form ADV Part 2B Brochure Supplements, which are provided to clients. Clients are encouraged to review these disclosures and discuss any questions directly with their IAR. ITEM 10: Other Financial Industry Activities & Affiliations Cape Investment Advisory, Inc. (“CIA”) is under common ownership and control with affiliated financial services entities, including broker-dealers, an insurance agency, and another registered investment adviser. These relationships may create conflicts of interest as certain investment adviser representatives (“IARs”) may receive compensation from multiple sources depending on the services provided. CIA addresses these conflicts through disclosure, supervisory oversight, and policies requiring that recommendations be made in the best interest of clients. Clients are under no obligation to utilize any affiliated entity and may choose unaffiliated service providers. Broker-Dealer Affiliations Cape Securities, Inc. (“CSI”) was an affiliated broker-dealer under common ownership with CIA. CSI is no longer conducting business and is in the process of winding down operations. As a result, CSI does not engage in new brokerage activity, and any conflicts of interest associated with CSI are limited to legacy matters. American Global Wealth Management, Inc. (“AGWM”) is a broker-dealer registered with the SEC, FINRA, and various state regulatory authorities. AGWM is under common control with CIA. Certain IARs of CIA are also registered representatives of AGWM and in their separate capacity may receive commissions for brokerage transactions conducted outside of CIA. This arrangement may create a conflict of interest, as such individuals may have an incentive to recommend commission-based products. Insurance Affiliation Cape Insurance Solutions, Inc. (“CIS”) is an affiliated insurance agency under common ownership with CIA. CIA IARs who are licensed insurance agents may recommend insurance products and receive commissions. This arrangement may create a conflict of interest because such compensation provides an incentive to recommend insurance products. Affiliated Investment Adviser Global Investment Advisory, LLC (“GIA”) is an SEC-registered investment adviser under common ownership and control with CIA. In certain circumstances, GIA may provide sub-advisory or portfolio management services to CIA clients. Certain IARs of CIA are also registered with GIA. This relationship may create a conflict of interest because CIA and its IARs may have an incentive to recommend an affiliated adviser. CIA addresses this conflict through disclosure of these relationships. Clients are under no obligation to utilize GIA’s services. CIA is responsible for the overall relationship with the client in such arrangements. 12  Custodial Relationships CIA may recommend that clients maintain custody of their assets with Charles Schwab & Co., Inc. (“Schwab”), SEI Private Trust Company (“SEI”), Hilltop Securities Inc. (“Hilltop”), or another qualified custodian. These custodians are independent and not affiliated with CIA. Clients are not required to use any recommended custodian and may select another qualified firm. ITEM 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Participation Or Interest In Client Transactions CIA IARs may be registered representatives with AGWM which are affiliated broker/dealers. Clients are under no obligation to purchase or sell securities through AGWM; however, if they choose to implement recommendations within a financial plan, commissions may be earned in addition to any fee paid for advisory services. Fees and commissions won’t be charged for the same services or transactions. The receipt of commissions for recommended products could represent an incentive for the IAR to recommend products that pay a commission over other products that don’t or that pay a lower commission than the one(s) recommended, therefore creating a conflict of interest. Additionally, if the client implements the plan through the IAR, clients may be limited to products or services available through AGWM. Commissions earned may be higher or lower at AGWM than commissions earned at other broker/dealers. Employees and IARs of CIA may buy or sell securities that are also held by or recommended to clients, thus creating another potential conflict of interest. Employees and IARs may not enter trades for a security in their own personal account prior to entering the Client’s trade in Client accounts. Code Of Ethics Our Code of Ethics holds CIA IAR’s to a high ethical standard. IAR’s must place the interest of the Client above their own interest. Adviser will provide a copy of our Code of Ethics to any Client or prospective client upon request. Education & Business Standards CIA requires IARs to have a college degree or relevant experience in a business similar or related to investment management and/or planning. In addition, IARs will be registered as required by applicable state law or statute. The IARs may also be required to obtain appropriate insurance education and licensing. Additional consideration will be given to those candidates with advance industry designations (e.g., CFP™, ChFC, PFS, etc.) ITEM 12: Brokerage Practices Investment Or Brokerage Discretion CIA seeks to obtain best execution for client transactions, which means seeking to execute transactions in a manner that maximizes the overall value for the client. CIA does not receive commissions for securities transactions within its advisory services. Certain Investment Adviser Representatives of CIA are also registered representatives of an affiliated broker-dealer and, in their separate capacity, may receive commissions for brokerage transactions executed outside of CIA. These arrangements present a financial incentive for such individuals when acting in their separate capacity. Clients are not obligated to implement recommendations through any affiliated broker-dealer. CIA generally recommends that clients maintain custody of their assets with Charles Schwab & Co., Inc. (“Schwab”), SEI Private Trust Company (“SEI”), or Hilltop Securities Inc. (“Hilltop”). While clients may select any qualified custodian, the majority of client assets are maintained with Schwab due to the scope of services, technology, and operational support available. 13  CIA evaluates custodial and brokerage relationships based on execution capability, service, and overall value provided to clients. Transaction costs and services may vary depending on the custodian or broker-dealer selected, and CIA considers these factors as part of its overall evaluation. While CIA does not receive commissions for transactions within its advisory services, custodians may provide products and services that benefit CIA, including technology, research, and administrative support. These arrangements may create a conflict of interest because they provide an incentive for CIA to recommend these custodians. CIA addresses this conflict by acting in the best interest of its clients and seeking best execution for all transactions. Persons associated with CIA may also be registered representatives of American Global Wealth Management, Inc. (“AGWM”), an affiliated broker-dealer, in their separate capacity. In such capacity, they may effect securities transactions for commissions outside of CIA’s advisory services. This arrangement creates a potential conflict of interest because such individuals may have a financial incentive associated with brokerage services or commission-based products. However, clients are under no obligation to implement recommendations through AGWM and may choose any broker-dealer or custodian. ITEM 13: Review of Accounts IARs will review accounts no less than annually or as agreed upon by IAR and Client. Supervisory reviews will occur randomly and/or on the accounts with disproportionate losses and gains. CIA does not provide customized Client statements. These statements will come from the Client’s respective custodian. ITEM 14: Client Referrals & Other Compensation Employees of CIA may receive commissions from the sale of insurance products and services, working with various insurance companies. Sales transactions will be completed only by licensed agents. Clients are under no obligation to purchase any insurance products and/or services through agents affiliated with CIA. The recommended broker/dealers also make available to CIA other products and services that benefit CIA but may not benefit its client’s accounts. Some of these other products and services assist CIA in managing and administering Clients’ accounts. These include software and other technology that provide access to Client account data (such as trade confirmations and account statements); facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts); provide research, pricing information and other market data; facilitate payment of CIA’s fees from its clients’ accounts; and assist with back- office functions, recordkeeping, client reporting and/or assist in increased client communication. Promoter Arrangements CIA is party to written agreements with certain Third-Party Asset Managers (TPAMs) under which its IARs provide personal advisory services to their clients. Such personal advisory services include qualifying their clients for a particular TPAM as well as determining client’s goals and objectives (determining risk tolerance and investment styles). In doing so, CIA may be acting as a promoter for that TPAM. CIA and its IARs receive compensation pursuant to these agreements for introducing clients to the TPAM and for providing the aforementioned personal advisory services. This compensation is typically equal to a percentage of the investment advisory fee charged by the TPAM. Because such compensation may differ depending on the individual agreement with each TPAM, the IARs may have an incentive to recommend a particular TPAM over other TPAMs with which CIA has less favorable compensation arrangements or alternative advisory program. Any solicitation or referral arrangements will comply with applicable laws that govern the nature of the service, fees to be paid, disclosures to clients and any necessary client consents. CIA may enter into a promoter agreement with a real-estate agent, mortgage broker, accountant, attorney, or other professional where the promoter can receive compensation based upon the amount of assets brought to CIA. Promoter compensation is typically equal to a percentage of the investment advisory fee paid by the 14  Client, who is deemed to have become a Client as a result of such individual’s direct or indirect efforts. These payments are proportional to the fee charged by us and do not result in an increase in the amount of the fee paid by Client. CIA and its IARs may also be paid by other Investment Advisers for the referral of clients. Any solicitation or referral arrangements will be in writing and in accordance with applicable laws that govern: • The nature of the service, • Fees to be paid, • Disclosures to client and • Any necessary client consent. All promoter arrangements are governed by written agreements and comply with Rule 206(4)-1 under the Investment Advisers Act of 1940. Clients will receive clear and prominent disclosure at the time of solicitation describing the nature of the relationship, the compensation to be paid, and the associated incentives. ITEM 15: Custody Adviser may recommend a broker/dealer and/or custodian. Adviser considers the full range and quality of services in placing accounts, including promptness and accuracy of execution, commission rate, operational capabilities, and the firm’s financial condition to ensure compliance with Adviser’s best execution policy. Generally, the Adviser will recommend that client assets be held in custody at Charles Schwab. Charles Schwab & Co., Inc., is not affiliated with CIA. CIA is deemed to have custody of client assets solely due to its authority to deduct advisory fees directly from client accounts. Client assets are maintained with qualified custodians, and clients receive account statements directly from those custodians at least quarterly. Clients are encouraged to carefully review those statements and compare them to any reports provided by CIA. CIA does not send statements to its clients. Clients receive statements from their respective custodian on a monthly or quarterly basis. Clients also have online access to their account, including statements and confirmations, via their custodian’s website. CIA advises Client to review and compare their account statements, which they receive in the mail, with their electronic account statement, to ensure consistency. ITEM 16: Investment Discretion Clients who participate in the Advisory Services Program may elect to grant full discretionary investment authority to CIA, IAR and/or TPAM to determine the securities to be bought or sold, the amount of securities to be bought or sold, and the timing of such transactions. This discretionary authority is authorized by the client when the client signs CIA’s Advisory Services Agreement. CIA, IAR and/or TPAM can use this authority to replace a Sub-Manager. However, CIA, IAR and/or TPAM will generally only use this grant of discretion to replace Sub-Managers when it deems such change to be necessary; to rebalance a Client’s account as agreed between the Adviser and/or Client; and to liquidate sufficient assets to pay the advisory fee when necessary and advisable. CIA, IAR and/or TPAM will not have the authority to withdraw funds or take custody of client funds or securities other than where the client has authorized the deduction of investment advisory fees via a qualified custodian or at the request of Client to have money withdrawn from the brokerage account and sent to the address of record or an existing bank account registered to Client. ITEM 17: Voting Client Securities PROXY VOTING AND CLASS ACTION LAWSUITS CIA does not vote, nor advise clients how to vote, proxies for securities held in client accounts. CIA clients retain the right to vote the proxies of shares held in their accounts. In addition, CIA will not take any action or render any advice with respect to any securities held in any accounts that are named in or subject to class action lawsuits. 15  ITEM 18: Financial Information We have no financial commitment that impairs our ability to meet contractual and fiduciary commitments to you and we have not been the subject of a bankruptcy proceeding. Additionally, CIA does not require or solicit prepayment of client fee more than six months in advance, thus a balance sheet is not required to be maintained or provided. 16