Capital Trust Advisors

BROCHURE SUPPLEMENT ITEM 1: COVER SHEET J. Jeffrey Lambert Goldberg Advisers, LLC also doing business as Capital Trust Advisors PO Box 2295 Minden, NV 89423 (916) 685-7040 March 26, 2026 This Brochure Supplement provides information about J. Jeffrey Lambert that supplements the Goldberg Advisers, LLC Brochure. You should have received a copy of that Brochure. Please contact John Goldberg, Managing Member at (415) 399-9100 or john@capitaltrustadvisors.com if you did not receive Goldberg Advisers, LLC’s Brochure or if you have any questions about the content of this supplement. Additional information about J. Jeffrey Lambert is available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE J. Jeffrey Lambert was born in 1952. He attended American River College, Sacramento City College, Sacramento State University and BYU – Idaho (formerly Ricks College). Employment Background Employment Dates: Firm Name: Type of Business: Job Title & Duties: 12/2025 – Present Goldberg Advisers, LLC also dba Capital Trust Advisors Investment Advisor Investment Adviser Representative Employment Dates: Firm Name: Type of Business: Job Title & Duties: 9/2013 – 12/2025 Lambert Wealth Advisory, LLC Investment Advisor Managing Member  Goldberg Advisers, LLC also doing business as Capital Trust Advisors Brochure Supplement J. Jeffrey Lambert Professional Designations Certified Financial Planner (CFP) - 1984 The CFP designation is issued by the Certified Financial Planner Board of Standards, Inc. In order to receive a CFP designation, the candidate must have a bachelor’s degree or higher from an accredited college or university and have 3 years of full-time personal financial planning experience. In addition, the candidate must complete a CFP board-registered program or hold one of the following: CPA, ChFC, Chartered Life Underwriter (CLU), CFA, Ph.D. in business or economics, Doctor of Business Administration or attorney’s license. Once the designation is earned, the CFP must complete 30 hours of continuing education every 2 years. ITEM 3: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. There is no information of this type to report. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Lambert is not involved in any other business activities. ITEM 5: ADDITIONAL COMPENSATION Mr. Lambert does not receive any economic benefit from any non-client for providing advisory services. ITEM 6: SUPERVISION John Goldberg, Managing Member, is the owner and responsible for the supervision of all investment personnel. His telephone number is (415) 399-9100. Page 2 

BROCHURE SUPPLEMENT ITEM 1: COVER SHEET John J. Goldberg Goldberg Advisers, LLC also doing business as Capital Trust Advisors 323 Magnolia Avenue Piedmont, CA 94610 (415) 867-9320 March 26, 2026 This Brochure Supplement provides information about John J. Goldberg that supplements the Goldberg Advisers, LLC Brochure. You should have received a copy of that Brochure. Please contact John Goldberg, Managing Member at (415) 399-9100 or john@capitaltrustadvisors.com if you did not receive Goldberg Advisers, LLC’s Brochure or if you have any questions about the content of this supplement. Additional information about John J. Goldberg is available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE John J. Goldberg was born in 1967. He received a BA in Philosophy from Lehigh University in 1989 and studied Business Administration with a concentration in accounting and finance at the University of California Berkeley Extension. Employment Background Employment Dates: Firm Name: Type of Business: Job Title & Duties: 8/1999 – Present Goldberg Advisers, LLC also dba Capital Trust Advisors Investment Advisor Managing Member and Portfolio Manager Employment Dates: Firm Name: Type of Business: Job Title & Duties: 7/2009 – 12/2010 Natura Capital, LLC Investment Advisor Managing Member and Portfolio Manager  Goldberg Advisers, LLC also doing business as Capital Trust Advisors Brochure Supplement John J. Goldberg Employment Background (continued) Employment Dates: Firm Name: Type of Business: Job Title & Duties: 10/2000 – 06/2004 Hahn Capital Management Investment Advisor Portfolio Manager Employment Dates: Firm Name: Type of Business: Job Title & Duties: 8/1997 – 9/2000 Wells Capital Management (now Allspring Global Investments) Investment Advisor Research Analyst Professional Designations Chartered Financial Analyst (CFA®) - 2000 The CFA Charterholder designation is issued by the CFA Institute. In order to receive this designation, a candidate must have either: 1) an undergraduate degree and 4 years of professional experience involving investment decision-making, or 2) 4 years qualified work experience (full time, but not necessarily investment related). Each candidate must complete a self-study program of 250 hours of study for each of the 3 levels. Once a candidate passes each of the three 6-hour exams and meets the appropriate experience requirements the CFA charterholder designation may be used. There are no continuing education requirements. ITEM 3: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. There is no information of this type to report. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Goldberg is not involved in any other business activities. ITEM 5: ADDITIONAL COMPENSATION Mr. Goldberg does not receive any economic benefit from any non-client for providing advisory services. ITEM 6: SUPERVISION John Goldberg, Managing Member, is the owner and responsible for the supervision of all investment personnel. His telephone number is (415) 399-9100. Page 2 

BROCHURE SUPPLEMENT ITEM 1: COVER SHEET Paul A. D. Evans Goldberg Advisers, LLC 1210 Fifth Avenue #275 San Rafael CA 94910 (415) 399-9100 March 26, 2026 This Brochure Supplement provides information about Paul A. D. Evans that supplements the Goldberg Advisers, LLC Brochure. You should have received a copy of that Brochure. Please contact John J. Goldberg, Managing Member at (415) 867-9320 or john@capitaltrustadvisors.com if you did not receive Goldberg Advisers, LLC’s Brochure or if you have any questions about the content of this supplement. Additional information about Paul A. D. Evans is available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Paul A. D. Evans was born in 1943. Educational Background Degree Associate Fellow MBA Year Major(s) 1964 Chemistry 1966 Chemistry: Structures of the Octahydrocarbazoles 1968 Chemistry: Studies in Indole Chemistry 1968 1979 1977 Business Administration Member CFA 1972 1987 1997 School Name New College, Oxford University, England BA New College, Oxford University, England B Sc. New College, Oxford University, England M Sc. Institute of Chartered Accountants of England & Wales Graduate School of Business, Stanford University London Stock Exchange CFA Institute, Charlottesville, Virginia Continuing Education Program: Five Year Certificate of Achievement  Goldberg Advisers, LLC Brochure Supplement Paul A. D. Evans Employment Background Employment Dates: Firm Name: Type of Business: Job Title & Duties: 11/2023 – Present Goldberg Advisers, LLC dba Capital Trust Advisors Investment Adviser Portfolio Manager Employment Dates: Firm Name: Type of Business: Job Title & Duties: 1993 – 3/2024 Paladin Capital Management, LLC Investment Adviser Managing Member, President Employment Dates: Job Title & Duties: 1994 – 2000 Grader for the Professional Investment Exams Employment Dates: Firm Name: Type of Business: 1990 - 1993 Independent Consultant Provision of marketing services to professional firms and preparation of fund- raising proposals. Employment Dates: Firm Name: Type of Business: Job Title & Duties: 1989 – 1990 The Portola Group Inc. Investment adviser serving high net worth individuals Vice President of Research and Chairman/Member of the Investment Committee Employment Dates: Firm Name: Type of Business: Job Title & Duties: 1983-1988 S. G. Warburg & Co. Inc. International Investment Bankers Vice President and Securities Analyst specializing in high technology and international media companies. Employment Dates: Firm Name: Job Title & Duties: 1977-1982 McKinsey & Co. Inc. Engagement Manager with responsibility for projects involving corporate strategy and the management of Research & Development ITEM 3: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. There is no information of this type to report. Page 2  Goldberg Advisers, LLC Brochure Supplement Paul A. D. Evans ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Evans is not involved in any other business activities. ITEM 5: ADDITIONAL COMPENSATION Mr. Evans does not receive any economic benefit from any non-client for providing advisory services. ITEM 6: SUPERVISION John J. Goldberg, Managing Member, is responsible for the supervision of Mr. Evans. His telephone number is (415) 867-9320. Page 3 

BROCHURE SUPPLEMENT ITEM 1: COVER SHEET Sanford P. Lowengart, III Goldberg Advisers, LLC also doing business as Capital Trust Advisors 1210 5th Avenue, #275 San Rafael, CA 94901 (415) 399-9100 March 26, 2026 This Brochure Supplement provides information about Sanford P. Lowengart, III that supplements the Goldberg Advisers, LLC Brochure. You should have received a copy of that Brochure. Please contact John Goldberg, Managing Member at (415) 399-9100 or john@capitaltrustadvisors.com if you did not receive Goldberg Advisers, LLC’s Brochure or if you have any questions about the content of this supplement. Additional information about Sanford P. Lowengart, III is available on the SEC’s website at www.adviserinfo.sec.gov. ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Sanford P. Lowengart, III was born in 1968. He received a B.A. in Political Science from University of California, Berkeley in 1990. Employment Background Employment Dates: Firm Name: Type of Business: Job Title & Duties: 02/2013 – Present Goldberg Advisers, LLC Investment Advisor Portfolio Manager  Goldberg Advisers, LLC also doing business as Capital Trust Advisors Brochure Supplement Sanford P. Lowengart, III Employment Background (continued) Employment Dates: Firm Name: Type of Business: Job Title & Duties: 02/2009 – 02/2013 Heffernan Investment Advisors Investment Advisor Sr. Portfolio Manager Employment Dates: Firm Name: Type of Business: Job Title & Duties: 01/2010 – 08/2012 Atlin Capital Advisers, LLC Investment Advisor Managing Partner Employment Dates: Firm Name: Type of Business: Job Title & Duties: 06/2004 – 02/2009 Cephus Capital Management, LLC Investment Advisor Principal Employment Dates: Firm Name: Type of Business: Job Title & Duties: 08/2003 – 07/2004 SDR Capital Management, Inc. Investment Advisor Sr. Portfolio Manager ITEM 3: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. There is no information of this type to report. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Lowengart is not involved in any other business activities. ITEM 5: ADDITIONAL COMPENSATION Mr. Lowengart does not receive any economic benefit from any non-client for providing advisory services. ITEM 6: SUPERVISION John Goldberg, Managing Member, is responsible for the supervision of Mr. Lowengart. His telephone number is (415) 399-9100. Page 2 

PART 2A ITEM 1: COVER SHEET Goldberg Advisers, LLC also doing business as Capital Trust Advisors 1210 5th Avenue, #275 San Rafael, CA 94901 (415) 399-9100 capitaltrustadvisors.com March 26, 2026 This brochure provides information about the qualifications and business practices of Goldberg Advisers, LLC. If you have any questions about the contents of this brochure, please contact us at the telephone number above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Our e-mail for regulatory compliance is compliance@capitaltrustadvisors.com. Goldberg Advisers, LLC is a registered investment advisor. Registration of an investment advisor does not imply any level of skill or training. The verbal and written communications of an investment adviser provide you with information you need to determine whether to hire or retain the advisor. Additional information about Goldberg Advisers, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov.  PART 2A ITEM 2: MATERIAL CHANGES Goldberg Advisers, LLC also doing business as Capital Trust Advisors Our previous annual update was dated March 15, 2025. Following is a summary of the material changes made to Part 2 since that amendment. Item 4: As of March 31, 2026, we have $402.6 million in discretionary assets under management. Please contact us at john@capitaltrustadvisors.com if you would like a copy of our updated Part 2. Additional information about us is also available on the SEC’s website at www.adviserinfo.sec.gov.  ITEM 3 TABLE OF CONTENTS Item 1: Cover Sheet Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business...................................................................................................................... 1 Who we Are ........................................................................................................................................ 1 Wealth Management............................................................................................................................ 1 Financial Planning ............................................................................................................................... 2 Assets Under Management .................................................................................................................. 2 Item 5: Fees and Compensation .............................................................................................................. 2 Wealth Management............................................................................................................................ 2 Other Costs Involved ........................................................................................................................... 3 Item 6: Performance-Based Fees and Side-By-Side Management............................................................ 3 Item 7: Types of Clients ......................................................................................................................... 3 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 4 Item 9: Disciplinary Information............................................................................................................. 5 Item 10: Other Financial Industry Activities and Affiliations .................................................................. 5 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading................ 6 Code of Ethics ..................................................................................................................................... 6 Personal Trading for Associated Persons.............................................................................................. 6 Item 12: Brokerage Practices .................................................................................................................. 6 The Custodian and Brokers We Use..................................................................................................... 6 How We Select Brokers/Custodians..................................................................................................... 7 Your Brokerage and Custody Costs ..................................................................................................... 7 Products and Services Available to Us From Schwab........................................................................... 8 Our Interest in Schwab's Services ........................................................................................................ 9 Aggregation of Orders ......................................................................................................................... 9 Soft Dollars ......................................................................................................................................... 9 Item 13: Review of Accounts................................................................................................................ 10 Wealth Management.......................................................................................................................... 10 Financial Planning ............................................................................................................................. 10 Item 14: Client Referrals and Other Compensation ............................................................................... 10 Item 15: Custody .................................................................................................................................. 11 Item 16: Investment Discretion............................................................................................................. 11 Item 17: Voting Client Securities.......................................................................................................... 11 Item 18: Financial Information ............................................................................................................. 11  ITEM 4: ADVISORY BUSINESS Who we Are Goldberg Advisers, LLC dba Capital Trust Advisers (referred to as “we,” “our,” “us,” “CTA,” or “Goldberg”) has been registered as an investment advisor since 2000. Mr. John Goldberg is responsible for day-to-day management of our operations and is the Managing Member, Mr. Sanford Lowengart, III is the Chief Operating Officer. Goldberg will provide management services to balanced portfolios under the name of Capital Trust Advisors (“CTA”). Wealth Management Using the name Capital Trust Advisors, we provide continuous advice to clients regarding the investment of client funds based on the individual needs of each client. Through personal discussions in which goals and objectives based on a client's particular circumstances are established, CTA establishes a client's personal investment strategy and manages a portfolio based on that strategy. During the data-gathering process, CTA determines the client’s individual objectives, time horizons, risk tolerance, and liquidity needs. CTA may also review and discuss a client’s prior investment history, as well as family composition and background. CTA manages advisory accounts on a discretionary basis. Account supervision is guided by, amongst other considerations, information discovered during the data-gathering process, such as the client's stated objectives (i.e., capital appreciation, growth, income, growth and income, or capital preservation). We provide our clients with investment advisory services consisting of discretionary asset management through use of equity, fixed income and balanced (between equity securities such as stocks and fixed income securities such as municipal and government bonds) portfolios. Our wealth management services include asset allocation, investment management, financial and retirement planning and net worth/cash flow planning. We generally expect that our clients’ investments are mutual funds and exchange traded funds. Our services and processes are designed to determine and address our individual client’s general wealth management needs, with a focus on coordination and implementation of the client’s overall investment, retirement and tax and estate plans. This process involves the use of a detailed confidential client questionnaire/new account form designed to collect information as to the client’s investment and financial circumstances and objectives, time horizon expectations and risk tolerance as well as the collection of certain key financial documents. We then may prepare a written investment or asset allocation policy based upon the client information collected. Some of our clients’ investments are in what we call Held-Away accounts. Held-Away accounts are client accounts that are accessible by the client, and don't routinely provide for access by investment advisers. In order to provide more comprehensive advice, we recommend that you grant one of our service providers, ByAllAccounts, Inc., access to your Held-Away accounts. ByAllAccounts, Inc. downloads the holdings information for these accounts to our portfolio management software so we can take those investments into account when we invest your portfolio. We can also provide recommendations for changes in the Held-Away accounts, when appropriate. At no time will we be able to access your Held-Away account directly. Page 1  We will tailor our advisory services to our clients’ individual needs based on meetings and conversations with each client. If clients wish to impose certain restrictions on investing in certain securities or types of securities, we will address those restrictions with the client to have a clear understanding of the client’s requirements. We do not provide portfolio management services to a wrap fee program. Financial Planning CTA offers financial planning services to its clients. Financial planning involves an 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. CTA gathers required information through personal interviews. Information gathered may include the client's current financial status, tax status, future goals, objectives and attitudes towards risk. CTA carefully reviews information supplied by the client in preparing recommendations. Should the client choose to implement the recommendations made, CTA suggests the client work closely with his/her attorney, accountant, insurance agent, and/or stockbroker. Implementation of financial plan recommendations is entirely at the client's discretion. Financial Planning recommendations are typically not limited to any specific product or service offered by a broker dealer or insurance company. All recommendations are generally of a generic nature. Assets Under Management As of March 31, 2026, we have $402.6 million in discretionary assets under management. We have no non-discretionary assets under management. ITEM 5: FEES AND COMPENSATION Wealth Management CTA is typically compensated for its investment advisory services by charging you a management fee based on the market value of your assets under our management according to the fee schedule set forth below: Assets under Management Annual Fee First $500,000 $500,000 - $2,000,000 $2,000,000 - $5,000,000 Over $5,000,000 1.50% 1.20% 1.00% Negotiable Fees are billed quarterly in arrears based upon the market value of the assets at the end of the quarter. If your relationship with us has begun or ended during a calendar quarter, your fee will be will be prorated for the appropriate number of days completed or remaining in the quarter and you will be issued an invoice for the final fees. We may negotiate the amount of your fee depending upon circumstances including but not limited to account composition and complexity; other client employee or family relationships; or other conditions which may result in different fees being charged by us for client accounts similar in composition and objectives. Our employees and their family related accounts may be charged a reduced fee, or no fee, for our services. Page 2  Financial planning services are included in the management fees disclosed above. We require that you authorize your custodian to allow us to directly debit our fee from your account or accounts. Please note that your custodian will not confirm our fee but will pay the amount based on the fee amount communicated to the custodian by us and send it directly to us. You will receive a periodic statement from your custodian which will include the amount of the fee which has been sent to us. You will also receive an invoice, which shows the fee calculation, in your quarterly report package from CTA. You should confirm the accuracy of our fee calculation upon receipt of your custodian’s statement and CTA’s invoice. Other Costs Involved The fees you pay us do not include brokerage commissions or other fees or charges associated with securities transactions implemented with or through a brokerage firm, mark-ups or mark-downs in principal transactions, deferred sales charges, stock exchange fees, wire transfer or related processing fees, transfer taxes or other charges mandated by law or regulation, all of which will be charged to you in addition to our fee. We do not receive any portion of any of the foregoing expenses or fees. You should go to the section on Brokerage Practices in our brochure for more information on how we select or recommend brokerage firms for your securities transactions and information related to that process. You should understand that mutual funds, including exchange traded funds, in which your assets are invested by us or by others, impose separate investment management fees and other operating expenses, described in each fund’s prospectus, for which you, the client, will be charged separately from the fee paid to us for our services. Neither Goldberg, CTA, nor its supervised persons accept compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. You can find additional information about brokerage costs and what is provided by brokers in Item 12: Brokerage Practices. We believe the fees mentioned above are competitive; however you may be able to obtain similar services from other sources at a lower price. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not receive performance-based fees for any client account. Our investment advisory clients are managed using a separate investment style. ITEM 7: TYPES OF CLIENTS Our clients may include individual persons, pension and profit sharing plans, trusts, estates, charitable organizations, corporations or similar business, other investment advisers, and governmental entities. Generally, our minimum account size is $500,000 for individual clients although this may be waived based on other considerations such as the account’s relationship to existing clients and other factors. Page 3  ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS CTA may utilize fundamental, technical or cyclical analysis techniques in formulating investment advice or managing assets for clients, using various information sources. Fundamental analysis of businesses involves analyzing its financial statements and health, its management and competitive advantages and its competitors and markets. Fundamental analysis is performed on historical and present data but with the goal of making financial forecasts. There are several possible objectives; to conduct a company stock valuation and predict its probable price evolution; to make a projection on its business performance; to evaluate its management and make internal business decisions and to calculate its credit risk. Technical analysis is a method of evaluating securities by relying on the assumption that market data, such as charts of price, volume and open interest can help predict future (usually short-term) market trends. Technical analysis assumes that market psychology influences trading in a way that enables predicting when a stock will rise or fall. Cyclical analysis of economic cycles is used to determine how these cycles affect the returns of an investment, an asset class or an individual company’s profits. Cyclical risks exist because the broad economy has been shown to move in cycles, from periods of peak performance followed by a downturn, then a trough of low activity. Between the peak and trough of a business or other economic cycle, investments may fall in value to reflect the uncertainty surrounding future returns as compared with the recent past. The investment strategies CTA will implement may include long-term purchases of securities held at least for one year, short-term purchases for securities sold within a year, or trading of securities sold within 30 days. Clients need to be aware that investing in securities involves risk of loss that clients need to be prepared to bear. The methods of analysis and investment strategies followed by CTA are utilized across all of our clients, as applicable. One method of analysis or investment strategy is not more significant than the other as CTA is considering the client’s portfolio, risk tolerance, time horizon and individual goals. However, the client should be aware that with any trading that occurs in the client account, the client will incur transaction and administrative costs. Investing includes the risk that the value of an investment can be negatively affected by factors specifically related to the investment (e.g., capability of management, competition, new inventions by other companies, lawsuits against the company, labor issues, patent expiration, etc.), or to factors related to investing and the markets in general (e.g., the economy, wars, civil unrest or terrorism around the world, concern about oil prices or unemployment, etc.). Clients need to be aware that investing in securities involves risk of loss of some or all of their investment that clients need to be prepared to bear. We do not primarily recommend a particular type of security. However, clients are advised that many unexpected broad environmental factors can negatively impact the value of portfolio securities causing the loss of some or all of the investment, including changes in interest rates, political events, natural disasters, and acts of war or terrorism. Further, factors relevant to specific securities may have negative effects on their value, such as competition or government regulation. Also, the factors for which the company was selected for inclusion in a client portfolio may change, for example, due to changes in management, new product introductions, or lawsuits. Page 4  All investments involve different degrees of risk. You should be aware of your risk tolerance level and financial situations at all times. We cannot guarantee the successful performance of an investment and we are expressly prohibited from guaranteeing accounts against losses arising from market conditions. Risks of fundamental analysis may include risks that market actions, natural disasters, government actions, world political events or other events not directly related to the price or valuation of a specific company’s fundamental analysis can adversely impact the stock price of a company causing a portfolio containing that security to lose value. Risks may also include that the historical data and projections on which the fundamental analysis is performed may not continue to be relevant to the operations of a company going forward, or that management changes or the business direction of management of the company may not permit the company to continue to produce metrics that are consistent with the prior company data utilized in the fundamental analysis, which may negatively affect our estimate of the valuation of the company. In cyclical analysis, economic or business cycles may not be predictable and may have many fluctuations between long-term expansions and contractions. Also, the lengths of the economic cycles may be difficult to predict with accuracy. Therefore, the risk of cyclical analysis is the difficulty in predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. The primary risks in technical analysis are that the factors used to analyze the price, trends and volatility of a security may not be replicated, or the outcomes of such analysis will not be the same as in past periods where similar combinations existed. Because of the reliance on trends, technical analysis can signal buying at market peaks and selling at market troughs. Investing in securities such as the types of securities used by us in managing your assets or providing you investment advice involves the potential risk of loss in the value of the securities both in the amount invested in the securities as well as any profits which have not been realized by selling the securities. You should be prepared to bear the risk of such losses. The degree of risk depends upon the type of security or strategy involved. ITEM 9: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of the investment advisor and each investment advisor representative providing investment advice to you. We have no information of this type to report. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS CTA and its principals/owners do not have any additional outside business activities in the financial industry. Page 5  ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics We have adopted a set of enforceable guidelines (Code of Ethics), which describes unacceptable conduct by Goldberg and our associated persons. Summarized, this Code of Ethics prohibits us from: placing our interests before yours,  using non public information gathered when providing services to you for our own gains, or   engaging in any act, practice or course of business that is, or might be considered, fraudulent, deceptive, manipulative, or in violation of any applicable law, rule or regulation of a governmental agency. Please contact us if you would like to receive a full copy of this Code of Ethics. Personal Trading for Associated Persons We may buy or sell some of the same securities for you that we already hold in our personal account. We may also buy for our personal account some of the same securities that you already hold in your account. It is our policy not to permit our associated persons (or their immediate relatives) to trade in a way that takes advantage of price movements caused by your transactions. We may restrict trading for a particular security for our accounts or those of our associated person if there is a pending trade in that security in a client account. Trades for our accounts (and those of our associated persons) will be placed as part of a block trade with client trades, or individually after client trades have been completed. Additional information about block trades is provided in “Item 12: Brokerage Practices.” When our trades are placed after our client trades, we may receive a better or worse price than that received by the client. CTA and its associated persons may purchase or sell specific securities for their own account based on personal investment considerations without regard to whether the purchase or sale of such security is appropriate for clients. All persons associated with us are required to report all personal securities transactions to us quarterly. ITEM 12: BROKERAGE PRACTICES The Custodian and Brokers We Use We do not maintain custody of your assets that we manage, although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see “Item 15: Custody”). Your assets must be maintained in an account at a “qualified custodian,” generally a broker/dealer or bank. We recommend that our clients use Charles Schwab & Co., Inc. (“Schwab”), a registered broker- dealer, member SIPC as the qualified custodian. We are independently owned and operated and are not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend Page 6  that you use Schwab as custodian/broker, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. Conflicts of interest associated with this arrangement are described below as well as in "Item 14: Client Referrals and Other Compensation". You should consider these conflicts of interest when selecting your custodian. We do not open the account for you, although we may assist you in doing so. How We Select Brokers/Custodians We seek to recommend a custodian/broker who will hold your assets and execute transactions on terms that are, overall, most advantageous when compared to other available providers and their services. We consider a wide range of factors, including, among others:  Combination of transaction execution services and asset custody services (generally without a separate fee for custody)  Capability to execute, clear, and settle trades (buy and sell securities for your account)  Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.)  Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (ETFs), etc.)  Availability of investment research and tools that assist us in making investment decisions  Quality of services  Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices  Reputation, financial strength, and stability Prior service to us and our other clients   Availability of other products and services that benefit us, as discussed below (see “Products and Services Available to Us From Schwab”) Your Brokerage and Custody Costs For our clients’ accounts that Schwab maintains, Schwab generally does not charge you separately for custody services but is compensated by charging you commissions or other fees on trades that it executes or that settle into your Schwab account. Certain trades (for example, many mutual funds and ETFs) may not incur Schwab commissions or transaction fees. Schwab is also compensated by earning interest on the uninvested cash in your account in Schwab’s Cash Features Program. In addition to commissions, Schwab charges you a flat dollar amount as a “prime broker” or “trade away” fee for each trade that we have executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into your Schwab account. These fees are in addition to the commissions or other compensation you pay the executing broker-dealer. Because of this, in order to minimize your trading costs, we have Schwab execute most trades for your account. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Schwab, we have determined that having Schwab execute most trades is Page 7  consistent with our duty to seek "best execution" of your trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above (see "How we Select Brokers/Custodians"). By using another broker or dealer you may pay lower transaction costs. Products and Services Available to Us From Schwab Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. They provide us and our clients with access to their institutional brokerage services (trading, custody, reporting, and related services), many of which are not typically available to Schwab retail customers. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. Following is a more detailed description of Schwab’s support services: Services that benefit you. Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit you and your account. Services that do not directly benefit you. Schwab also makes available to us other products and services that benefit us but do not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We may use this research to service all or a substantial number of our clients’ accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that:  Provide access to client account data (such as duplicate trade confirmations and account statements) Facilitate trade execution and allocate aggregated trade orders for multiple client accounts  Provide pricing and other market data  Facilitate payment of our fees from our clients’ accounts   Assist with back-office functions, recordkeeping, and client reporting Services that generally benefit only us. Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include:  Educational conferences and events  Consulting on technology and business needs  Consulting on legal and related compliance needs Publications and conferences on practice management and business succession   Access to employee benefits providers, human capital consultants, and insurance providers  Marketing consulting and support Page 8  Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some of these services or pays all or a part of the third party's fees. Schwab also provides us with other benefits, such as occasional business entertainment of our personnel. If you did not maintain your account with Schwab we would be required to pay for these services from our own resources. Our Interest in Schwab's Services The availability of these services from Schwab benefits us because we do not have to produce or purchase them. We don’t have to pay for Schwab’s services. These services are not contingent upon us committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate, our [selection/recommendation] of Schwab as custodian and broker is in the best interests of our clients. Our selection is primarily supported by the scope, quality, and price of Schwab’s services (see “How We Select Brokers/Custodians”) and not Schwab’s services that benefit only us. Aggregation of Orders We may combine orders into block trades when more than one account is participating in the trade, including accounts for associated persons. This blocking or bunching technique must be equitable and potentially advantageous for each such account (e.g. for the purposes of reducing brokerage commissions or obtaining a more favorable execution price). Block trading is performed when it is consistent with the duty to seek best execution and is consistent with the terms of our investment advisory agreements. Equity trades are blocked based upon fairness to client, both in the participation of their account, and in the allocation of orders for the accounts of more than one client. Allocations of all orders are performed in a timely and efficient manner. All managed accounts participating in a block execution receive the same execution price (average share price) for the securities purchased or sold in a trading day. Any portion of an order that remains unfilled at the end of a given day will be rewritten on the following day as a new order with a new daily average price to be determined at the end of the following day. Due to the low liquidity of certain securities, broker availability may be limited. Open orders are worked until they are completely filled, which may span the course of several days. If an order is filled in its entirety, securities purchased in the aggregated transaction will be allocated among the accounts participating in the trade in accordance with the allocation statement. If an order is partially filled, the securities will be allocated pro rata based on the allocation statement. CTA may allocate trades in a different manner than indicated on the allocation statement (non-pro rata) only if all managed accounts receive fair and equitable treatment. Soft Dollars The receipt of goods and/or services from the required custodian in connection with providing advice to clients is seen by the regulators as “soft dollars.” The additional services we receive from Schwab, as disclosed in the section entitled “Products and Services Available to Us From Schwab” above, would fall under this description of soft dollars. Page 9  ITEM 13: REVIEW OF ACCOUNTS Wealth Management Our clients’ accounts are reviewed on a monthly basis by John Goldberg, Managing Member, Sanford Lowengart, Portfolio Manager/Chief Operating Officer, and/or Paul Evans and Jeff Lambert, each a Portfolio Manager. CTA provides a quarterly report that includes an Asset Allocation report, a Portfolio Valuation Report, a Performance Report with index returns, the invoice detailing the quarterly fee, and a notes page with definitions and disclosures. We urge our clients to carefully compare brokerage account statements provided by the custodian against the information CTA provides in these reports to ensure that all account transactions, holdings and values are correct and current. These quarterly reports will include details of the cost basis for each security as well as market value and income yield, separated by asset classes and possibly grouped with other accounts related to you. This report will also include an invoice for our quarterly fee. On an quarterly basis you will also receive a report from us which will track all activity including income earned, contributions, withdrawals and capital gains. You should also receive written reports directly from your custodian concerning your account(s) which generally contain information relating to all transactions and other account activity. Factors which may trigger more frequent reviews include change in client investment objectives or circumstances such as retirement or a large contribution or withdrawal to or from an account, significant developments or events specific to a particular security held in the account, or significant market, economic or political developments. Market activity and/or investment policy statements may trigger interim reviews of client accounts. Account holdings will also be reviewed at any time changing market conditions warrant or as dictated by changes to clients’ specific situations as communicated to CTA by clients. Financial Planning Financial planning clients will receive an initial plan report. John Goldberg reviews financial plans with clients annually. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. You do not pay more for assets maintained at Schwab as a result of these arrangements. However, we benefit from the referral arrangement because the cost of these services would otherwise be borne directly by us. You should consider these conflicts of interest when selecting a custodian. These products and services, how they benefit us, and the related conflicts of interest are described above (see Item 12: Brokerage Practices”). We do not pay for client referrals. Page 10  ITEM 15: CUSTODY Under government regulations, we are deemed to have custody of your investment advisory account assets if, for example, you authorize us to instruct the Custodian to deduct our advisory fees directly from your account. Schwab maintains actual custody of your assets. You will receive account statements directly from your Custodian at least quarterly. They will be sent to the email or postal mailing address you provided. You should carefully review those statements promptly when you receive them. We also urge you to compare the Custodian's account statements to the periodic portfolio reports you will receive from us. At no time do we accept physical custody of client assets. ITEM 16: INVESTMENT DISCRETION CTA generally has discretion over the selection and amount of securities to be bought or sold in client accounts without obtaining prior consent or approval from the client for each transaction. However, these purchases or sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the client and agreed to by CTA. Discretionary authority will only be provided upon full disclosure to the client. The granting of such authority will be evidenced by the client’s execution of an Investment Advisory Agreement containing all applicable limitations to such authority. All discretionary trades made by CTA will be in accordance with each client’s investment objectives and goals. ITEM 17: VOTING CLIENT SECURITIES We do not accept the authority to vote proxies on your behalf and we do not provide guidance about how to vote proxies. You will receive proxies and other related paperwork directly from your custodian. Please contact your investment manager by calling (415) 399-9100 if you want to discuss how to vote a specific proxy solicitation. ITEM 18: FINANCIAL INFORMATION We do not charge or solicit pre-payment of more than $1,200 in fees per client six months or more in advance. We have never filed for bankruptcy and are not aware of any financial conditions that are reasonably likely to impair our ability to meet our contractual obligations to clients. Page 11