COLLABORATIVE CAPITAL ADVISORS LLC

Collaborative Capital Advisors Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Collaborative Capital Advisors. If you have any questions about the contents of this brochure, please contact us at 646-933-5730 or by email at: info@collabadv.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 Collaborative Capital Advisors is also available on the SEC’s website at www.adviserinfo.sec.gov. Collaborative Capital Advisors’ CRD number is: 337588. 1120 Ave of the Americas 13th Floor New York, NY 10036 646-933-5730 info@collabadv.com https://www.collaborativecapitaladvisors.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 12/11/2025 i  Item 2: Material Changes This Item of the Brochure discusses only specific material changes that are made to the Brochure and provides clients with a summary of such changes. The following is a summary of the material changes made to Items in this Brochure since the initial version dated August 28, 2025: • Item 4 was amended (a) to add that Nathan Paul Romano and Jonathan Michael Bergman are indirect principal owners of Collaborative Capital Advisors, and (b) to describe CCA’s advisory services to certain private funds. • Items 5, 6, 7 and 11 were amended to describe (a) that CCA advises certain private funds, (b) fees that CCA or its affiliate earn when CCA recommends that clients invest in a private fund advised by CCA, (b) how CCA or its affiliate earns performance fees (i.e., in the form of carried interest), and (3) the apparent conflicts that these fee arrangements present for CCA, and how CCA mitigates and/or discloses them. • Item 5 was amended to add that accounts of family members may be included together for calculation of advisory fee breakpoints, at CCA’s sole discretion. • Item 8 was amended to enhance the description of the strategies, and specific types of investments engaged in by CCA, and risks associated with these strategies and investments. • Item 12 was amended (a) to enhance the description of how CCA recommends brokers/custodians that clients ultimately open accounts with, and certain risks that are associated with client’s selection of those custodian/brokers, and (b) to describe CCA’s trade error policy, including how trade errors may be netted under certain limited and de-mimimis circumstances. Certain other non-material changes were made to either enhance or clarify existing disclosures. We will provide you with a new Brochure as necessary when there are material changes, or when you request one, without charge. Currently, our Brochure may be requested by contacting our Chief Compliance Officer at 646-933-5730. ii  Item 3: Table of Contents Item 1: Cover Page Item 2: Material Changes ....................................................................................................................................... ii Item 3: Table of Contents ...................................................................................................................................... iii Item 4: Advisory Business ......................................................................................................................................2 Item 5: Fees and Compensation .............................................................................................................................5 Item 6: Performance-Based Fees and Side-By-Side Management ....................................................................7 Item 7: Types of Clients ..........................................................................................................................................7 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss ...............................................................8 Item 9: Disciplinary Information .........................................................................................................................16 Item 10: Other Financial Industry Activities and Affiliations .........................................................................16 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...............17 Item 12: Brokerage Practices ................................................................................................................................19 Item 13: Review of Accounts ................................................................................................................................21 Item 14: Client Referrals and Other Compensation ..........................................................................................21 Item 15: Custody ....................................................................................................................................................22 Item 16: Investment Discretion ............................................................................................................................23 Item 17: Voting Client Securities (Proxy Voting) ..............................................................................................24 Item 18: Financial Information .............................................................................................................................24 iii  Item 4: Advisory Business A. Description of the Advisory Firm Collaborative Capital Advisors (hereinafter “CCA”) is a Limited Liability Company organized in the State of Delaware. The firm was formed in June 2025, and the principal owner is Collaborative Capital Holdings LLC, which in turn is principally owned by Nathan Paul Romano and Jonathan Michael Bergman. B. Types of Advisory Services Portfolio Management Services As described in Item more detail in Item 7, CCA offers ongoing portfolio management services via separately managed accounts primarily to high-net-worth individuals based on the individual goals, objectives, time horizon, and risk tolerance of each client. CCA creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: • • • Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring CCA evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. CCA will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. CCA also provides investment advisory services to partnerships, trusts, estates, charitable organizations, educational institutions, retirement accounts, pension and profit-sharing plans, corporations and other types of business entities associated with its individual clients, and other institutional clients from time to time. CCA seeks to provide that investment decisions are made in accordance with the fiduciary duties owed to its accounts and without consideration of CCA’s economic, investment or other financial interests. To meet its fiduciary obligations, CCA attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, CCA’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is CCA’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including 2  initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. CCA may direct clients to third-party (i.e., not affiliated with CCA) investment advisers to manage all or a portion of the client's assets. Before selecting other advisers for clients, CCA will always ensure those other advisers are properly licensed or registered as an investment adviser. CCA conducts due diligence on any third-party investment adviser, which may involve one or more of the following: phone calls, meetings and review of the third-party adviser's performance and investment strategy. CCA then makes investments with a third-party investment adviser by referring the client to the third-party adviser. These investments may be allocated either through the third-party adviser's fund or through a separately managed account managed by such third-party adviser on behalf of CCA's client. CCA may also allocate among one or more private equity funds or private equity fund advisers. CCA will review the ongoing performance of the third-party adviser as a portion of the client's portfolio. CCA also advises certain private funds (“Funds"). The Funds advised are generally those offered to investors who meet minimum requirements, including that they are an “accredited investor” within the meaning of Regulation D promulgated under the Securities Act of 1933 (as amended), or a “qualified purchaser” as such term is defined under the Investment Company Act (as amended), and in certain circumstances a “Qualified client”1 within the meaning of the rules and regulations promulgated under the Investment Advisers Act (as amended). Financial planning advisory services may include, but are not limited to: life insurance; tax concerns; retirement planning; and education planning. Financial planning is included with portfolio management services. CCA does not sell insurance or provide tax or legal advice, rather CCA provides introductions and coordinates with qualified service providers who provide insurance, tax or legal services as the need arises. Services Limited to Specific Types of Investments CCA generally limits its investment advice to mutual funds, fixed income securities, real estate funds (including REITs), insurance products including annuities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, commodities, non-U.S. securities, venture capital funds, crypto currencies and private (equity, credit, and other) placements. CCA may use other securities as well to help diversify a portfolio when applicable. 1 While CCA does not generally charge performance-based fees to investment advisory contract clients, such clients that meet the definition of “Qualified Client” may at any time enter into an agreement with CCA to be charged performance fees (a “Performance Fee”). The Performance Fee, if charged, is negotiable. As of August 16, 2021, Qualified Client is defined as: “…a natural person who, or a company that: (a) immediately after entering into the contract has at least $1,100,000 under the management of the investment adviser; or (b) the investment adviser entering into the contract (and any person acting on his behalf) reasonably believes, immediately prior to entering into the contract, either: (i) has a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more than $2,200,000 or (ii) is a qualified purchaser as defined in section 2(a)(51)(A) of the Investment Company Act of 1940 at the time the contract is entered into.” 3  Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. We also have a fiduciary duty under the Investment Advisers Act of 1940 with respect to all client accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. C. Client Tailored Services and Client Imposed Restrictions CCA will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by CCA on behalf of the client. An investment policy statement is created at the onset of every relationship. Factors that drive asset allocation include liquidity needs, risk tolerance, tax consequences and investor sophistication. CCA may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose reasonable restrictions on investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent CCA from properly servicing the client account, or if the restrictions would require CCA to deviate from its standard suite of services, CCA reserves the right to end the relationship. D. Wrap Fee Programs A wrap fee program is an investment program where the investor pays one stated fee that includes management fees and transaction costs. CCA does not participate in wrap fee programs. E. Assets Under Management CCA has the following assets under management: 4  Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $ 282,151,805 $ 99,753,915 December 1, 2025 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees Total Assets Under Management Annual Fees $0 - $25,000,000 0.75% $25,000,001 - $100,000,000 0.60% $100,000,001 - AND UP 0.50% The advisory fee is calculated using the value of the assets in the Account on the last business day of the prior billing period. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Accounts of family members may be included together for calculation of advisory fee breakpoints, at CCA’s sole discretion. Clients may terminate the agreement without penalty for a full refund of CCA's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract generally with 90 days' written notice. Selection of Other Advisers Fees Clients will pay CCA its standard fee in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between CCA, each third-party adviser, and/or the client. The fees will not exceed any limit imposed by any regulatory agency. Private Fund Fees The Funds that CCA advises each have offering documents that will detail the fees that an investor will pay to service providers, like CCA, as well as other fund expenses, the frequency with which these fees and expenses are charged, and how they are accounted for by the Funds and reported to investors. These fees often differ from the fees that are typically charged directly to clients pursuant to an investment advisory contract, and an important difference is further described below in Item 6 of this brochure. When an investment in the Funds is recommended by CCA, to CCA clients, the client will pay a management fee to CCA pursuant to the investment advisory agreement with CCA. 5  When CCA advises clients to invest in a Fund where CCA is also an adviser, the client will not pay management fees on the Fund level, but clients will, depending on the Fund, pay a performance fee (in the form of carried interest) as investors in the Fund, to an affiliate of CCA. Other Funds may have different fee structures, but CCA will avoid having the client pay asset or performance-based fees on both client advisory and the fund level. Although waiving of the asset-based fee on either the client advisory level or at the Fund level is a substantial mitigant, such a fee structure where CCA and its affiliate earn an asset based fee and a performance based fee, will be more profitable than the asset based fees typically charged to advisory clients, and therefore CCA may have a conflict when offering or recommending the Funds to advisory clients. CCA takes its fiduciary duties seriously and will recommend investment in the Funds only when it is suitable and in the best interests of the client, and with full disclosure of the fee structure. B. Payment of Fees Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis, or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in advance. Payment of Selection of Other Advisers Fees The timing, frequency, and method of paying fees for selection of third-party managers will depend on the specific third-party adviser selected. C. Client Responsibility For Third Party Fees Clients are responsible for the payment of all third-party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, borrowing fees, etc.). Those fees are separate and distinct from the fees and expenses charged by CCA. Please see Item 12 of this brochure regarding broker-dealer/custodian. D. Prepayment of Fees CCA collects fees in advance. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check, or return deposit back into the client’s account. For all asset-based fees paid in advance, the fee refunded will be equal to the balance of the fees collected in advance minus the daily rate* times the number of days elapsed in the billing period up to and including the day of termination. (*The daily rate is calculated by dividing the annual asset-based fee rate by 365.) 6  E. Outside Compensation For the Sale of Securities to Clients Neither CCA nor its supervised persons accept any compensation for the sale of securities or other investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management As described in Item 5 above, when CCA advises Funds, fees to CCA or its affiliate include performance-based fees (carried interest) which are fees based on a share of capital gains or capital appreciation. Direct investment advisory clients are generally NOT charged performance- based fees as part of the investment advisory agreement directly with them. Managing both kinds of accounts at the same time presents a conflict of interest because CCA or its supervised persons have an incentive to favor the Funds due to receipt of performance-based fees (e.g., carried interest). CCA addresses the conflicts by only recommending private fund investments when appropriate and suitable, and with disclosure of the fee structure. CCA seeks best execution and upholds its fiduciary duty for all clients and Funds. Clients who are investors in Funds that are paying a performance-based fee (e.g., carried interest) should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes. More information about potential conflicts can be found in Item 11 of this Brochure. Item 7: Types of Clients CCA’s clients include, without limitation: • • • • family offices; individuals and high net worth individuals; trusts, estates or charitable organizations; and corporations, limited liability companies and/or other business types. CCA generally works with clients client with net worths of $25,000,000 or more. However, we can accept clients of any net worth, and on occasion work with clients whose net worth is below this threshold. CCA also provides investment advisory services to partnerships, trusts, estates, charitable organizations, educational institutions, retirement accounts, pension and profit-sharing plans, corporations and other types of business entities associated with its individual clients, and other institutional clients from time to time, including Funds as described above in Items 4, 5 and 6. 7  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis CCA’s methods of analysis include Fundamental analysis, Modern portfolio theory and Quantitative analysis. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Investment Strategies CCA uses but is not limited to long term trading, short term trading, short sales, margin transactions and options trading (including covered options, uncovered options, hedging or spreading strategies Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will 8  evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Investment Strategies CCA's use of short sales, margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Selection of Other Advisers: Although CCA will seek to select only money managers who will invest clients' assets with the highest level of integrity, CCA's selection process cannot ensure that money managers will perform as desired and CCA will have no control over the day-to-day operations of any of its selected money managers. CCA would not necessarily be aware of certain activities at the underlying money manager level, including without limitation a money manager's engaging in unreported risks, investment “style drift” or even regulatory breaches or fraud. Short sales entail the possibility of infinite loss. An increase in the applicable securities’ prices will result in a loss and, over time, the market has historically trended upward. Short term trading risks include liquidity, economic stability, and inflation, in addition to the long term trading risks listed above. Frequent trading can affect investment performance, particularly through increased brokerage and other transaction costs and taxes. 9  implemented, hedging reduces volatility without Hedging, while usually intended to reduce risk, involves other risks that should be understood by clients. Hedging involves using financial instruments (e.g., derivatives, options, futures, etc.) or strategic asset allocation to reduce exposure to market, currency, or interest rate risk. Its primary purpose is risk transfer, not profit amplification. Hedging rarely eliminates all risk; there is often basis risk (difference between the hedge and underlying exposure) and model risk (mispricing or misestimation of hedge ratios). Hedging typically involves upfront costs (e.g., option premiums), potentially reducing net returns. Properly introducing asymmetric tail risk. Extreme market movements are mitigated by the hedge instruments. Poor execution, however, can increase risk inadvertently (e.g., incorrect hedge ratios, liquidity constraints). Some hedging instruments may be less liquid, impacting the ability to close positions promptly during market stress. In essence, the “risk of hedging” is mostly cost-efficiency and imperfect hedge execution, rather than exposure to market loss. Proper hedges generally reduce portfolio variance and tail risk. Risks Associated with Non-Diversification: CCA intends to hold diversified positions; however, unless otherwise provided in a client contract or Fund governing document, it is not subject to any formal policies regarding diversification. CCA may sometimes concentrate holdings in industries, geographic regions, or companies which, in light of investment considerations, market risks and other factors, that it believes will provide the best opportunity for attractive risk-adjusted returns. The concentration of assets in a single or small number of issuers, in any one industry or a small number of industries, or in a single industry would subject clients or Funds to a greater degree of risk with respect to the failure of one or a few investments or with respect to economic variations in relation to such industry or industries. Epidemic or Serious Public Health Event Risk: CCA’s business activities, as well as its operations and investments, could be materially adversely affected by outbreaks of disease, epidemics and public health issues in Asia, Europe, North America, the Middle East and/or globally, such as COVID-19 (and other novel coronaviruses), Ebola, H1N1 flu, H7N9 flu, H5N1 flu, Severe Acute Respiratory Syndrome, or SARS, or other epidemics, pandemics, outbreaks of disease or public health issues. An outbreak or recurrence of any kind of epidemic, communicable disease, virus, or major public health issue could cause a slowdown in the levels of economic activity generally (or push the world or local economies into recession), which would be reasonably likely to adversely affect the business, financial condition and operations of CCA. Should these or other major public health issues, including pandemics, arise, spread farther or worsen, CCA and the value of client accounts could be adversely affected by more stringent travel restrictions (such as mandatory quarantines and social distancing), limitations on CCA’s operations and business activities and governmental actions limiting the movement of people and goods between regions and other activities or operations. Cyber Security Breaches and Identity: The information technology systems of CCA and its third-party service providers may be vulnerable to damage or interruption from computer viruses, network failures, computer and telecommunication failures, infiltration by unauthorized persons and security breaches, usage errors by its 10  professionals, power outages and catastrophic events such as fires, tornadoes, floods, hurricanes, and earthquakes. Although CCA and its third-party service providers have implemented various measures to manage risks relating to these types of events, if these systems are compromised, become inoperable for extended periods of time, or cease to function properly, CCA may have to make a significant investment to fix or replace them. The failure of these systems and/or of disaster recovery plans for any reason could cause significant interruptions in CCA’s operations and result in a failure to maintain the security, confidentiality, or privacy of sensitive data, including personal information relating to account holders, beneficial owners, or investors. Such a failure could harm CCA’s reputation, subject any such entity and its respective affiliates to legal claims and otherwise affect its business and financial performance. Risk of Default or Bankruptcy of Third Parties: Client accounts may engage in transactions in securities and other financial instruments and assets that involve counterparties. Under certain conditions, the client could suffer losses if a counterparty to a transaction were to default or if the market for certain securities or other financial instruments or assets were to become illiquid. In addition, the client could suffer losses if there were a default or bankruptcy by certain other third parties, including brokerage firms and banks with which the client does business, or to which securities or other financial instruments or assets have been entrusted for custodial purposes. Market Disruption and Geopolitical Risk. Each client account is subject to the risk that war, terrorism, country-specific sanctions, and related geopolitical events may lead to increased short-term market volatility and have adverse long-term effects on the U.S. and world economies and markets generally, as well as adverse effects on issuers of securities and the value of the client’s investments. War, terrorism, related geopolitical events, and natural and other disasters have led, and in the future may lead, to increased short-term market volatility and may have adverse long-term effects on U.S. and non-U.S. economies and markets generally. Those events as well as other changes in U.S. and non-U.S. economic and political conditions also could adversely affect individual issuers or related groups of issuers, securities markets, futures markets, interest rates, credit ratings, inflation, investor sentiment and other factors affecting the value of a client’s investments. At such times, a client’s exposure to a number of other risks described elsewhere in this section can increase. It should also be noted that in February 2022, Russia launched a largescale invasion of Ukraine. The extent and duration of Russian military action in the Ukraine, resulting economic sanctions and resulting future market disruptions, including declines in stock markets in Russia and elsewhere, decline in the value of the ruble against the U.S. dollar, or the rise in the price of oil, are impossible to predict, but could be significant. Any disruptions caused by the invasion of Ukraine or other actions (including cyberattacks and espionage) or disruptions resulting from actual or threatened responses to the invasion of Ukraine or other actions could cause disruptions to companies and markets globally. Any such disruptions could have a material adverse effect on client accounts. As of March 2025, there are ongoing military conflicts in the Middle East which, in a relatively short period of time, have caused and are likely to cause in the future disruption to the global financial system and trade and transport, among other things. In response to the conflicts, multiple countries have and may in the future put in place global sanctions and other severe restrictions or prohibitions on the activities of individuals and 11  businesses related to the countries engaging in the conflicts. However, the ultimate impact of these conflicts and their effect on global economic and commercial activity and conditions, and on the operations, financial condition and performance of investment vehicles or any particular industry, business or investee country and the duration and severity of those effects, is impossible to predict. Any conflict around the globe may have a significant adverse impact and result in significant losses to investments. This impact may include reductions in revenue and growth, unexpected operational losses and liabilities and reductions in the availability of capital. It may also limit the ability of CCA to source, diligence and execute new investments and to manage, finance and exit investments in the future. Developing and further governmental actions (military or otherwise) may cause additional disruption and constrain or alter existing financial, legal and regulatory frameworks and systems in ways that are adverse to CCA and/or client accounts or which they intend to pursue, any or all of which could adversely affect CCA’s ability to fulfill its investment objectives. Additional Counterparty Risk: Some of the markets in which the securities or other investments trade may be “over-the-counter” or “interdealer” markets. The participants in such markets are typically not subject to credit evaluation and regulatory oversight as are members of “exchange based” markets. This exposes the client to the risk that a counterparty will not settle a transaction in accordance with its terms and conditions because of a dispute over the terms of the relevant contract or because of a credit or liquidity problem, thus causing the client to suffer a loss. Such risk may be accentuated for contracts with longer maturities where events may intervene to prevent settlement, or where the client has concentrated its transactions with a single or small group of counterparties. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized CCA's use of short sales, margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. 12  Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Risks in investing in ETFs include trading risks, liquidity and shutdown risks, risks associated with a change in authorized participants and non-participation of authorized participants, risks that trading price differs from indicative net asset value (iNAV), or price fluctuation and disassociation from the index being tracked. With regard to trading risks, regular trading adds cost to your portfolio thus counteracting the low fees that one of the typical benefits of ETFs. Additionally, regular trading to beneficially “time the market” is difficult to achieve. Even paid fund managers struggle to do this every year, with the majority failing to beat the relevant indexes. With regard to liquidity and shutdown risks, not all ETFs have the same level of liquidity. Since ETFs are at least as liquid as their underlying assets, trading conditions are more accurately reflected in implied liquidity rather than the average daily volume of the ETF itself. Implied liquidity is a measure of what can potentially be traded in ETFs based on its underlying assets. ETFs are subject to market volatility and the risks of their underlying securities, which may include the risks associated with investing in smaller companies, foreign securities, commodities, and fixed income investments (as applicable). Foreign securities in particular are subject to interest rate, currency exchange rate, economic, and political risks, all of which are magnified in emerging markets. ETFs that target a small universe of securities, such as a specific region or market sector, are generally subject to greater market volatility, as well as to the specific risks associated with that sector, region, or other focus. ETFs that use derivatives, leverage, or complex investment strategies are subject to additional risks. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. The return of an index ETF is usually different from that of the index it tracks because of fees, expenses, and tracking error. An ETF may trade at a premium or discount to its net asset value (NAV) (or indicative value in the case of exchange-traded notes). The 13  degree of liquidity can vary significantly from one ETF to another and losses may be magnified if no liquid market exists for the ETF’s shares when attempting to sell them. Each ETF has a unique risk profile, detailed in its prospectus, offering circular, or similar material, which should be considered carefully when making investment decisions. Real estate funds (including REITs) face several kinds of risk that are inherent in the real estate sector, which historically has experienced significant fluctuations and cycles in performance. Revenues and cash flows may be adversely affected by: changes in local real estate market conditions due to changes in national or local economic conditions or changes in local property market characteristics; competition from other properties offering the same or similar services; changes in interest rates and in the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental laws. Annuities are a retirement product for those who may have the ability to pay a premium now and want to guarantee they receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company designed to meet requirement or other long-term goals. An annuity is not a life insurance policy. Variable annuities are designed to be long-term investments, to meet retirement and other long-range goals. Variable annuities are not suitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Hedge funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Privately placed securities (including those specifically described in this Item) carry a substantial risk as they are subject to less regulation and regulatory oversight than are publicly offered securities and as a result, often lack transparency. The private markets to resell these assets under applicable securities laws may be illiquid, there may be restrictions in the governing documents on the transferability , and the liquidation – if possible at all – may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Additional risks include limited financial disclosures, reliance on the management or issuer’s representations, and the potential for higher volatility due to concentrated or speculative strategies. 14  Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Commodities are tangible assets used to manufacture and produce goods or services. Commodity prices are affected by different risk factors, such as disease, storage capacity, supply, demand, delivery constraints and weather. Because of those risk factors, even a well-diversified investment in commodities can be uncertain. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Cryptocurrency investing refers to trading in digital/virtual currencies, such as Bitcoin, that are not back by real assets or tangible securities and are more volatile than traditional currencies and financial assets. Digital currency is a digital representation of value that functions as a medium of exchange, a unit of account, or a store of value, but it does not have legal tender status. Digital currency is not backed or supported by any government or central bank. Digital currency’s price is completely derived by market forces of supply and demand, traded between consenting parties with no broker and tracked on digital ledgers commonly known as blockchains. Investing in digital currency comes with significant risk of loss that a client should be prepared to bear and, due to the nature of cryptocurrencies, clients are exposed to the risks normally associated with investing but also unique risks not typical of investing in traditional securities. These, include, but are not limited to, volatile market price swings or flash crashes, market manipulation, economic, regulatory, technical, and cybersecurity risks. Please also see below for additional description/properties: • • Unregulated – Digital currency markets and exchanges are not regulated with the same controls or customer protections available in fixed income, equity, option, futures, or foreign exchange investing. Increased Price Volatility – The price of cryptocurrency is constantly fluctuating. Trade or balance can surge or drop suddenly. Price can drop to zero. • Susceptible to Error/Hacking – Technical glitches, human error and hacking can occur, which typically do not affect traditional securities to the same extent. 15  • Forks – This implies a splitting of the chain on which the cryptocurrency runs, which makes it go in a different direction, with different rules than the existing blockchain. o Soft Fork – only a protocol change; the cryptocurrency still continues to work on the original blockchain rules. o Hard Fork – a permanent divergence in the blockchain. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither CCA nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither CCA nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. 16  C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests CCA has a related entity, Collaborative Capital Family Advisors which provides retainer- based fee family office services. From time to time, clients may be offered advice or products from those activities and clients should be aware that these services may involve a conflict of interest. CCA always acts in the best interest of the client and clients always have the right to decide whether or not to utilize the services. D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections CCA may direct clients to third-party investment advisers to manage all or a portion of the client's assets. Clients will pay CCA its standard fee in addition to the standard fee for the advisers to which it directs those clients. This relationship will be memorialized in each contract between CCA, each third-party advisor, and/or the client. The fees will not exceed any limit imposed by any regulatory agency. CCA will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients. CCA will ensure that all recommended advisers are licensed or notice filed in the states in which CCA is recommending them to clients. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics High ethical standards are essential for the success of CCA and to maintain the confidence of clients. CCA’s long-term business interests are best served by adherence to the principle that the interests of clients come first. To this end, and as required by Rule 204A-1 under the Investment Advisers Act of 1940 (as amended), CCA has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. These policies and other procedures of CCA help to assure that CCA has reasonable procedures to, understand its fiduciary duties, ensure the ethical conduct of and by CCA and its supervised persons, identify certain conflicts of interest that must be avoided, and help assure client confidentiality. Compliance with the Code of Ethics and associated compliance manual and procedures is required to be acknowledged by all supervised 17  persons. A copy of CCA’s Code of Ethics is available free upon request to any client or prospective client by contacting the CCO at 646-933-5730. B. Recommendations Involving Material Financial Interests From time to time, CCA will recommend investments in Funds (which it also advises) to those clients for which investment in the fund is suitable. This presents a conflict of interest in that CCA, or its related persons, may receive more compensation from investment in the Fund than from other investments. Nevertheless, CCA acts in the best interests of the client consistently with its fiduciary duties and Clients are not required to invest in the Funds if they do not wish to do so. CCA and/or its related persons receive carried interest from respective Funds, meaning they receive a share of profits upon the sale of a Fund’s asset. Carried interest in a Fund may create an incentive for the CCA and any of the Fund’s General Partners who may received such an interest. CCA does not otherwise recommend that clients buy or sell any security in which a related person to CCA or CCA has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of CCA may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of CCA to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. CCA will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of CCA may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of CCA to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, CCA will never engage in trading that operates to the client’s disadvantage if representatives of CCA buy or sell securities at or around the same time as clients. 18  Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers CCA’s agreements generally provide that clients open accounts with a custodian or other authorized third party for the execution of transactions in securities that are traded publicly and for custodial services. As such, CCA does not generally select these brokers or custodians and executes with the brokers/custodian with which the client has opened an account. Please see Item 12.A.3, below. CCA recommends custodians/broker-dealers based on their provision of comprehensive services that CCA believes are beneficial to clients, and which are complementary to the services that CCA offers. In recommending these custodians/brokers, CCA takes into consideration the custodian/broker’s ability to achieve “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and CCA may also consider the market expertise and research access provided by the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in CCA's research efforts. CCA will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker- dealer/custodian. CCA recommends Schwab Institutional, a division of Charles Schwab & Co., Inc., and Goldman Sachs Custody Services. 1. Research and Other Soft-Dollar Benefits While CCA has no formal soft dollars program in which soft dollars are used to pay for third party services, CCA may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). CCA may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and CCA does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. CCA benefits by not having to produce or pay for the research, products or services, and CCA will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that CCA’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals CCA receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 19  3. Clients Directing Which Broker/Dealer/Custodian to Use Given that CCA’s agreements generally provide that clients open accounts with a custodian or other authorized third party for the execution of securities transactions and custodial services, CCA permits clients to direct it to execute transactions through such Custodian (which will generally be the specified broker-dealer named in the agreement to be the Custodian). When a client directs CCA to use a specified Custodian for brokerage, then the client acknowledges in writing that the client’s direction with respect to the use of brokers supersedes any authority granted to CCA to select brokers; this direction may result in less favorable prices, particularly for illiquid securities or during volatile market conditions. Not all investment advisers allow their clients to direct brokerage. B. Aggregating (Block) Trading for Multiple Client Accounts If CCA buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, CCA would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. CCA would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). C. Trade Errors If CCA makes errors that cause trades to be entered incorrectly for advisory accounts, CCA will first seek to have the broker cancel the trade. Sometimes this will not be possible. In most instances, the cost of such errors will be borne by CCA, and any incidental benefit will be enjoyed by the client, subject to the below process that is followed by Charles Schwab & Co. Inc. (“Schwab”). The majority of CCA’s clients have engaged Charles Schwab & Co. If an investment gain results from correcting a trade error in a Schwab account, the gain will remain in the client account unless the same error involved other client account(s) that should have received the gain, it is not permissible for the client to retain the gain, or CCA confers with the client(s) and applicable clients decide to forego the gain (e.g., due to tax reasons). If the gain does not remain in the applicable Client’s account and Schwab is the custodian, Schwab will donate the amount of any gain $100 and over to charity. If a loss occurs greater than $100, CCA will pay for the loss. Schwab will maintain the loss or gain (if such gain is not retained in the client’s account) if it is under $100 to minimize and offset its administrative time and expense. Generally, if related trade errors result in both gains and losses in your account, they may be netted, typically by Schwab, but CCA may determine to net them independently. 20  Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for CCA's advisory services provided on an ongoing basis are reviewed at least monthly by Charles Friedberg, Chief Compliance Officer, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at CCA are assigned to this reviewer. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Each client of CCA's advisory services provided on an ongoing basis will receive a monthly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) Other than soft dollar benefits as described in Item 12 above and below, CCA does not receive any economic benefit, directly or indirectly from any third party for advice rendered to CCA's clients. With respect to Schwab and Goldman Sachs, CCA receives access to Schwab’s and Goldman’s institutional trading and custody services, which are typically not available to Schwab and Goldman retail investors. These services generally are available to independent investment advisers on an unsolicited basis. Schwab’s services include brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For CCA client accounts maintained in its custody, Schwab and Goldman generally does not charge separately for custody services but is compensated by account holders through 21  commissions or other transaction-related or asset-based fees for securities trades that are executed through Schwab and Goldman or that settle into Schwab and Goldman accounts. Schwab and Goldman also makes available to CCA other products and services that benefit CCA but may not benefit its clients’ accounts. These benefits may include national, regional or CCA specific educational events organized and/or sponsored by Schwab Advisor Services and Goldman Sachs Custody Solutions. Other potential benefits may include occasional business entertainment of personnel of CCA by Schwab Advisor Services and Goldman personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist CCA in managing and administering clients’ accounts. These include software and other technology (and related technological training) 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, if applicable), provide research, pricing information and other market data, facilitate payment of CCA’s fees from its clients’ accounts (if applicable), and assist with back-office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of CCA’s accounts. Schwab Advisor Services and Goldman Sachs Custody Solutions also makes available to CCA other services intended to help CCA manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, human capital consultants, insurance and marketing. In addition, Schwab may make available, arrange and/or pay vendors for these types of services rendered to CCA by independent third parties. Schwab Advisor Services and Goldman Sachs Custody Solutions may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third- party providing these services to CCA. CCA is independently owned and operated and not affiliated with Schwab or Goldman. B. Compensation to Non – Advisory Personnel for Client Referrals CCA does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody CCA does not take physical custody over client’s cash or securities. However, CCA is deemed to have custody in certain situations under guidance issued be the SEC. Specifically, pursuant to the Investment Advisers Act of 1940, CCA is deemed to have “constructive custody” of client funds because we have the authority and ability to debit our fees directly from the accounts of those clients receiving our services. Additionally, certain clients have, and could in the future, sign a Standing Letter of Authorization (“SLOA”) that gives us the authority to transfer funds to a third- party as directed by the client in the SLOA. This is also deemed to give us custody. Custody is 22  defined as any legal or actual ability by the firm to withdraw client funds or securities. Firms with deemed custody must take the following steps: 1. Ensure clients’ managed assets are maintained by a qualified custodian; 2. Have a reasonable belief, after due inquiry, that the qualified custodian will deliver an account statement directly to the client at least quarterly; 3. Confirm that account statements from the custodian contain all transactions that took place in the client’s account during the period covered and reflect the deduction of advisory fees; and 4. Obtain a surprise audit by an independent accountant on the clients’ accounts for which the advisory firm is deemed to have custody. However, the rules governing the direct debit of client fees and SLOAs exempts us from the surprise audit rules if certain conditions (in addition to steps 1 through 3 above) are met. Those conditions are as follows: 1. When debiting fees from client accounts, we must receive written authorization from clients permitting advisory fees to be deducted from the client’s account. 2. In the case of SLOAs, we must: (i) confirm that the name and address of the third party is included in the SLOA, (ii) document that the third-party receiving the transfer is not related to our firm, and (ii) ensure that certain requirements are being performed by the qualified custodian. The qualified custodian that is selected by a client maintains actual physical custody of client assets. Client account statements from custodians will be sent directly to each client to the email or postal mailing address that is provided to the qualified custodian selected by the client. Clients are encouraged to compare information provided in reports or statements received by our firm with the account statements received from their custodian for accuracy. In addition, clients should understand that it is their responsibility, not the custodian’s, to ensure that the fee calculation is correct. If client funds or securities are inadvertently received by our firm, they will be returned to the sender immediately, or as soon as practical. We encourage our clients to raise any questions with us about the custody, safety or security of their assets. The custodians we do business with will send clients independent account statements listing your account balance(s), transaction history and any fee debits or other fees taken out of your account. Item 16: Investment Discretion CCA provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, CCA generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what 23  securities to buy or sell, or the price per share. In some instances, CCA’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to CCA. Item 17: Voting Client Securities (Proxy Voting) CCA will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet CCA neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither CCA nor its management has any financial condition that is likely to reasonably impair CCA’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years CCA has not been the subject of a bankruptcy petition in the last ten years. 24