Dc Capital Management, LLC

DC Capital Management, LLC 101 Gold Run Circle Dillon, Colorado 80435 Phone: 970-468-1339 Web Site: www.dc-cm.com August 14, 2026 FORM ADV PART 2A. BROCHURE This brochure provides information about the qualifications and business practices of DC Capital Management, LLC. If you have any questions about the contents of this brochure, please contact us at 970-468-1339. 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 DC Capital Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for DC Capital Management, LLC is 142841. DC Capital Management, LLC is a registered investment adviser. Registration with the United States Securities and Exchange Commission or any state securities authority does not imply a certain level of skill or training. Material Changes Form ADV Part 2A, Item 2 Since the last annual filing of this Form ADV Part 2A, dated March 27, 2026, the following material change has occurred: Item 4 – We are now registered with the U.S. Securities and Exchange Commission. • Please note, this section discusses changes we consider material and not all changes made.  IARD/CRD No: 142841 DC Capital Management, LLC Form ADV Part 2A Brochure August 14, 2026 Table of Contents Advisory Business ................................................................................................................. 1 Fees and Compensation ........................................................................................................ 1 Performance-Based Fees and Side-By-Side Management ...................................................... 2 Types of Clients ..................................................................................................................... 2 Methods of Analysis, Investment Strategies and Risk of Loss ................................................. 3 Disciplinary Information ....................................................................................................... 6 Other Financial Industry Activities and Affiliations ............................................................... 6 Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........... 6 Brokerage Practices .............................................................................................................. 8 Review of Accounts ............................................................................................................... 8 Client Referrals and Other Compensation ............................................................................. 9 Custody ................................................................................................................................. 9 Investment Discretion ............................................................................................................ 9 Voting Client Securities ....................................................................................................... 10 Financial Information ......................................................................................................... 10  Advisory Business Form ADV Part 2A, Item 4 DC Capital Management, LLC’s registration was granted by the State of Maryland on July 11, 2007, by the State of Colorado on September 4, 2008, and the U.S. Securities and Exchange Commission on July 6, 2026. Sean Paul Butson (CRD Number 2917873) is the “Member” and Chief Compliance Officer of the firm. Mr. Butson is the principal owner of the firm. The firm is not publicly owned or traded. There are no indirect owners of the firm or intermediaries who have any ownership interest in the firm. The firm manages each client’s portfolio on an individualized basis. Clients may impose restrictions. The firm does not sponsor any wrap program. As of December 31, 2025, the firm managed assets on a discretionary basis in the amount of $107,009,732, which represented 236 accounts and $0 on a non- discretionary basis. Firm shall devote approximately seventy (70%) percent of its professional time to the provision of investment supervisory service activity on behalf of advisory clients. Firm shall have discretionary authority over client assets. Firm shall make its investment recommendations in accordance with the Investment Policy Statement or other suitable survey, without the Client’s prior approval of each specific transaction. Under this authority, Client shall allow Firm to purchase and sell securities and instruments in this account, arrange for delivery and payment in connection with the foregoing, and act on behalf of the Client in most matters necessary or incidental to the handling of the account, including monitoring certain assets. In addition to the foregoing, Firm shall provide fee based financial planning services on behalf of certain clients. Firm will elicit all pertinent financial planning related information and shall then, upon detailed analysis of such information, Firm shall prepare, present and deliver a written financial plan to the client. Fees and Compensation Form ADV Part 2A, Item 5 In relation to financial planning fees, an hourly fee of between $150-$400 per hour or a flat fee of between $1,000-$10,000 shall be charged based upon the facts and circumstances of the case and based upon the anticipated complexity of the case. A retainer fee of one-half of the anticipated full fee will be required with the balance due and owing upon completion of the financial planning process. Firm shall base its asset advisory fees upon a percentage of assets under management. All such asset management fees shall be payable quarterly in advance. All advisory fees shall be negotiable. No advisory fee shall be based upon capital gains or upon capital appreciation of assets. The professional relationship may be terminated at will by either the Firm or the advisory client upon thirty days’ written 1  notice served upon the other party. In the event that there should be any unearned or unapplied fees, Firm will refund such fees at once to the advisory client. The adviser may allow the use of margin accounts. If the adviser uses margin accounts, this will result in a client paying additional fees for securities bought on margin. When clients pay an asset management fee based on assets under management as opposed to the net value of an account, they will pay additional fees for securities bought on margin and the adviser has a conflict of interest when securities are bought on margin because this will increase advisory fees. Clients will be required to pay other types of fees and expenses in connection with our advisory services such as custodial fees and/or mutual fund expenses. Clients will incur brokerage and other transaction costs. The client is hereby directed to Item 12 of this narrative which addresses our firm’s brokerage practices. Firm’s investment supervisory fees shall generally be deducted directly from the client’s account, shall be due quarterly in advance, shall be based on the net value of the account as of the last day of the previous quarter, and shall be based upon a percentage of assets under management as follows: Annual Fee Amount of Assets Investment Management Only Investment Management and Financial Planning $0-$500,000 1.00% 1.10% Next $500,000 0.90% 1.00% Next $1,500,000 0.80% 0.90% Next $2,500,000 0.70% 0.80% Over $5,000,000 0.60% 0.70% Performance-Based Fees and Side-By-Side Management Form ADV Part 2A, Item 6 None. Types of Clients Form ADV Part 2A, Item 7 Individuals, pension plans, profit sharing plans, trusts, estates, charitable organizations, corporations and other business entities. 2  Firm requires minimum assets under management of $500,000 for its asset management services. Methods of Analysis, Investment Strategies and Risk of Loss Form ADV Part 2A, Item 8 The following methods will be used by Firm to analyze securities: charting, fundamental, technical and cyclical. Charting analysis involves the gathering and processing of price and volume information for a particular security. This price and volume information is analyzed using mathematical equations. The resulting data is then applied to graphing charts, which is used to predict future price movements based on price patterns and trends. Charts may not accurately predict future price movements. Current prices of securities may not reflect all information about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. Fundamental analysis involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience, and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. Technical analysis involves using chart patterns, momentum, volume, and relative strength in an effort to pick sectors that may outperform market indices. However, there is no assurance of accurate forecasts or that trends will develop in the markets we follow. In the past, there have been periods without discernible trends and similar periods will presumably occur in the future. Even where major trends develop, outside factors like government intervention could potentially shorten them. Furthermore, one limitation of technical analysis is that it requires price movement data, which can translate into price trends sufficient to dictate a market entry or exit decision. In a trendless or erratic market, a technical method may fail to identify trends requiring action. In addition, technical methods may overreact to minor price movements, establishing positions contrary to overall price trends, which may result in losses. Finally, a technical trading method may under perform other trading methods when fundamental factors dominate price moves within a given market. Cyclical analysis is a type of technical analysis that involves evaluating recurring price patterns and trends based upon business cycles. Economic/business cycles may not be predictable and may have many fluctuations between long term expansions and contractions. The lengths of economic cycles may be difficult to predict with accuracy and therefore the risk of cyclical analysis is the difficulty in 3  predicting economic trends and consequently the changing value of securities that would be affected by these changing trends. The following investment strategies will be used by Firm: DCCM has developed five proprietary portfolios that are chosen based on a client’s risk aversion, return expectations, liquidity needs, time horizon, tax implications, legal considerations, and any unique factors: Preservation: to protect your initial investment from significant loss of principal. Conservative: to provide current income rather than long-term growth of principal. Moderate: to provide current income and long-term growth of principal. Aggressive: to increase principal over time while assuming higher volatility. Speculative: to increase principal over time while assuming a high level of volatility. Material Risks Involved All investing strategies we offer involve risk and may result in a loss of your original investment which you should be prepared to bear. Many of these risks apply equally to stocks, bonds, commodities and any other investment or security. Material risks associated with our investment strategies are listed below. Market Risk: Market risk involves the possibility that an investment’s current market value will fall because of a general market decline, reducing the value of the investment regardless of the success of the issuer’s operations or its financial condition. Strategy Risk: The Adviser’s investment strategies and/or investment techniques may not work as intended. Small and Medium Cap Company Risk: Securities of companies with small and micro market capitalizations are often more volatile and less liquid than investments in larger companies. Small and medium cap companies may face a greater risk of business failure, which could increase the volatility of the client’s portfolio. Turnover Risk: At times, the strategy may have a portfolio turnover rate that is higher than other strategies. A high portfolio turnover would result in correspondingly greater brokerage commission expenses and may result in the distribution of additional capital gains for tax purposes. These factors may negatively affect the account’s performance. Limited markets: Certain securities may be less liquid (harder to sell or buy) and their prices may at times be more volatile than at other times. Under certain market conditions we may be unable to sell or liquidate investments at prices we consider reasonable or favorable or find buyers at any price. 4  Concentration Risk: Certain investment strategies focus on particular asset-classes, industries, sectors or types of investment. From time to time these strategies may be subject to greater risks of adverse developments in such areas of focus than a strategy that is more broadly diversified across a wider variety of investments. Interest Rate Risk: Bond (fixed income) prices generally fall when interest rates rise, and the value may fall below par value or the principal investment. The opposite is also generally true: bond prices generally rise when interest rates fall. In general, fixed income securities with longer maturities are more sensitive to these price changes. Most other investments are also sensitive to the level and direction of interest rates. Legal or Legislative Risk: Legislative changes or Court rulings may impact the value of investments, or the securities’ claim on the issuer’s assets and finances. Inflation: Inflation may erode the buying-power of your investment portfolio, even if the dollar value of your investments remains the same. Risks Associated with Securities Apart from the general risks outlined above which apply to all types of investments, specific securities may have other risks. Commercial Paper is, in most cases, an unsecured promissory note that is issued with a maturity of 270 days or less. Being unsecured the risk to the investor is that the issuer may default. Common stocks may go up and down in price quite dramatically, and in the event of an issuer’s bankruptcy or restructuring could lose all value. A slower growth or recessionary economic environment could have an adverse effect on the price of all stocks. Corporate Bonds are debt securities to borrow money. Generally, issuers pay investors periodic interest and repay the amount borrowed either periodically during the life of the security and/or at maturity. Alternatively, investors can purchase other debt securities, such as zero-coupon bonds, which do not pay current interest, but rather are priced at a discount from their face values and their values accrete over time to face value at maturity. The market prices of debt securities fluctuate depending on such factors as interest rates, credit quality, and maturity. In general, market prices of debt securities decline when interest rates rise and increase when interest rates fall. The longer the time to a bond’s maturity, the greater its interest rate risk. Bank Obligations including bonds and certificates of deposit may be vulnerable to setbacks or panics in the banking industry. Banks and other financial institutions are greatly affected by interest rates and may be adversely affected by downturns in the U.S. and foreign economies or changes in banking regulations. Municipal Bonds are debt obligations generally issued to obtain funds for various public purposes, including the construction of public facilities. Municipal bonds pay a lower rate of return than most other types of bonds. However, because of a municipal bond’s tax-favored status, investors should compare the relative after-tax return to the after-tax return of other bonds, depending on the investor’s tax bracket. Investing in municipal bonds carries the same general risks as investing in bonds in general. 5  Those risks include interest rate risk, reinvestment risk, inflation risk, market risk, call or redemption risk, credit risk, and liquidity and valuation risk. Options and other derivatives carry many unique risks, including time-sensitivity, and can result in the complete loss of principal. While covered call writing does provide a partial hedge to the stock against which the call is written, the hedge is limited to the amount of cash flow received when writing the option. When selling covered calls, there is a risk the underlying position may be called away at a price lower than the current market price. Exchange Traded Funds prices may vary significantly from the Net Asset Value due to market conditions. Certain Exchange Traded Funds may not track underlying benchmarks as expected. Investment Companies Risk. When a client invests in open end mutual funds or ETFs, the client indirectly bears its proportionate share of any fees and expenses payable directly by those funds. Therefore, the client will incur higher expenses, many of which may be duplicative. In addition, the client’s overall portfolio may be affected by losses of an underlying fund and the level of risk arising from the investment practices of an underlying fund (such as the use of derivatives). ETFs are also subject to the following risks: (i) an ETF’s shares may trade at a market price that is above or below their net asset value; (ii) the ETF may employ an investment strategy that utilizes high leverage ratios; or (iii) trading of an ETF’s shares may be halted if the listing exchange’s officials deem such action appropriate, the shares are de-listed from the exchange, or the activation of market-wide “circuit breakers” (which are tied to large decreases in stock prices) halts stock trading generally. The Adviser has no control over the risks taken by the underlying funds in which clients invest. Disciplinary Information Form ADV Part 2A, Item 9 None. Other Financial Industry Activities and Affiliations Form ADV Part 2A, Item 10 None. Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Form ADV Part 2A, Item 11 Firm is in full compliance with The Insider Trading and Securities Fraud Enforcement Act of 1988. Furthermore, Firm monitors the personal securities transactions of all access persons. As a fiduciary, 6  our firm and its associates have a duty of utmost good faith to act solely in the best interests of each client. Our clients entrust us with their funds and personal information, which in turn places a high standard on our conduct and integrity. Our fiduciary duty is a core aspect of our Code of Ethics and represents the expected basis of all of our dealings. The Chief Compliance Officer of the firm carries out all compliance related mandates as set forth by the Code of Ethics. A copy of the firm’s Code of Ethics is available upon request by all clients and prospective clients. It is the policy of DCCM to always place the interests of its advisory clients ahead of the interests of DCCM and its principals. As part of this policy, DCCM will not front-run its client’s trades. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of Interest Our firm and its “related persons” may buy or sell securities similar to, or different from, those we recommend to clients for their accounts. Our policy is designed to assure that the personal securities transactions, activities and interests of the employees of our firm will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. In an effort to reduce or eliminate certain conflicts of interest involving the firm or personal trading, our policy may require that we restrict or prohibit associates’ transactions in specific reportable securities transactions. Any exceptions or trading pre-clearance must be approved by the firm principal in advance of the transaction in an account, and we maintain the required personal securities transaction records per regulation. Trading Securities at/Around the Same Time as Client’s Securities From time to time, our firm or its “related persons” may buy or sell securities for themselves at or around the same time as clients. We will not trade non-mutual fund securities prior to the same security for clients on the same day. Investment Advice Relating to Retirement Accounts When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. 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); 7  • 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. In addition, and as required by this rule, we provide information regarding the services that we provide to you, and any material conflicts of interest, in this brochure and in your client agreement. Brokerage Practices Form ADV Part 2A, Item 12 Firm may recommend specific brokers to advisory clients. Firm shall evaluate such factors as track record, performance and reputation in the securities industry. Moreover, the firm has assessed the reasonableness of the commissions and has concluded that the commissions are reasonable. We currently do not receive soft dollar benefits. The firm does not receive research or other products or services other than execution from a broker/dealer or a third party in connection with effecting securities transactions on behalf of clients. Generally, we combine multiple orders for shares of the same securities purchased for advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. The distribution of the shares purchased is typically proportionate to the size of the account, but it is not based on account performance or the amount or structure of management fees. Subject to our discretion, regarding particular circumstances and market conditions, when we combine orders, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. Review of Accounts Form ADV Part 2A, Item 13 With respect to investment supervisory activities, ongoing and continuous monitoring of the portfolio shall be undertaken. The "Qualified Custodian" shall send account statements out to the advisory client 8  on a monthly basis. With respect to fee based financial planning activities, an annual review shall be encouraged. Sean Paul Butson, managing member and Chief Compliance Officer of the firm, conducts all reviews. Client Referrals and Other Compensation Form ADV Part 2A, Item 14 We do not receive any economic benefit directly or indirectly from any third party for advice rendered to our clients, other than what is disclosed in Item 12 above. Nor do we directly or indirectly compensate any person who is not advisory personnel for client referrals. Custody Form ADV Part 2A, Item 15 The firm does not accept physical custody of client funds, however it is deemed to have limited custody solely with its ability to withdraw fees from clients’ accounts. Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client's investment assets. We urge you to carefully review such statements and compare such official custodial records to the account statements or reports that we may provide to you. Our statements or reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Investment Discretion Form ADV Part 2A, Item 16 For those client accounts where we provide investment management services, we maintain discretion over client accounts with respect to securities to be bought and sold and the amount of securities to be bought and sold. Investment discretion is explained to clients in detail when an advisory relationship has commenced. At the start of the advisory relationship, the client will execute a Limited Power of Attorney, which will grant our firm discretion over the account. Additionally, the discretionary relationship will be outlined in the advisory contract and signed by the client. Clients may impose reasonable restrictions on investing in certain securities, types of securities, or industry sectors. 9  Voting Client Securities Form ADV Part 2A, Item 17 Firm shall not vote proxy statements on behalf of advisory clients. Clients may contact us if they have any questions about the voting of proxies. The client should receive the proxy statements directly from the qualified custodian. Financial Information Form ADV Part 2A, Item 18 Firm does not receive fees more than six months in advance. 10 

Sean Paul Butson, CFA DC Capital Management, LLC 101 Gold Run Circle Dillon, CO 80435 Phone: 970-468-1339 August 14, 2026 FORM ADV PART 2B BROCHURE SUPPLEMENT This brochure supplement provides information about Sean Paul Butson that supplements the DC Capital Management, LLC brochure. You should have received a copy of that brochure. Please contact Mr. Butson, Member and Chief Compliance Officer if you did not receive DC Capital Management, LLC's brochure or if you have any questions about the contents of this supplement. information about Sean Paul Butson is available on the SEC’s website at Additional www.adviserinfo.sec.gov using CRD #2917873.  Sean Paul Butson, CFA Form ADV Part 2B Brochure Supplement CRD No: 2917873 IARD No.: 142841 August 14, 2026 Educational Background and Business Experience Form ADV Part 2B, Item 2 Sean Paul Butson, CFA Born December 25, 1971 Education Achieved Chartered Financial Analyst (CFA) designation in minimum number of years University of Maryland, College Park, MD, 1994: Bachelor of Science, Finance: 3.8 GPA Wake Forest University, Winston-Salem, NC, 1993: Bachelor of Arts, Politics: Dean’s List Business Background DC Capital Management, 2006-Present President • Manage discretionary investment accounts in proprietary portfolios • Provide financial planning services focused on retirement planning, college savings, estate planning, etc. Legg Mason, Baltimore, MD, 1997-2005 Principal/Equity Analyst, Media Industry, 2003-2005 • Covered the satellite radio, Hispanic media, cable networks, film, and TV broadcasting sectors (including XM Radio, Sirius, Viacom, and Univision) via financial models, written reports, and oral communication with clients in the U.S. and Europe • Authored dozens of reports on the satellite radio industry, including insightful pieces on technology, subscribers, and content • Appeared on CNBC and quoted in major publications regarding the media industry • Asked to lecture MBA course on finance and capital markets Principal/Equity Analyst, Wireless Services and Tower Industries, 2000-2002 • Received Wall Street Journal award as the #1 stockpicker (co-coverage) in the wireless services industry (including Nextel, Sprint PCS, and AT&T Wireless) in only year eligible (2002) • Leading analyst covering the tower industry; provided extensive research coverage of American Tower, Crown Castle, and SBA Communications, while avoiding Pinnacle and SpectraSite, both of which went bankrupt • Served as an expert witness Associate Equity Analyst, Wireless Services, Towers, and Equipment Industries, 1997-1999 • One of the first associate analysts promoted to analyst of 1997 hires • Drafted equity research reports, built valuation models, and discussed investment theses with Legg Mason clients in the wireless services, equipment, and tower industries (including Nokia, Ericsson, 1  Sean Paul Butson, CFA Form ADV Part 2B Brochure Supplement CRD No: 2917873 IARD No.: 142841 August 14, 2026 and Motorola) NationsBank (now Bank of America), Bethesda, MD, 1995-1997 Portfolio Manager, 1997 • Manager of a $20 million debt portfolio of middle market clients with annual revenues of $10-$250 million Credit Analyst, 1995-1996 • Structured debt financing for clients, which included senior debt, revolving credit facilities, and standby letters of credit Chartered Financial Analyst [‘CFA’]: This designation is issued by the CFA Institute and is granted to individuals who meet one of the following prerequisites: possess an undergraduate degree and four years of professional experience investment decision making; or four years qualified work experience (full time, but not necessarily investment related). The candidate is required to follow a self study program involving 250 hours of study for each of the following three disciplines: Level One: Ethics & Professional Standards; Level Two: Investment Tools & Asset Classes; and Level Three: Portfolio Management & Wealth Planning. Once the designation is issued, no further Continuing Education is required. Disciplinary Information Form ADV Part 2B, Item 3 None. Other Business Activities Form ADV Part 2B, Item 4 None. Additional Compensation Form ADV Part 2B, Item 5 None. 2  Sean Paul Butson, CFA Form ADV Part 2B Brochure Supplement CRD No: 2917873 IARD No.: 142841 August 14, 2026 Supervision Form ADV Part 2B, Item 6 Mr. Sean Butson, as Member and Chief Compliance Officer of DC Capital Management, LLC, is responsible for supervision. He may be contacted at the phone number on this brochure supplement. 3