DELTA INVESTMENT MANAGEMENT, LLC

BROCHURE SUPPLEMENT ITEM 1: COVER SHEET Andrew D. Houghton Delta Investment Management, LLC 708 Montgomery Street San Francisco, CA 94111 (415) 249-6337 Prepared: June 10, 2025 This Brochure Supplement provides information about Andrew D. Houghton that supplements the Delta Investment Management, LLC Brochure. You should have received a copy of that Brochure. Please contact Nicholas G. Atkeson, Managing Member at (415) 249-6337 if you did not receive Delta Investment Management, LLC’s Brochure or if you have any questions about the content of this supplement. Additional information about Andrew D. Houghton is available on the SEC’s website at www.adviserinfo.sec.gov. Mr. Houghton’s CRD number is 2825725. ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Andrew D. Houghton was born in 1963. He received a BA in Economics from Boston University in 1985. Employment Background Employment Dates: Firm Name: Type of Business: Job Title & Duties: 4/2009 - Present Delta Investment Management, LLC Investment Advisor Chief Investment Strategist, oversight of investment process Employment Dates: Firm Name: Type of Business: Job Title & Duties: 5/2016 – 7/2018 US Capital Wealth Management, LLC Investment Advisor Principal, oversight of investment process Employment Dates: Firm Name: Type of Business: Job Title & Duties: 4/2006 – 3/2009 Delta Force Capital, LLC Hedge Fund Partner, portfolio manager  Brochure Supplement Andrew D. Houghton Employment Background (continued) Employment Dates: Firm Name: Type of Business: Job Title & Duties: 3/2005 – 3/2006 ThinkEquity LLC Brokerage/Investment Bank Managing Director/Institutional Sales (Research) Employment Dates: Firm Name: Type of Business: Job Title & Duties: 3/2003 – 3/2005 Susquehanna International Group, LLC Brokerage/Trading/Options & Equity Institutional Sales (Research) Employment Dates: Firm Name: Type of Business: Job Title & Duties: 11/1996 – 3/2003 Banc of America Securities, LLC Brokerage/Investment Bank Principal/Institutional Sales (Research) ITEM 3: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. There is no information of this type to report. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Houghton is not involved in any other business activities. ITEM 5: ADDITIONAL COMPENSATION Mr. Houghton does not receive any economic benefit from any non-client for providing advisory services. ITEM 6: SUPERVISION Nicholas G. Atkeson, Managing Member, is responsible for the supervision of Mr. Houghton. His telephone number is (415) 249-6337. Page 2 

BROCHURE SUPPLEMENT ITEM 1: COVER SHEET Nicholas G. Atkeson Delta Investment Management, LLC 708 Montgomery Street San Francisco, CA 94111 (415) 249-6337 Prepared: June 10, 2025 This Brochure Supplement provides information about Nicholas G. Atkeson that supplements the Delta Investment Management, LLC Brochure. You should have received a copy of that Brochure. Please contact Andrew D. Houghton, Managing Member at (415) 249-6335 if you did not receive Delta Investment Management, LLC’s Brochure or if you have any questions about the content of this supplement. Additional information about Nicholas G. Atkeson is available on the SEC’s website at www.adviserinfo.sec.gov. Mr. Atkeson’s CRD number is 2883445. ITEM 2: EDUCATIONAL BACKGROUND AND BUSINESS EXPERIENCE Nicholas G. Atkeson was born in 1962. He received a BA in Economics from Haverford College in 1984 and a MBA from Stanford University Graduate School of Business in 1988. Employment Background Employment Dates: Firm Name: Type of Business: Job Title & Duties: 4/2009 - Present Delta Investment Management, LLC Investment Advisor Chief Investment Officer, oversight of investment process Employment Dates: Firm Name: Type of Business: Job Title & Duties: 5/2016 – 7/2018 US Capital Wealth Management, LLC Investment Advisor Principal, oversight of investment process. Employment Dates: Firm Name: Type of Business: Job Title & Duties: 4/2006 - 3/2009 Delta Force Capital, LLC Hedge Fund Partner, portfolio manager  Brochure Supplement Nicholas G. Atkeson Employment Background (continued) Employment Dates: Firm Name: Type of Business: Job Title & Duties: 3/2005 - 3/2006 ThinkEquity LLC Investment Bank Institutional Sales Employment Dates: Firm Name: Type of Business: Job Title & Duties: 3/2003 - 3/2005 Susquehanna International Group, LLC Options Market Making Firm Institutional Sales Employment Dates: Firm Name: Type of Business: Job Title & Duties: 1/1997 - 3/2003 Banc of America Securities, LLC Investment Bank Managing Director, Institutional Sales ITEM 3: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of each investment advisor representative providing investment advice to you. There is no information of this type to report. ITEM 4: OTHER BUSINESS ACTIVITIES Mr. Atkeson is not involved in any other business activities. ITEM 5: ADDITIONAL COMPENSATION Mr. Atkeson does not receive any economic benefit from any non-client for providing advisory services. ITEM 6: SUPERVISION Andrew Houghton, Managing Member, is responsible for the supervision of Mr. Atkeson. His telephone number is (415) 249-6335. Page 2 

FORM ADV, PART 2A ITEM 1: COVER SHEET Disclosure Brochure 708 Montgomery Street San Francisco, CA 94111 (415) 249-6337 Delta Investment Management website www.deltaim.com Investment Representatives' websites www.getretirementplanning.com www.ifsgllc.com www.stopthewealthleakage.com www.northstar65.com rail-splitter.com Prepared: June 10, 2025 This brochure provides information about the qualifications and business practices of Delta Investment Management, LLC. If you have any questions about the contents of this brochure, please contact us at the telephone number and/or e-mail address above. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or any state securities authority. Our e-mail for regulatory compliance is compliance@deltaim.com. Delta Investment Management, LLC is a registered investment advisor. Registration of an investment advisor does not imply any level of skill or training. The verbal and written communications of an investment adviser provide you with information you need to determine whether to hire or retain the advisor. Additional information about Delta Investment Management, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. The Firm’s CRD number is 149596.  FORM ADV, PART 2A ITEM 2: MATERIAL CHANGES The previous annual update was dated January 27, 2025. This item will be updated with the next annual updating amendment to reflect material changes to the Part 2. You may request a copy of our updated Part 2 by calling (415) 249-6337 or sending an e-mail to info@deltaim.com. Additional information about us is also available on the SEC’s website at www.adviserinfo.sec.gov. The Firm’s CRD number is 149596.  ITEM 3 TABLE OF CONTENTS Item 1: Cover Sheet Item 2: Material Changes Item 3: Table of Contents Item 4: Advisory Business....................................................................................................................... 1 Who we are ......................................................................................................................................... 1 Services we offer ................................................................................................................................. 1 Assets under management .................................................................................................................. 4 Item 5: Fees and Compensation ............................................................................................................. 4 Item 6: Performance-Based Fees and Side-By-Side Management .......................................................... 5 Item 7: Types of Clients .......................................................................................................................... 5 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss...................................................... 6 Item 9: Disciplinary Information............................................................................................................... 9 Item 10: Other Financial Industry Activities and Affiliations ...................................................................... 9 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ................ 9 Code of Ethics ..................................................................................................................................... 9 Personal Trading for Associated Persons........................................................................................... 10 Item 12: Brokerage Practices................................................................................................................ 10 Selection of Brokers........................................................................................................................... 10 Aggregation of Orders........................................................................................................................ 12 Directed Brokerage............................................................................................................................ 12 Soft Dollars........................................................................................................................................ 12 Item 13: Review of Accounts................................................................................................................. 13 Item 14: Client Referrals and Other Compensation ............................................................................... 13 Other Compensation.......................................................................................................................... 13 Client Referrals.................................................................................................................................. 13 Item 15: Custody .................................................................................................................................. 13 Item 16: Investment Discretion.............................................................................................................. 14 Item 17: Voting Client Securities ........................................................................................................... 14 Item 18: Financial Information............................................................................................................... 14  ITEM 4: ADVISORY BUSINESS Who we are Delta Investment Management, LLC (referred to as “we,” “our,” “us,” or “Delta”), has been registered as an investment advisor since April 2009. Our principals and owners are Nicholas Atkeson and Andrew Houghton. Services we offer Delta provides investment consulting and investment management services to its clients. Delta charges fees based on assets under management (asset based fees) and does not charge fees separately for investment consulting services. For those clients who request a comprehensive investment plan, Delta will design a plan that meets industry standard practice and may include the use of third party mutual funds and exchange traded funds (ETFs) as a way to achieve the financial objectives identified in the plan. With the client’s approval, Delta will implement the financial plan. Within the plan, some portion of the client's funds could be allocated to one of the following strategies: Capital Appreciation, Kress Tactical, Core, Opportunity, Blue Chip Growth or could be managed by Delta in a custom account. Some portion of our clients maintain only a portion of their total investable assets with Delta Investment Management. Many of these clients with only a portion of their liquid net worth managed by Delta have their funds in the Kress Tactical, Capital Appreciation, Opportunity, Blue Chip Growth, and/or Core strategies. In Delta assists its clients in analyzing needs, setting objectives, developing asset allocation models and selecting Managers to implement the asset allocation plan and to make specific investments. preparing a financial plan using a comprehensive disciplined approach intended to be consistent with each client's particular needs and circumstances, we consider the following issues: total net worth, liquid net worth, age, income, income visibility, risk tolerance, tax considerations, investment income needs, savings requirements, overall investment objectives, investment experience, understanding of investment risk considerations, expected investment return rates, volatility of various investment choices, correlation of portfolio assets, diversification, and asset allocation. Once we implement an investment plan for you, we will monitor your investment performance on an ongoing basis. It is your responsibility to inform us of any changes to your financial situation that may impact the suitability of your investment. Delta also acts as a subadvisor to other investment advisors. In these cases, the investment advisor hiring Delta has responsibility for client communication, gathering suitability information and choosing the appropriate investment strategy for each client. We do not sponsor or manage wrap fee program assets. Capital Appreciation Capital Appreciation strategy seeks to appreciate client assets during bullish U.S. equity market periods and mitigate potential loss during U.S. equity bearish market periods by means of making opportunistic investments in equity and bond ETFs and cash. The strategy seeks to achieve positive absolute performance through major market cycles. The strategy is focused on managing equity risk by measuring stock market momentum of U.S. equity markets and positioning the strategy either in high relative strength stock ETFs, defined outcome/hedged ETFs, U.S. treasury ETFs or cash based on equity risk levels. During times when the strategy is invested in equities, it achieves its equity exposure through an Page 1  ETF(s). During times the strategy is allocated in U.S. treasury bonds, it achieves its exposure through an ETF(s). While the strategy incorporates stringent risk control metrics, it makes no guarantee that your investment may not suffer from severe drawdowns. Capital Appreciation is managed by Delta. Asset allocation decisions are made weekly. Accounts that follow the Capital Appreciation strategy are expected to experience significant turnover and short-term capital gains and losses. The Capital Appreciation strategy is not suitable for all investors and involves risks associated with ETF investments including the risk of loss of the principal invested. Opportunity Opportunity is a relative strength ETF rotation strategy that seeks to outperform the S&P 500 through the full investment cycle. The strategy may invest in ETFs representing various industry sectors, geographies, market capitalizations, styles (including value, blend and growth) and asset types including equities, bonds, treasuries and cash. On a periodic basis, price performance of the available investment opportunity set is measured and portfolio positions may be replaced with new positions with higher relative strength measurements. The investment opportunity set is analyzed quantitatively with multiple investment models using a variety of investment analysis metrics. The strategy seeks to transition client assets to the best performing areas of a broad investment set that includes global equities, bonds and cash. The strategy incorporates several layers of risk management including the capability of transitioning to defensive asset types during bearish equity cycles. Tactical position changes are designed to capture growth opportunities in up markets and mitigate risk in declining markets. Core Core is a diversified strategy which owns both fixed income and equity investments using both exchange traded funds (ETFs) and mutual funds. The strategy is benchmarked against a globally diversified 60% equity/40% bond portfolio. The strategy is designed to be tax efficient with a low turnover ratio. The primary method of risk management in the Core strategy is through asset diversification. When recession risk is elevated based on macro-economic indicators, the strategy may further mange risk by reducing its equity exposure materially below the 60% range. Kress Tactical The objective of the Kress Tactical strategy is to appreciate client assets during bullish U.S. equity market periods and mitigate potential loss during U.S. equity bearish market periods by means of making opportunistic investments in equity and bond ETFs and cash. Purchase and sales of securities is partly based on a systematic analysis on certain technical indicators. The strategy may at times cause portfolios to hold significant amounts of cash. Investors should bear in mind that even when accounts hold significant amounts of cash, earning potentially lower rates of return, they will nevertheless be charged significant management fees. Kress Tactical strategy may not be suitable for risk-averse clients or permissible for certain retirement accounts. Risks include the possibility that investors could lose their entire investment. In addition, because the strategy involves buying and selling securities on a short-term basis, generally at least every few months, the client accounts may incur short-term capital gains and losses, which are taxed less favorably than investments held for more than one year. Page 2  Blue Chip Growth Blue Chip Growth is a concentrated, bottom-up stock picking strategy that seeks to outperform the S&P 500 through the full investment cycle. The strategy uses fundamental analysis to invest in individual stocks and focuses on intrinsic value growth of those stocks over time. The mandate of the strategy is to be fully invested in stocks at all times. Blue Chip Growth is unconstrained with regards to value or growth weightings, size weightings, sector concentration, or stock concentration. The manager allocates capital to where he sees the best relative value among equities at any given time even if that leads to significant concentration in sectors and/or individual stocks. Custom Delta works with clients to understand their financial conditions and goals. Delta performs in-depth analysis to provide clients with information necessary to making informed investment decisions and understand likely investment scenarios and trade-offs. With the client, Delta designs and implements investment plans that will help clients achieve their financial goals. These investment plans and portfolio holdings may be specific to each client and are designed to meet the needs of an individual client. These custom designed client accounts may hold a variety of assets including ETFs, stocks, bonds and mutual funds. Positions are not style or market capitalization constrained and may be actively managed. Delta may seek diversification in client accounts through use of various investment management techniques and a broad array of asset types including global equities, bonds, commodities and currencies. Delta monitors and reviews the investments and managers selected to ensure custom investment plans are serving the particular needs of each client. Alternative Investments Based on client investment objectives and financial condition, Delta may recommend investing in alternative assets. Generally, Delta considers alternative investments to be investments that do not offer daily liquidity, are in pooled investment vehicles such as limited partnerships and may place restrictions on capital withdrawals. Alternative investments do not fall into one of the conventional categories including stocks, bonds, exchange traded funds (ETFs), mutual funds and cash. Alternative investments often require that an investor be an accredited investor. The Securities and Exchange Commission (SEC) defines who is an accredited investor under Regulation D. Accredited investors are legally authorized to purchase securities that are not registered with regulatory authorities like the SEC. An individual accredited investor is defined by an income or net worth threshold. Accredited investors are presumed to be financially sophisticated so they are able to understand the risks associated with investing in non-standard assets. The custodians and broker/dealers that work with Delta and also custody alternative assets often apply additional fees and commissions to alternative assets that they do not on conventional, listed securities. Commissions to buy and sell alternative assets may be substantially higher than standard commission rates and some custodians charge annual holding fees for alternative assets. High fees diminish the investment returns of alternative assets. To make the fees a small percentage of the overall investment return, alternative investments often involve significant position sizes that are often materially larger than what is suitable in a typical Delta account. Page 3  Assets under management As of June 12, 2025, we manage assets of $781.2 million on a discretionary basis and no assets on a non-discretionary basis. ITEM 5: FEES AND COMPENSATION Investment management services, including subadvisory services, are provided for an asset-based fee ranging from 1.00% to 1.85%, based on the value of the assets being managed. The negotiated fee takes into account use of third party strategy provider(s), the scope and complexity of the services provided, account size, and account history with Delta including duration and services provided. The annual fee on all accounts are billed quarterly, in advance, based on the account’s net asset value on the last day of the previous billing cycle, as reflected in the ELECTRONIC DATA transmitted to us by the custodian of the account. In the event the Delta Advisor Agreement is executed and the account funded at any time other than the first day of a calendar quarter, the advisory fee is payable in proportion to the number of days in the quarter for which you are a client. “Net asset value” = long market value – short market value + credit balance – debit balance + money market fund balance. Fees cover Delta’s investment advisory, reporting, and account-related services. Fees do not cover any execution-related expenses, commissions, if any, securities exchange fees, or other fees required by law or charged by the broker-dealer with custody of the account. Clients are responsible for commissions, fees, and other charges, if any, associated with such transactions and the maintenance of their account(s). Fees are negotiable in limited circumstances. Financial Planning services are included in the above fees, excluding accounts for which Delta solely provides subadvisory services. On all of our accounts, we generally request that you provide authorization for us to deduct our fees directly from your investment account. Important information about the deduction of management fees:  You must provide written authorization for us to deduct fees by checking the appropriate section of our contract.  You will receive a statement from your custodian which shows all transactions in your account, including the deduction of our fees.  You are responsible for reviewing the accuracy of the fees being billed, as the custodian will not do so. You may elect to pay by check rather than having payment deducted directly from your account. You may terminate an advisory account by providing written notice. If an account is terminated before the last day of a calendar quarter, we will prorate the advisory fees earned through the termination date and send you a refund of the prepaid, unearned portion of your fee. We process refund payments within 30 days of the termination date and will send you a check or refund your investment account. Page 4  Other Costs Involved In addition to our advisory fee shown above, you are responsible for paying fees associated with investing for your account. These fees include:  mutual fund loads (if applicable). These charges are paid to brokers as a form of commission.  management fees for ETFs and mutual funds. These are fees charged by the managers of the ETF or mutual fund and are a portion of the expenses of the ETF or mutual fund.  management fees and other operating expenses paid for alternative investments. These fees are charged by the manager of the alternative investment and fully disclosed in the offering materials provided before investing.  In the case of alternative assets, brokerage costs and transaction fees for any securities or fixed income trades. These are generally charged by your custodian and/or executing broker. these fees may be substantially higher than they are on standard, listed securities. Additional information about brokerage costs and services is provided in “Item 12: Brokerage Practices.” We believe the fees mentioned above are competitive; however you may be able to obtain similar services from other sources at a lower price. Several individuals who provide investment advice to our clients are also affiliated with various insurance agencies. If you elect to implement insurance recommendations through one of these individuals, that person will receive the normal and customary commissions. In these situations, a conflict of interest exists between the interests of the client and Delta. In these instances, these individuals have an incentive to recommend products based on the compensation they receive, rather than on client’s needs. Clients of Delta are under no obligation to implement insurance recommendations through one of these individuals. Clients may purchase insurance products and services from individuals other than those affiliated with Delta. ITEM 6: PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not receive performance fees for managing accounts. ITEM 7: TYPES OF CLIENTS Generally, Delta's minimum account size on the date of account opening is $50,000. We reserve the right to waive this minimum account size requirement at our sole discretion. Our clients include entities who are able to invest $50,000 and who are in compliance with AML regulations. We generally provide advisory services to individuals, institutions, trusts and pension plans. Page 5  ITEM 8: METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS Delta uses fundamental, company, industry and sector analysis along with quantitative macro-economic analysis to construct portfolios. Typically the process used is a multiple step screening process that is adjusted on periodic intervals not less than annually. Delta may use one or more of the following methods of analysis or investment strategies when managing the Kress Tactical accounts:  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.  Cyclical/Quantitative Analysis – a type of technical analysis that involves evaluating recurring price patterns and trends.  Macro-economic analysis - focuses on economic performance including economic expansion and recession. All investments involve different degrees of risk. You should be aware of your risk tolerance level and financial situations at all times. We cannot guarantee the successful performance of an investment and we are expressly prohibited from guaranteeing accounts against losses arising from market conditions. Capital Appreciation The Capital Appreciation strategy seeks to achieve positive absolute market returns regardless of equity or bond market conditions by owning equities, bonds, U.S. Treasuries, or cash. The strategy seeks to align with the stock market during sustained bull markets by means of being allocated to equities. During sustained bear markets, the strategy transitions out of equities and into bonds and/or cash. Bullish and bearish equity market cycles are determined by the Delta Market Sentiment Indicator (MSI) which is based on a proprietary technical equity market risk premium measurement. The bullish/bearish MSI is measured weekly and strategy allocations can be made weekly. During bullish cycles, equity market exposure is achieved through ownership of high relative strength ETFs and defined outcome/hedged equity ETFs. During bearish cycles, the strategy may invest in high relative strength bond funds, defined outcome/hedged equity ETFs and cash. When the Delta MSI reaches very oversold levels, the Capital Appreciation strategy may invest in equities. Capital Appreciation is not suitable for all investors and involves risks associated with equity and bond investments including the risk of loss of the principal invested. There is a risk of loss of principal if the strategy does not exit the equity or bond market quickly enough in a bearish downturn. Conversely, if the strategy is too slow in entering a bullish market, your investment will participate only to the extent that the strategy was invested and may miss a portion of the advance. Because the strategy buys only certain ETFs and mutual funds rather than exposure to the broad market, there is risk that your investment may not achieve broad equity or bond market actual returns. Risks include the possibility that investors could lose their entire investment. In addition, because the strategy involves buying and selling securities on a Page 6  short term basis, generally at least every few months, the client accounts may incur short-term capital gains and losses, which are taxed less favorably than investments held for more than one year. Because the strategy is actively managed and traded, performance can be negatively impacted by increased brokerage and other transaction costs and taxes. Opportunity The Opportunity strategy attempts to create a portfolio exposed to the best performing areas of the equity and bond markets by buying and selling ETFs based on multiple relative strength calculations. ETF funds available to be included in the Opportunity portfolio represent equity value, growth, blend, small, mid, large, U.S., developed country, emerging market, defined outcome/hedged and industry sectors. The investment opportunity set also includes ETF funds that represent corporate and government bonds of multiple durations. Portfolio positions are reviewed periodically with price performance analysis and portfolio positions are replaced based on the judgment of the manager and the output of the various relative strength models used to help identify attractive investment opportunities. The investment models provide guidance on which areas of the market are moving in or out of favor and the likely duration an ETF should be held in the diversified portfolio. The models’ objective sell disciplines may occasionally cause the strategy to miss some market gains, but the sell disciplines are critical in mitigating investors’ exposure to down markets. As in investing in any equities or bonds there is a risk of loss of principal if the strategy does not exit the broad market quickly enough in a declining market. Conversely, if the strategy is too slow in entering a bullish market, an investor may not participate to the extent if they had remained invested. The Opportunity strategy primarily uses ETFs as its investment vehicle. ETFs generally have expenses which are charged to the owner of the fund (i.e., the client) and represent an embedded cost and a potential source of performance degradation in the Opportunity strategy. Principal loss may occur due to the selection of the individual ETFs themselves. Some ETFs may suffer losses or not perform as well as the broader markets or may not perform as well as their peers. Generally, when the strategy is defensive, it will transition from equity exposure to bond exposure. Bonds including U.S. treasuries can be negatively impacted by credit risk, interest rate changes and other factors that may negatively impact your principal. Because the strategy is actively managed and traded, performance can be negatively impacted by brokerage and other transaction costs and taxes. Core Core seeks to provide clients with a balanced equity and debt portfolio that has low asset turnover. Risk management is primarily achieved by owning broadly diversified equity and fixed income investments. A second layer of risk control is applied when Delta’s macro-economic indicators signal that the probability of a recession is elevated. In this case, some of the equities holdings may transition to cash or fixed income ETFs. Equity and bond investments are volatile. There is always a risk of loss of principal. During periods when the equity and bond portions of the Core strategy are fully invested, we would expect the strategy to experience volatility similar to what is experienced by the broader markets. Additionally, principal loss may also occur due to the selection of individual mutual funds and ETFs themselves. Mutual funds often have higher expense ratios and brokerage trading costs than ETFs. Mutual funds are only traded once per day after stock market close. Because of these costs and trading restrictions, mutual funds may not deliver the returns of the market indexes they are benchmarked to. In cases when Delta reduces equity exposure because of perceived increased risk of recession, there is risk to the investor from Delta’s Page 7  market timing. Timing risk may involve the portfolio underperforming during bullish periods by being less than fully invested and by being fully invested during bearish periods. Kress Tactical The Kress Tactical strategy is an opportunistic long-only, all cap strategy that utilizes a proprietary combination of technical and fundamental analysis seeking to grow capital while stressing the importance of capital preservation in down markets. Following this approach there are times in market cycles when the strategy will be fully invested in equity ETFs and there will be times when the strategy is completely out of equities and in cash. The strategy is not tax sensitive. Step 1, Market Sentiment, by rigorously following a weekly market sentiment indicator they constantly evaluate the risk-reward of owning equities versus protecting investment capital in cash during weak markets. Step 2, Portfolio Construction, a technical filter highlights the high relative strength ETFs. Step 3, Sell Discipline, the portfolio is actively maintained using strict technical sell discipline. This avoids the common pitfall of becoming emotionally attached to a position. As in investing in any equities there is a risk of loss of principal if the strategy does not exit the broad market quickly enough in a bearish downturn conversely if the strategy is too slow in entering a bullish market you will participate to the extent if you had remained invested. Principal loss may also occur due to the selection of the individual ETFs themselves, some individual ETFs may suffer losses or not perform as well as the broader markets or may not perform as well as their peers. Because the strategy is actively managed and traded, performance can be negatively impacted by increased brokerage and other transaction costs and taxes. Blue Chip Growth Blue Chip Growth uses fundamental analysis to invest in what it believes are the individual equities that can deliver long-term returns superior to those of the S&P 500. Blue Chip Growth’s mandate is to be fully invested, so its goal is to have positive performance relative to the S&P 500 index over a multi-year period. Blue Chip Growth is unusually concentrated, often holding 25 or fewer stocks. Because of this concentration, in addition to a lack of controls on sector or size weights, clients are exposed to high levels of volatility and risk. In fact, Blue Chip Growth has had many instances of pronounced underperformance relative to the S&P 500 index. Clients should understand this risk and expect these periods of significant underperformance. Clients should also expect volatility due to underlying equity volatility, coupled with Blue Chip Growth’s mandate to be fully invested in equities at all times. Blue Chip Growth is not suitable for all clients, and as a high volatility and high risk strategy should only be considered for investors with high risk tolerances and long time horizons. Investors also face tax consequences if equities in the strategy are sold for a gain. Custom As in any investing there is a risk of loss of principal if the strategy does not perform as expected. The strategy may follow a broad market decline or it may lose principal due to the selection of the individual securities themselves, some individual securities may suffer losses or not perform as well as similar securities. Because the Core strategy is actively managed and traded, performance can be negatively impacted by increased brokerage and other transaction costs and taxes. Page 8  All investments involve different degrees of risk. You should be aware of your risk tolerance level and financial situations at all times. We cannot guarantee the successful performance of an investment and we are expressly prohibited from guaranteeing accounts against losses arising from market conditions. Alternative Investments In evaluating potential alternative investments, Delta performs fundamental due diligence which may include meetings with management, review of financial performance, review of physical assets, review of broader industry trends and background checks of investment sponsors. Alternative investments are often more complex than tradition investment vehicles, and have less transparency, lower liquidity and higher fees. Because of these factors, alternative investments are generally considered materially more risky than traditional, listed security investing. Even with careful and comprehensive due diligence, alternative investments may be subject to complete loss of principal. If, after the initial investment is made, market conditions change in a manner that is detrimental to the investment, liquidity restrictions (“gates”) may prevent an investor from liquidating the position and avoiding substantial loss. Because alternative investments often address a niche perceived investment opportunity, they can be subject to high investment-specific risk that is not easily identified in advance. Alternative investments are generally only suitable for accredited investors and in position sizes that are manageable in the event of catastrophic loss. ITEM 9: DISCIPLINARY INFORMATION Registered investment advisors are required to disclose any material facts regarding any legal or disciplinary actions that would be material to your evaluation of the investment advisor and each investment advisor representative providing investment advice to you. We have no information of this type to report. ITEM 10: OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Delta and its principals/owners do not have any additional outside business activities in the financial industry. However, some investment advisor representatives sell insurance products for several insurance companies. Please see Item 5: Fees and Compensation, for additional information. Additional disclosure regarding these relationships is provided on Part 2B for the individuals. ITEM 11: CODE OF ETHICS, PARTICIPATION OR INTEREST IN CLIENT TRANSACTIONS AND PERSONAL TRADING Code of Ethics We have adopted a set of enforceable guidelines (Code of Ethics), which describes unacceptable conduct by Delta and our associated persons. Summarized, this Code of Ethics prohibits us from: placing our interests before yours,  using non public information gathered when providing services to you for our own gains, or  Page 9   engaging in any act, practice or course of business that is, or might be considered, fraudulent, deceptive, manipulative, or in violation of any applicable law, rule or regulation of a governmental agency. Please contact us if you would like to receive a full copy of this Code of Ethics. Personal Trading for Associated Persons We may buy or sell some of the same securities for you that we already hold in our personal account. We may also buy for our personal account some of the same securities that you already hold in your account. It is our policy not to permit our associated persons (or their immediate relatives) to trade in a way that takes advantage of price movements caused by your transactions. We may restrict trading for a particular security for our accounts or those of our associated person if there is a pending trade in that security in a client account. Trades for our accounts (and those of our associated persons) will be placed as part of a block trade with client trades, or individually after client trades have been completed. Additional information about block trades is provided in the Aggregation of Orders section of “Item 12: Brokerage Practices.” When our trades are placed after our client trades, we may receive a better or worse price than that received by the client. Delta and its associated persons may purchase or sell specific securities for their own account based on personal investment considerations without regard to whether the purchase or sale of such security is appropriate for clients. All persons associated with us are required to report all personal securities transactions to us quarterly. ITEM 12: BROKERAGE PRACTICES Selection of Brokers We do not maintain custody of your assets that we manage, although we may be deemed to have custody of your assets if you give us authority to withdraw assets from your account (see “Item 15: Custody”). Your assets must be maintained in an account at a “qualified custodian,” generally a broker/dealer or bank. We have chosen Charles Schwab & Co., Inc. (“Schwab”), a registered broker/dealer, member SIPC, Nationwide, Goldman Sachs, and Interactive Brokers to act as custodian and broker/dealer for our client accounts. We are independently owned and operated and are not affiliated with any of these custodians. The custodians hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we provide recommendations for custodian/brokers, you will decide which to use and open an account by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. In selecting brokers to execute portfolio transactions, we make a good faith judgment about which broker would be appropriate. We take into consideration not only the available prices and rates of brokerage commissions, but also other relevant factors that may include (without limitation): the execution capabilities of the broker/dealer,   research (including economic forecasts, investment strategy advice, fundamental and technical advice on individual securities, valuation advice and market analysis), Page 10   custodial and other services provided by the broker/dealer that are expected to enhance our general portfolio management capabilities, the size of the transaction,  the difficulty of execution,  the operational facilities of the broker-dealers involved,  the risk in positioning a block of securities, and  the quality of the overall brokerage and research services provided by the broker/dealer.  When we select the broker/dealer for a transaction, we may cause you to pay a higher commission for effecting a transaction than another broker/dealer would have charged for effecting that transaction. We do this if we determine in good faith that the amount of the commission is reasonable in relation to the value of the brokerage and research services provided by the broker/dealer. The determination is viewed in terms of either the particular transaction or our overall responsibilities to you. Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like us. Through Schwab Advisor Services, Schwab provides us and our clients, both those enrolled in the Program and our clients not enrolled in the Program, with access to its institutional brokerage services— trading, custody, reporting, and related services—many of which are not typically available to Schwab retail customers. However, certain retail customers may be able to get institutional brokerage services from Schwab without going through us. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services described below are generally available on an unsolicited basis (we don’t have to request them) and at no charge to us. The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Here is a more detailed description of Schwab’s support services: Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit the client and the client’s account. Schwab also makes available to us other products and services that benefit us but do not directly benefit the client or its account. These products and services assist us in managing and administering our clients’ accounts and operating our firm. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or some substantial number of our clients’ accounts, including accounts not maintained at Schwab In addition to investment research, Schwab also makes available software and other technology that: (cid:127) (cid:127) (cid:127) (cid:127) (cid:127) provide access to client account data (such as duplicate trade confirmations and account statements); facilitate trade execution and allocate aggregated trade orders for multiple client accounts; provide pricing and other market data; facilitate payment of our fees from our clients’ accounts; and assist with back-office functions, recordkeeping, and client reporting. Page 11  Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include: educational conferences and events; technology and business consulting; (cid:127) (cid:127) (cid:127) Consulting on legal and related compliance needs; (cid:127) (cid:127) publications and conferences on practice management and business succession; and access to employee benefits providers, human capital consultants, and insurance providers. Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. If you did not maintain your account with Schwab, we would be required to pay for these services from our own resources. Delta receives similar services to those described above from its other broker/dealer custodians. Aggregation of Orders There are occasions on which portfolio transactions will be executed as part of concurrent authorizations to purchase or sell the same security for another client or one or more of our associated persons. We may choose to block (aggregate) trades for your account with those of other client accounts and personal accounts of persons associated with Delta. When we place a block trade, all participants included in the block receive the same price per share on the trade. The price is calculated by averaging the price of all of the shares traded. Due to the averaging of price over all of the participating accounts, aggregated trades could be either advantageous or disadvantageous. Commission costs are not averaged. You will pay the same commission whether your trade is placed as part of a block or on an individual basis. The objective of the aggregated orders will be to allocate the executions in a manner that is deemed equitable to the accounts involved. Client accounts maybe established at a number of different firms and we would normally execute with those firms that custody the assets. Because of this we may not be able to aggregate all our client orders and therefore we may be unable to reduce transaction costs or the client may receive less favorable prices. Directed Brokerage You may instruct us to execute any or all securities transactions for your account with or through one or more broker/dealers designated by you. In these cases, you are responsible for negotiating the terms and conditions (including, but not limited to, commission rates) relating to all services to be provided by the broker/dealers and you are satisfied with the terms and conditions. We have no responsibility for obtaining the best prices or any particular commission rates for transactions with or through the broker/dealer in these situations. You recognize that you may not obtain rates as low as you might otherwise obtain if we had discretion to select broker/dealers other than those chosen by you. If you would like us to cease executing transactions with or through the designated broker/dealer you must notify us in writing. Soft Dollars The receipt of goods and/or services from the required custodian in connection with providing advice to clients is seen by the regulators as “soft dollars.” The additional services we receive from custodians, as Page 12  disclosed in Item 14 below, would fall under this description of soft dollars. There is an inherent conflict in this relationship, as Delta receives services from the custodian it recommends to clients. Delta acknowledges its duty to act in the best interest of the client and in line with its fiduciary duty. ITEM 13: REVIEW OF ACCOUNTS Periodically, not less than annually, a review of the asset allocation and market exposure is performed. This review is performed by Nicholas Atkeson and Andrew Houghton, both Partners. Michael Kress, Managing Director, is responsible for the review of the Kress Tactical strategy. Delta does not custody any client funds or securities. Each custodian sends monthly or quarterly account statements directly to clients. Clients should carefully review those statements. In addition, Delta may send clients portfolio appraisal or transactions reports. Generally, clients receive a brokerage statement on a monthly basis. The statements include an account summary with opening and closing balances. A portfolio equity allocation pie chart is included. Individual securities held in the account are shown. Transactions executed in the account are listed by date. On a quarterly basis, Delta provides clients with a review of the strategies’ performance during the prior quarter. The quarterly report provides market observations and an explanation of the performance of the Tactical strategies by Nick Atkeson and Andrew Houghton. ITEM 14: CLIENT REFERRALS AND OTHER COMPENSATION Other Compensation Delta receives similar services to those described below from Nationwide, Goldman Sachs, and Interactive Brokers. We receive an economic benefit from Schwab in the form of the support products and services it makes available to us and other independent investment advisors whose clients maintain their accounts at Schwab. These products and services, how they benefit us, and the related conflicts of interest are described above (see “Item 12: Brokerage Practices”). The availability to us of Schwab’s products and services is not based on us giving particular investment advice, such as buying particular securities for our clients. Client Referrals We engage solicitors to provide client referrals. We pay these solicitors a portion of the fees we earn for managing the client that was referred. If you are referred by a solicitor, this practice will be disclosed in writing and we will comply with applicable rules or statutes. Clients referred by a solicitor do not pay a higher fee. ITEM 15: CUSTODY If you give us authority to deduct our fees directly from your separately managed account, we have custody of those assets. For accounts where the client has a standing letter of authorization that allows us to transfer money to third party accounts specified by the client, we are also deemed to have custody. Page 13  We follow the guidance outlined in the Investment Adviser Association no-action letter dated February 21, 2017, for these accounts. A copy of this letter is available upon request. At no time do we accept physical custody of client assets. In all cases, you will also receive quarterly statements directly from custodian of the account that details all transactions in the account. Clients should compare the account statements they receive from their qualified custodian with the reports they receive from Delta. ITEM 16: INVESTMENT DISCRETION As one of the conditions of managing your account, you are required to provide discretionary authority for us to manage your assets. Discretionary authority means that you are giving us a limited power of attorney to place trades on your behalf. This limited power of attorney does not allow us to withdraw money from your account, other than advisory fees if you agree to give us that authority. You grant us discretionary authority by completing the following items:  Sign a contract with us that provides a limited power of attorney for us to place trades on your behalf. Any limitations to the trading authorization will be added to this agreement.  Provide us with discretionary authority on the new account forms that are submitted to the broker/dealer acting as custodian for your account(s). ITEM 17: VOTING CLIENT SECURITIES We do not accept the authority to vote proxies on your behalf and we do not provide guidance about how to vote proxies. You will receive proxies and other related paperwork directly from your custodian. At your request, we may offer you advice regarding corporate actions and the exercise of your proxy voting rights. If you own shares of common stock or mutual funds, you are responsible for exercising your right to vote as a shareholder. ITEM 18: FINANCIAL INFORMATION We do not charge or solicit pre-payment of more than $1,200 in fees per client six months or more in advance. We have never filed for bankruptcy and are not aware of any financial conditions that are reasonably likely to impair our ability to meet our contractual obligations to clients. Page 14