FIRST LOOK CAPITAL MANAGEMENT, LLC

Item 1 – Cover Page Mailing Address 49 Gillaspey Avenue Crested Butte, CO 81224 Main Office 100 Teocalli Road/Suite #4 Crested Butte, CO 81224 (844) 377-8526 www.firstlookcm.com Form ADV Part 2A Firm Brochure February 9, 2026 This brochure provides information about the qualifications and business practices of First Look Capital Management, LLC. If you have any questions about the content of this brochure, please contact our Chief Compliance Officer, John R. Garmhausen, CFP®, CFA, at (844) 377-8526 Extension #2.1 The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission (SEC) or any state securities administrator. Additional information about First Look Capital Management, LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Click on the “Investment Adviser Search” link and then search for “Investment Adviser Firm” using the firm’s IARD (“CRD”) number, which is 173040. Although the firm and its associates may be notice-filed (“registered”) and/or licensed within a particular jurisdiction it does not imply an endorsement by any regulatory authority nor infers a certain level of skill or training on the part of the firm or its associated personnel. 1 Please refer to Mr. Garmhausen’s accompanying Form ADV Part 2B brochure supplement for an explanation about his professional designations’ prerequisites and continuing education requirements. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 1 of 29  Item 2 – Material Changes This Form ADV Part 2A firm brochure has been revised from the previous version dated November 20, 2025, as part of the firm’s annual updating amendment to report the firm’s client assets under management; please see item 4 for details. No material changes have occurred. Our firm may at any time update this document and either send a copy of its updated brochure or provide a summary of material changes to its brochure and an offer to send an electronic or hard copy form of the updated brochure. Clients are also able to download this brochure from the SEC’s at www.adviserinfo.sec.gov or by contacting our firm at (844) 377-8526. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 2 of 29  Item 3 – Table of Contents Item 1 - Cover Page ............................................................................................................................................. 1 Item 2 - Material Changes .................................................................................................................................. 2 Item 3 - Table of Contents ................................................................................................................................... 3 Item 4 - Advisory Business ................................................................................................................................... 4 Item 5 - Fees and Compensation ......................................................................................................................... 6 Item 6 - Performance-Based Fees and Side-By-Side Management ..................................................................... 9 Item 7 - Types of Clients ...................................................................................................................................... 9 Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ................................................................ 9 Item 9 - Disciplinary Information ...................................................................................................................... 15 Item 10 - Other Financial Industry Activities and Affiliations ............................................................................ 15 Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ...................... 16 Item 12 - Brokerage Practices ........................................................................................................................... 17 Item 13 - Review of Accounts ............................................................................................................................ 20 Item 14 - Client Referrals and Other Compensation ......................................................................................... 21 Item 15 - Custody .............................................................................................................................................. 22 Item 16 - Investment Discretion ........................................................................................................................ 23 Item 17 - Voting Client Securities ...................................................................................................................... 23 Item 18 - Financial Information ........................................................................................................................ 24 Form ADV Part 2B - Principal Officer ................................................................................................................. 25 General Information Throughout this document, First Look Capital Management, LLC may also be referred to as “the firm,” “firm,” “our,” “we” or “us.” The client or prospective client may be also referred to as “you,” “your,” etc., and refers to a client engagement involving a single person as well as two or more persons, including legal entities and natural persons. In addition, the term “advisor” and “adviser” are used interchangeably where accuracy in identification is necessary (i.e., internet address, etc.). Our firm maintains a business continuity and succession plan that is integrated within the organization to ensure it appropriately responds to events that pose a significant disruption to its operations. A statement concerning the current plan is available under separate cover upon request. The business and disciplinary history, if any, of an investment advisory firm and its representatives, may be obtained by reviewing information available on the SEC’s website at www.adviserinfo.sec.gov. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 3 of 29  Item 4 - Advisory Business Description of the Firm First Look Capital Management, LLC is a Colorado-based, Texas limited liability company established in September of 2014. The firm’s original registration as an investment adviser began in Texas and Colorado in 2014, followed by the firm’s registration with the SEC in 2025. The firm is notice-filed in Colorado, Texas and Louisiana, and the firm and its personnel are exempt from notice filing or registration in other jurisdictions where our investment advisory business activities are conducted.2 John R. Garmhausen, CFP®, CFA, serves as the firm’s Managing Principal and Chief Compliance Officer. He is also the firm’s Managing Member and its only unitholder (“shareholder”). Additional information about Mr. Garmhausen may be found in his accompanying Form ADV Part 2B - Brochure Supplement. Description of Advisory Services Offered An initial complimentary interview is conducted by a representative of the firm to determine the scope of services to be provided. During or prior to this meeting the prospective client will be provided with our Form ADV Part 3 (Form CRS), Form ADV Part 2A firm brochure, privacy policy statement, as well as the Form ADV Part 2B brochure supplement about their investment adviser representative. In addition, the firm will ensure it has disclosed any material conflicts of interest that could be reasonably expected to impair the rendering of unbiased and objective advice. Should you wish to engage our firm for its advisory services, you must first execute our client engagement agreement. Thereafter, discussion and analysis will be conducted to determine your financial needs, goals, holdings, etc. Depending on the scope of the engagement, you may be asked to provide copies of the following documents early in the process: • wills, codicils, and trusts • insurance policies • mortgage information • tax returns • current financial specifics including W-2s or 1099s • information on current retirement plans and benefits provided by your employer • statements reflecting current investments in retirement and non-retirement accounts • employment or other business agreements you may have in place, and • completed risk profile questionnaires or other forms provided by our firm. It is important that the information and/or financial statements you provide are accurate. Our firm may, but is not obligated to, verify the information you have provided which will then be used in the advisory process. Our ability to provide advisory services depends on access to important information about our clients. It is necessary that you provide us with an adequate level of information and supporting documentation throughout the term of the engagement, including source of funds, income levels, and an account holder or their legal agent’s authority to act on behalf of the account, among other information. This helps us determine the appropriateness of our planning and/or investment strategies for your portfolio. 2 State jurisdictions where a firm is currently notice filed, can be determined via the SEC’s website at www.adviserinfo.sec.gov. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 4 of 29  Financial Planning Services For those interested in areas such as cash flow and budgeting, education funding, retirement planning, risk management, estate planning, as well as periodic investment advice, we offer our financial planning services. Our financial planning services may be as broad-based or narrowly focused as you desire. The incorporation of most or all the above-listed components allows not only a more thorough analysis but also an in-depth view of your plans to assist you in reaching your goals and objectives. Portfolio Management Services You may also engage our firm to implement investment strategies that we have recommended to you. Depending on your risk profile, goals and needs, among other considerations, your portfolio will involve the employment of one of our investment strategies as well as either a broad range or more narrowly focused choice of investment vehicles which are further discussed in Item 8 of this brochure, and our fee rates are noted in Item 5. Where appropriate, we will prepare investment guidelines reflecting your objectives, time horizon, tolerance for risk, as well as any account constraints you may have for the portfolio. These guidelines will be designed to be specific enough to provide future guidance while allowing flexibility to work with changing market conditions. Since this effort is the product of information and data you have provided, you may be asked to review it and provide your final approval. Through our portfolio management services offering we develop a customized portfolio for you based on your unique situation, investment goals and tolerance for risk. We serve as your portfolio manager primarily under a discretionary trading agreement (defined in Item 16), and the engagement generally includes: • determination of risk tolerance • investment strategy • investment guideline development • asset allocation • asset selection • regular monitoring, and • periodic rebalancing. Client-Tailored Services and Client-Imposed Restrictions Broad-Based v. Modular Financial Planning A broad-based plan is an endeavor that requires detail; therefore, certain variables can affect the cost involved in the development of the plan: the quality of your own records, complexity and number of current investments, diversity of insurance products and employee benefits you currently hold, size of the potential estate, and special needs of the client or their dependents, among others. While certain broad-based plans may require 10 or more hours to complete, complex plans may require more than 20 hours. Alternatively, per your requirement, we may concentrate on reviewing only a specific area (modular planning), such as an employer retirement plan allocation, education funding or estate planning issues, or evaluating the sufficiency of your current retirement plan. Note that when these services focus only on certain areas of your interest or need, your overall situation or needs may not be fully addressed due to limitations you may have established. Each financial planning client will receive a customized written plan in printed or digital format at the end of the process tailored to their situation. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 5 of 29  Whether we have created a broad-based or modular plan, we will present you with a summary of our recommendations, guide you in the implementation of some or all of them per your decision, as well as offer you periodic reviews thereafter (see Item 13). In all instances involving our financial planning engagements, our clients retain full discretion over all implementation decisions and are free to accept or reject any recommendation we make. Investment Account Restrictions We will account for any reasonable restrictions you may require for the management of your investment account(s). We want to note that it will remain your responsibility to promptly notify us if there is any change in your financial situation and/or investment objectives for the purpose of our reviewing, evaluating or revising previous account restrictions or firm investment recommendations. Client Assets Under Management As of December 31, 2026, the firm managed approximately $121.8 million of client assets on a discretionary basis. General Information First Look Capital Management, LLC does not offer an investment program involving bundled (wrapped) fees. We do not provide legal or accounting services but with your consent we will work with other professionals, such as an estate planning attorney, to assist with the coordination and implementation of accepted strategies. You should be aware that these other advisers will charge you separately for their services and these fees will be in addition to our own advisory fees. Item 5 - Fees and Compensation Forms of payment are based on the types of services being provided, terms of service, etc., as stated in your engagement agreement with our firm. Fees are to be paid by check or teller’s draft from US-based financial institutions. With your prior authorization payment may also be made through a qualified, unaffiliated third- party processor or withdrawal from your investment account held at your custodian of record. First Look Capital Management, LLC does not accept cash, money orders or similar forms of payment for its engagements. Types of Fees and Payment Schedule Financial Planning Services Our financial planning engagements are based on an hourly rate of $250 per hour. We bill in 30-minute increments, and a partial increment (e.g., 15 minutes) will be treated as a whole increment. Prior to entering into an agreement with the firm you will receive an estimate of the overall cost based on your requirements and the time involved. Generally, we require an advance deposit which will be the greater of $250 or one- half the estimated fee and is due at the onset of the engagement. Any remaining fees due to our firm are to be paid upon delivery of your plan. Portfolio Management Services Our firm does not assess account opening and/or administrative fees to initiate its portfolio management services, nor are there minimum account sizes or minimum fees to open or maintain an investment account. Fees for our engagements are based on an annualized asset-based fee that will be calculated based on the reporting period ending value of your account (e.g., the last market day of the quarter). First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 6 of 29  We assess our fee on a straight tier; all client account assets are charged at a single rate that declines as account asset levels increase. These fees will be billed quarterly, in arrears, per the following table. Formula: ((quarter-end market value) x (applicable number of basis points)) ÷ 4 Assets Under Management $0 - $999,999 $1,000,000 – Above Annualized Asset-Based Fee 0.90% (90 basis points) 0.60% (60 basis points) Fee Example: An account maintaining assets of $500,000 as of quarter’s end would be assessed $1,125 (quarterly, in arrears). Formula: ($500,000 x 90 bps) = $4,500 (annualized fee) ÷ 4 (quarters) = $1,125 (quarterly fee). Aggregating Fees – For the benefit of discounting your asset-based fee, we may aggregate accounts for the same individual or two or more accounts within the same family, or accounts where a family member has power of attorney over another family member’s or incompetent person's account. Should investment objectives be substantially different for any two or more household accounts, requiring different investment approaches or operational requirements, we reserve the right to apply our fee schedule separately to each account. Account Valuations – Accounts will be assessed in accordance with asset values disclosed on the statement the client will receive from the custodian of record for the purpose of verifying the computation of the advisory fee. In the rare absence of a reportable market value, our firm may seek a third-party opinion from a recognized industry source (e.g., unaffiliated public accounting firm), and the client may choose to separately seek such an opinion at their own expense as to the valuation of “hard-to-price” securities if necessary. Fee Withdrawals – Your written authorization is required for the custodian of record to deduct advisory fees from your investment account. By signing our firm’s engagement agreement, as well as the selected custodian account opening documents, you will be authorizing the withdrawal of both advisory and transactional fees (see following section) from your account. The withdrawal of these fees from your account will be accomplished by the selected custodian at the request of our firm, and the custodian will remit fees directly to our firm. We do not entertain requests for direct payment of our portfolio management services fee; they must be paid from the account held at our custodian or record. All fees deducted will be noted on account statements that you will receive directly from the custodian of record on a quarterly or more frequent basis. First Look Capital Management, LLC will not be entitled to cash or other client assets held by the custodian of record except those monies owed to our firm in connection with its services. Subject to the custodian’s fee debit procedures, advisory fees will be payable first from free credit balances, if any, in the account(s) designated for payment and, second, from the liquidation of any money market funds. If such assets are insufficient to satisfy payment of the advisory fees, we require clients to authorize the firm (subject to suitability guidelines) to instruct the custodian to liquidate a portion of any asset in the applicable account to cover the advisory fee. In addition, the firm will charge a client for fees and assessments associated with checks that are returned for insufficient funds assessed by the custodian, including, but not limited to, custodial/clearing firm fees or charges. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 7 of 29  Advisory Fee Discounts The services to be provided to you and their specific fees will be detailed in your engagement agreement. Our published fees are not negotiable, but we may discount accounts for our associates and their family members. We strive to offer fees that are fair and reasonable considering the experience of our firm and the services to be provided, and clients may be able to find lower fees for comparable services from other registered investment advisers. Additional Client Fees Any transactional or service fees (sometimes termed brokerage fees), individual retirement account fees, qualified retirement plan fees, account termination fees, or wire transfer fees will be borne by the account holder and per the separate fee schedule of your custodian of record. We will ensure you receive a copy of our custodian’s fee schedule at the beginning of the engagement, and you will be notified of any future changes to these fees by the custodian of record and/or third-party administrator for certain tax-qualified plans. Fees paid by our clients to our firm for our advisory services are separate from any of these fees or other similar charges. In addition, advisory fees for our firm’s services are separate from any transactional charges a client may pay, as well as those for mutual funds, exchange-traded funds (ETFs), exchange-traded notes (ETNs), index mutual funds or other investments of this type. Per annum interest at the current statutory rate may be assessed on fee balances due more than 30 days; we may refer past due accounts to collections or legal counsel for processing. We reserve the right to suspend some or all services once an account is deemed past due. We do not offer or limit our investment services or recommendations to proprietary products; a security managed, issued, or sponsored by a firm. If our firm begins to offer such products or limit our investment recommendations to such products, we will notify our clients of such changes prior to their effective date. Additional information about our fees in relationship to our brokerage practices is noted in Item 12 of this document. External Compensation for the Sale of Securities to Clients We do not charge or receive a commission or mark-up on your securities transactions, nor do we receive SEC Rule 12b-1 fees (“trails”) from a mutual fund company we may recommend to you. You retain the right to purchase recommended or similar investments through a provider of your choice (i.e., broker, agent, etc.). Firm policy prohibits associated persons from accepting or receiving additional economic benefit, such as sales awards or other prizes, for providing advisory services to our clients. Termination of Services Either party may terminate the agreement at any time by communicating their intent to terminate in writing. If you verbally notify our firm of the termination and, if in two business days following this notification we have not received your notice in writing, we will make a written notice of the termination in our records and send you our own termination notice as a substitute. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 8 of 29  We will not be responsible for investment allocation, advice or transactional services (except for limited closing transactions) upon receipt of a termination notice. It will also be necessary that we inform the custodian of record that the relationship between our firm and the client has been terminated. The client has the right to terminate the engagement without fee or penalty within five business days after entering into the agreement with our firm. Should a client terminate a financial planning engagement after this five-day time period, the client may be assessed fees at the firm’s current hourly rate for any time incurred in the preparation of the client’s analysis or plan. When a portfolio management services client terminates their agreement after the five-day period, the client will be assessed fees on a prorated basis for services incurred from either (i) as a new client, the date of the engagement to the date of the firm’s receipt of the written notice of termination, or (ii) all other accounts, the last billing period to the date of the firm’s physical or constructive receipt of written termination notice. The firm will return any prepaid, unearned fees within 30 days of the firm’s receipt of termination notice. Earned fees in excess of any prepaid deposit will be billed at the time of termination and will be due upon receipt of our invoice. Our return of payment to a client for our hourly fee will only be completed via check from our firm’s US-based financial institution; no credits or “transaction reversals” will be issued. We will only coordinate remuneration of prepaid asset-based fees to an investment account via your account custodian. Item 6 - Performance-Based Fees and Side-By-Side Management Our firm’s advisory fees will not be based on a share of capital gains or capital appreciation (growth) of any portion of managed funds, also known as performance-based fees. Our fees will also not be based on side- by-side management, which refers to a firm simultaneously managing accounts that do pay performance- based fees (such as a hedge fund) and those that do not. Item 7 - Types of Clients While our current client base consists of individual investors and high net worth investors, we are also available to serve small businesses. We do not require minimum income, minimum asset levels or other similar preconditions to open or maintain an account. Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategies Method of Analysis When we are engaged to provide investment advice, we will first gather and consider several factors, including your: • current financial situation and need • interim and long-term goals and objectives • level of investment knowledge • tolerance or appetite for risk, and • reasonable investment restrictions involving your portfolio. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 9 of 29  First Look Capital Management, LLC employs a blend of fundamental and cyclical analyses. Firm research may be drawn from sources that include financial periodicals, information published by economists and other industry professionals, corporate rating services, company press releases, as well as annual reports, prospectuses and regulatory filings. Investment Strategy We recognize that each client’s needs and goals are different; subsequently portfolio strategies and underlying investment vehicles may vary. Our strategies generally align with Core + Satellite and Modern Portfolio Theory. Core + Satellite This strategy blends passive (or index) and active investing, where passive investments are used as the basis or “core” of a portfolio and actively managed investments are added as “satellite” positions. With this strategy, portfolio core holdings are indexed to potentially more efficient asset classes, while outlying selections are generally limited to active holdings to outperform a particular category (sector), or a selection of positions to increase core diversification, or to improve portfolio performance. For example, the core of a portfolio may be built with low-cost index funds or ETFs; satellite holdings would include active investment managers (mutual funds) with unique strategies that are believed capable of adding value beyond a stated benchmark over a full market cycle. The core may represent most of the total portfolio, using primarily index funds or index-based ETFs. The remainder of the portfolio may then employ mutual funds or ETFs that take a shorter duration to assist in the over-or-under allocation to specific sectors, regions, assets classes, etc. Modern Portfolio Theory Modern Portfolio Theory states that by employing securities whose price movements have historically low correlations, it is possible to create an efficient portfolio that can offer the highest expected return for a given level of risk, or one with the lowest level of risk for a given expected return. The practice of Modern Portfolio Theory does not employ market timing or stock selection methods of investing but rather a long- term, buy-and-hold strategy with periodically rebalancing of the account to maintain desired risk levels. Investment Vehicles We will strive to create portfolios that contain investment vehicles that are diversified, tax-efficient, and low-cost investments whenever practical. Although it is common to find a broad range of mutual funds or ETFs within a portfolio, certain accounts may necessitate holding individual securities (stocks and bonds). Investment Strategy and Method of Analysis Material Risks The firm believes its strategies and investment recommendations are designed to produce the appropriate potential return for the given level of risk; however, there is no guarantee that an investment objective or planning goal will be achieved. Each client must be able to bear the risk of loss that is associated with their account, which may include the loss of some, or their entire principal invested. We have offered examples of such risks in the following paragraphs, and we believe it is important that you review and consider each of them risk prior to your investing. Note that some of the referenced risks are reflective of underlying holdings of a security (e.g., mutual funds, ETFs, etc.). First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 10 of 29  Company Risk When investing in securities, such as stocks, there is always a certain level of company or industry-specific risk that is inherent in each company or issuer. There is the risk that the company will perform poorly or have its value reduced based on factors specific to the company or its industry. This is also referred to as unsystematic risk and can be reduced or mitigated through diversification. Core + Satellite Strategies Strategies involving Core + Satellite investing may have the potential to be affected by “active risk” (or “tracking error risk”), which might be defined as a deviation from a stated benchmark. Since the core portfolio attempts to closely replicate a stated benchmark, the source of the tracking error or deviation may come from a satellite portfolio or position, or from a “sample” or “optimized” index fund or ETF that may not as closely align the stated benchmark. In these instances, a portfolio manager may choose to reduce the weighting of a satellite holding, utilize very active satellites, or use a “replicate index” position as part of its core holdings to minimize the effects of the tracking error in relation to the overall portfolio. Cyclical Analysis An economic cycle may not be as predictable as preferred; many fluctuations may occur between long-term expansions and contractions. The length of an economic cycle may be difficult to predict with accuracy and therefore the risk of cyclical analyses is the difficulty in predicting economic trends. Consequently, the changing value of securities is affected. Failure to Implement As a financial planning client, you are free to accept or reject any or all the recommendations made to you. While no advisory firm can guarantee future performance, no plan can succeed if it is not implemented. Clients who choose not to take the steps recommended in their financial plan may face an increased risk that their stated goals and objectives will not be achieved. Financial Risk Excessive borrowing to finance a business operation increases profitability risk because the company must meet the terms of its obligations in good times and bad. During periods of financial stress, the inability to meet loan obligations may result in bankruptcy and/or a declining market value. Fundamental Analysis The challenge involving fundamental analysis is that information obtained may be incorrect; the analysis may not provide an accurate estimate of earnings, which may be the basis for a security’s value. Inflation Risk Also called purchasing power risk, inflation risk is the chance that the cash flows from an investment will not be worth as much in the future because of changes in purchasing power due to inflation. Market Risk When the stock market as a whole or an industry or sector falls, it can cause the prices of individual stocks to fall indiscriminately. This is also called systemic or systematic risk. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 11 of 29  Passive Investing A portfolio that employs a passive, efficient markets approach (representative of Modern Portfolio Theory) has the potential risk at times to generate lower-than-expected returns for the broader allocation than might be the case for a more narrowly focused asset class, and the return on each type of asset may be a deviation from the average return for the asset class. We believe this variance from the expected return is generally low under normal market conditions when a portfolio is made up of diverse, low or non-correlated assets. Political Risk The risk of financial, market or personnel losses because of political decisions or disruptions in a particular country or region and may also be known as "geopolitical risk." Research Data When research and analyses are based on commercially available software, rating services, general market and financial information, or due diligence reviews, a firm is relying on the accuracy and validity of the information or capabilities provided by selected vendors, rating services, market data, and the issuers themselves. While our firm makes every effort to determine the accuracy of the information received, we cannot predict the outcome of events or actions taken or not taken, or the validity of all information researched or provided which may or may not affect the advice on investment management of an account. Sequence of Return Issues The risk of receiving lower or negative returns due to early withdrawals from an investment account. Settlement Risk Also called delivery risk. The risk that one party will fail to deliver the terms of an investment contract with another party (contra-party) at the time of settlement. Settlement risk can be a risk associated with default, along with any timing differences in a settlement between the two parties. Socially Conscious Investing If you require your portfolio to be invested according to socially conscious principles, you should note that returns on investments of this type may be limited and because of this limitation you may not be able to be as well diversified among various asset classes. The number of publicly traded companies that meet socially conscious investment parameters is also limited, and due to this limitation, there is a probability of similarity or overlap of holdings, especially among socially conscious mutual funds or ETFs. There could be a more pronounced positive or negative impact on a socially conscious portfolio, which could be more volatile than a fully diversified portfolio. Security-Specific Material Risks ETF Risks ETF risks include risks due to their underlying securities (e.g., stocks, bonds, etc.), and can be affected by risks such as market, currency, credit, political, interest rate, etc., that are described in adjacent paragraphs. The liquidity of the underlying stocks in the index can affect “ETF liquidity.” Liquidity risk can result from an insufficient number of “active participants” performing their duties as intermediaries and liquidity providers in the ETF market. “Spread risk” may also occur, which is the difference between the bid and the ask price of a security. Since ETF transactions are priced throughout the day and are traded on exchanges like stocks, First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 12 of 29  widening spreads may occur and have impact on certain portfolios or transactions. As with any security, if the ETF “fails,” the investor may lose their gains and invested principal. ETFs can carry additional expenses based on their share of operating expenses and certain brokerage fees. Indexed ETFs have the potential to be affected by “active risk;” a deviation from its stated index. Leveraged and/or inverse ETFs attempt to achieve multiples of the performance of an index or benchmark or the opposite (inverse) of the performance of the tracked index or benchmark. This strategy attempts to increase profit from upward drifting markets, or hedge exposures to, downward drifting markets. There is risk involving this strategy and part of the concern is due to leveraged and inverse exchange traded funds "reset" daily, which means they are designed to achieve their stated objectives on a daily basis. It is due to the compounding effect of daily adjustments that ETF performance over longer periods of time can differ significantly from the performance (or inverse of the performance) of an underlying index or benchmark during the same period. This effect is potentially magnified during volatile markets. If effects contrary to the ETF strategy occur, losses may be significant; therefore, leveraged and/or inverse ETFs will be considered for portfolios either properly hedged or for clients able to sustain potentially higher risks; they will not be used in portfolios where a "buy-and-hold" philosophy is important. Fixed Income Risks Various forms of fixed income instruments, such as bonds, money market or bond funds may be affected by various forms of risk, including: • Call Risk - During periods of falling interest rates, issuers of callable bonds may call (redeem) securities with higher coupons or interest rates before their maturity dates. The owner of the bond would then lose any potential price appreciation above the bond’s call price and would be forced to reinvest the unanticipated proceeds at lower interest rates, resulting in a decline in the owner’s income. Call risk is generally low for short-term bond funds, moderate for intermediate-term bond funds, high for long- term bond funds, and high for high-yield bonds. • Credit Risk - The potential risk that an issuer would be unable to pay scheduled interest or repay principal at maturity, sometimes referred to as “default risk.” Credit risk may also occur when an issuer’s ability to make payments of principal and interest when due is interrupted. Bondholders are creditors of an issuer and have priority to assets before equity holders (e.g., stockholders) when receiving a payout from liquidation or restructuring. When defaults occur due to bankruptcy, the type of bond held will determine seniority of payment. • Interest Rate Risk - The risk that the value of the fixed income holding will decrease because of an increase in interest rates. The longer the maturity of the bond, the more sensitive its value is to changes in interest rates. Bond prices and interest rate changes are inversely correlated. • Prepayment Risk - The prepayment risk is the premature return of principal on a fixed-income security. When principal is returned early on a security, future interest payments will not be paid on that part of the principal. The owner of the security would lose any price appreciation above the principal and be forced to reinvest the unanticipated proceeds possibly at lower interest rates, resulting in a decline of dividends, income, and returns. The risk of prepayment is most prevalent in fixed-income securities such as callable bonds and mortgage-backed securities. • Reinvestment Risk - With declining interest rates, investors may have to reinvest interest income or principal at a lower rate. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 13 of 29  • State Government and Municipal Securities Risk - State government and municipal securities are subject to various risks based on factors such as economic and regulatory developments, changes or proposed changes in the federal and state tax structure, deregulation, court rulings and other factors. Repayment of state and municipal securities depends on the ability of the issuer or project backing such securities to generate taxes or revenues. There is also a risk the interest on an otherwise tax- exempt municipal security may be subject to federal income tax. Unfavorable developments in any economic sector may have far-reaching ramifications on the overall state and municipal market. • US Government Securities Risk - US government securities are subject to varying interest rates and inflation risks. Not all US government securities are backed by the full faith and credit of the US government. Certain securities issued by agencies and instrumentalities of the US government are only insured or guaranteed by the issuing agency or instrumentality, which must rely on its own resources to repay the debt. As a result, there is risk these entities will default on a financial obligation. Index Investing You will need to keep in mind that investment vehicles such as certain ETFs and indexed funds have the potential to be affected by “tracking error risk” (see earlier paragraph under Core + Satellite Strategies). Liquidity Liquidity risk is the inability to readily buy or sell an investment for a price close to the true underlying value of the asset due to a lack of buyers or sellers. There are times when there is no trading volume/market depth to support a security’s current price. As such, the true value of the bond (for example) may not be supported by the current price. Conversely, when trading volume is high, there is also a risk of not being able to purchase a particular issue at the desired price. Money Market Funds A money market fund is managed to maintain a stable net asset value (NAV) of $1 per share, the value of the fund may fluctuate, and you could lose money (termed “breaking the buck”). Money market funds are a type of mutual fund investing in high-quality, short-term debt securities, pay dividends that generally reflect short-term interest rates and seek to maintain a stable NAV per share (typically $1). An investment in a money market mutual fund is generally not insured or guaranteed by the Federal Deposit Insurance Corporation, National Credit Union Share Insurance Fund, or any government agency. Mutual Funds As with ETFs, the risk of owning a mutual fund is reflected in the underlying security(ies). Mutual funds are affected by risks such as market, interest rate, currency, credit, political, active risk, etc., as described in adjacent paragraphs. It is important to note that even “conservative” funds, such as a money market fund or fixed income fund, can and have lost their value below the principal amount invested. Mutual funds typically carry additional expenses based on their share of operating expenses and trading (brokerage) fees, which may result in the potential duplication of certain fees paid by the investor. Indexed mutual funds can also be adversely affected by “QDI ratios” that are described in a following paragraph. There are essentially nine main types of mutual fund shares classes, as well as sub-classes for some of these. Some open and closed-ended funds are sold through brokerage firms and assess a commission (“load) in addition to their underlying fees earlier noted, while others are offered through investment advisers, retirement plans and other institutions. “No load” funds are also available to the public through brokerage First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 14 of 29  firms, and they usually incur trading (brokerage) fees. If a client chooses to purchase a mutual fund on their own through a broker/dealer, they should consider the trading fees, internal operating costs, as well as potential commissions they pay through that executing firm. Our firm is not a broker/dealer, nor is the firm or its staff associated with a broker/dealer, and no one in our firm is compensated by a “loaded” fund. QDI Ratios While many ETFs and index mutual funds are known for their potential tax-efficiency and higher “qualified dividend income” (QDI) percentages, there are asset classes within these investment vehicles or holding periods within that may not benefit. Shorter holding periods, as well as commodities and currencies (that may be part of an ETF or mutual fund portfolio), may be considered “non-qualified” under certain tax code provisions. QDI will be considered when tax-efficiency is an important aspect of the client’s portfolio. Item 9 - Disciplinary Information Neither the firm nor its management has been involved in any material criminal or civil action in domestic, foreign or military jurisdiction, an administrative enforcement action, or self-regulatory organization proceeding that would reflect poorly upon our offering advisory business or its integrity. Item 10 - Other Financial Industry Activities and Affiliations Firm policies require associated persons to conduct business activities in a manner that avoids conflicts of interest between the firm and its clients, or that may be contrary to law. First Look Capital Management, LLC will provide disclosure to each client prior to and throughout the term of an engagement regarding any conflicts of interest involving its business relationships that might reasonably compromise its impartiality or independence. Our advisory firm and its management are not registered nor have an application pending to register as a Financial Industry Regulatory Authority (FINRA) or National Futures Association (NFA) member firm or associated person of such a firm, nor are we required to be registered with such entities. Neither our firm nor its management is or has a material relationship with any of the following types of entities: • accounting firm or accountant • another investment adviser, to include financial planning firms, municipal advisers, sub-advisers or third- party investment managers; nor do we recommend/refer, select or utilize their services • bank, credit union or thrift institution, or their separately identifiable department or division • insurance company or insurance agency/broker • lawyer or law firm • pension consultant • real estate broker, dealer or adviser • sponsor or syndicator of limited partnerships • trust company, or • issuer of a security, to include investment company or other pooled investment vehicle (including a mutual fund, closed-end investment company, unit investment trust, private investment company or “hedge fund,” and offshore fund). First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 15 of 29  Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading First Look Capital Management, LLC holds itself to a fiduciary standard, which means the firm and its associates will act in the utmost good faith, performing in a manner believed to be in the best interest of its clients. Our firm believes that business methodologies, ethics rules, and adopted policies are designed to eliminate or at least minimize material conflicts of interest and to appropriately manage any material conflicts of interest that may remain. You should be aware that no set of rules can possibly anticipate or relieve all material conflicts of interest. Our firm will disclose to its advisory clients any material conflict of interest relating to the firm, its representatives, or any of its employees which could reasonably be expected to impair the rendering of unbiased and objective advice. Code of Ethics We have adopted a Code of Ethics that establishes policies for ethical conduct for our personnel. Our firm accepts the obligation not only to comply with all applicable laws and regulations but also to act in an ethical and professionally responsible manner in all professional services and activities. Firm policies include prohibitions against insider trading, circulation of industry rumors, and certain political contributions, among others. First Look Capital Management, LLC periodically reviews and amends its Code of Ethics to ensure that it remains current and requires firm personnel to annually attest to their understanding of and adherence to the firm’s Code of Ethics. A copy of the firm’s Code of Ethics is made available to any client or prospective client upon request. CFP® Principles Firm personnel that are CFP® Practitioners also adhere to the Certified Financial Planner Board of Standards of Conduct and Code of Ethics. Clients wishing to view these standards may do so at www.CFP.net. CFA Code of Ethics An associate that is a Chartered Financial Analyst (CFA) also adheres to the CFA Institute’s Code of Ethics and Standards of Professional Conduct which may be found at www.cfainstitute.org. Firm Recommendations and Conflicts of Interest Neither the firm nor an associate is authorized to recommend to a client, or effect a transaction for a client, involving any security in which the firm or a “related person” (e.g., associate, an immediate family member, etc.) has a material financial interest, such as in the capacity as a board member, underwriter or adviser to an issuer of securities, etc. An associate is prohibited from borrowing from or lending to a client unless the client is an approved financial institution. The firm remains focused on ensuring that its offerings are based upon the needs of its clients, not resultant fees received for our services. We note that you are under no obligation to act on a recommendation from our firm and, if you choose to do so, you are under no obligation to complete them through our firm or a service provider whom we may recommend. First Look Capital Management, LLC does not trade for its own account (e.g., proprietary trading). The firm’s related persons may buy or sell securities that are the same as, similar to, or different from, those recommended to clients for their accounts, and this poses a conflict of interest. We mitigate this conflict by First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 16 of 29  ensuring that we have policies and procedures in place to ensure that the firm or a related person will not receive preferential treatment over a client. In an effort to reduce or eliminate certain conflicts of interest involving personal trading (i.e., trading ahead of client recommendation, etc.), firm policy may require that we periodically restrict or prohibit related parties’ transactions. Any exceptions must be approved by the firm, and we will maintain personal securities transaction records as required. Item 12 - Brokerage Practices Factors Used to Select Broker/Dealers for Client Transactions Client accounts must be separately maintained by an unaffiliated, qualified custodian (generally a broker/dealer, futures commission merchant, national bank, or trust company) that is frequently reviewed for its capabilities to serve in that capacity by their respective industry regulatory authority. Our firm is not a custodian or broker/dealer, there is not an affiliate that is a custodian or broker/dealer, nor does a custodian or broker/dealer supervise our firm, its activities, or our associates. We do not receive referrals from a custodian or broker/dealer, nor would client referrals ever be a factor in our recommendation of a custodian or broker/dealer. If we are engaged to provide an investment consultation component of our financial planning service, we may recommend the service provider where client assets are currently maintained. If a client prefers a new service provider, a recommendation made by the firm would be based on client need, overall cost, and ease of use. We have entered into an agreement with Charles Schwab & Co., Inc. (“Schwab”) to serve as custodian of record for our clients. Schwab is a FINRA and SIPC member,3 as well as an SEC-registered broker/dealer. While we recommend that clients use Schwab as custodian, the client must decide whether to do so and will open their account by entering into an account agreement directly with Schwab. We do not technically open an account for a client, but we will assist the client in doing so. If a client does not wish to place their assets with Schwab, we may be able to manage the account at the client’s preferred custodian depending on that custodian’s account trading policies. We seek to use a custodian who will hold client assets and execute transactions on terms that are overall advantageous when compared to other available providers and their services. Our firm considers a wide range of factors, including, among others, these: • combination of transaction execution services along with asset custody services (generally without a separate fee for custody) • capability to execute, clear and settle trades (buy and sell securities for an account) • capabilities to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • breadth of investment products made available (stocks, bonds, mutual funds, ETFs, etc.) • availability of investment research and tools that assist us in making investment decisions • quality of services • competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate them • reputation, financial strength, and stability of the provider 3 Our advisory firm is not, nor required to be, a Securities Investor Protection Corporation (SIPC) member. Clients may learn more about the SIPC and how it serves member firms and the investing public by going to their website at http://www.sipc.org. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 17 of 29  • their prior service to us and our other clients, and • availability of other products and services that benefit us, as discussed below. When the client’s account is maintained at Schwab, they are typically not charged separately for custody services and Schwab are compensated by charging a commission or other fees that Schwab executes or that settle into a Schwab account. Schwab’s fees applicable to our client accounts were negotiated based on our commitment to maintain a certain number of clients’ assets in accounts held at Schwab. This commitment benefits our client because overall commission rates are lower than they would be if we had not made the commitment. Schwab Advisor ServicesTM (formerly called “Schwab Institutional”) is Schwab’s business serving independent investment advisory firms like ours. They provide our firm and its clients with access to its institutional brokerage - trading, custody, reporting and related services - many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts, while others help us manage and grow our business. Schwab’s support services are generally available to us on an unsolicited basis (we don’t have to request them) and at no charge to us if we keep a certain level of our clients’ assets in accounts at Schwab. 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 from our clients. Schwab’s services described in previous paragraphs generally benefit our clients. Schwab also makes available to our advisory firm other products and services that benefit us but may not directly benefit each client’s account. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We may 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: • provides access to client account data (such as duplicate trade confirmations and account statements) • facilitates trade execution and allocates aggregated trade orders for multiple client accounts • provides pricing and other market data • facilitate payment of our fees from our clients’ accounts, and • assists with back-office functions, recordkeeping and client reporting. Schwab also offers other services intended to help us manage and further develop our business enterprise, such as: • educational conferences and events • technology, compliance, legal, and business consulting • publications and conferences on practice management and business succession, and • access to employee benefits providers, human capital consultants and insurance providers. Schwab may provide some of these services itself. In other cases, they may arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third party’s fees. Schwab may also provide us with other benefits such as occasional business entertainment for our personnel. Some of the noted tools and services made available by Schwab may benefit our advisory firm but may not directly benefit a client account. Certain tools, services or discounts First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 18 of 29  made available to our firm by our custodian benefit our advisory firm but may not directly benefit each client’s account. While our firm does not think these services are considered "brokerage or research services" under Section 28(e) of the Securities Exchange Act of 1934, certain jurisdictions where we serve client accounts believe they fall under this definition. The availability of these services benefits our firm because we do not have to produce or purchase them if clients maintain assets in accounts at our recommended custodian. There is a conflict of interest since our firm has an incentive to select or recommend a custodian based on our firm’s interest in receiving these benefits rather than the client’s interest in receiving favorable trade execution. It is important to mention that the benefit received by our firm through participation in any custodian’s program does not depend on the amount of brokerage transactions directed to that custodian, and our selection of a custodian is primarily supported by the scope, quality, and cost of services provided as a whole, not just those services that benefit only our advisory firm. Further, we will act in the best interest of our clients regardless of the custodian we may select. Our firm conducts periodic assessments of any recommended service provider which generally involves a review of the range and quality of services, reasonableness of fees, among other items, in comparison to industry peers. Best Execution “Best execution” means the most favorable terms for a transaction based on all relevant factors, including those listed in the paragraph titled Factors Used to Select Broker/Dealers for Client Transactions. We recognize our obligation in seeking best execution for our clients; however, it is our belief that the determinative factor is not always the lowest possible cost but whether the selected custodian’s transactions represent the best “qualitative execution” while taking into consideration the full range of services provided. The firm will seek services involving competitive rates, but it may not necessarily correlate with the lowest possible rate for each transaction. We have determined having portfolio management services account trading completed through our recommended custodian is consistent with the firm’s obligation to seek best execution of your trades. A review is regularly conducted regarding recommending a custodian to our clients considering our duty to seek best execution. Our firm may, in its discretion and following custodian authorization, accept a client’s transfer of preexisting retail mutual funds into their account. A transfer-in-kind of retail share-class mutual funds may potentially benefit the client since they are able to invest in their portfolio more quickly, mitigate tax and/or short-term trading liabilities, and/or avoid contingent deferred sales charges (CDSC). Our firm regularly reviews accounts that have transferred different share classes of mutual funds and will convert share classes into a lower expense share class when we believe doing so would be beneficial to the client. In addition, if account assets remain in a retail share class and within a CDSC period, we may exclude those assets from our advisory fee until they have been converted into what we believe is a more appropriate share class. While our firm has access to a broad range of securities through our custodians, it is a finite number. In addition, not all investment managers, share classes, etc., are represented at each custodian. Due to these normal and customary limitations, not all portfolio holdings will be readily available, least expensive, best performing, etc. It is an unrealistic expectation for an investor to maintain a premise otherwise. Directed Brokerage Not all investment advisers require their clients to direct brokerage, nor do we think our firm is involved in directed brokerage per industry definition. However, our operational relationship with our custodian require client accounts custodied with them to have trades executed per their order routing requirements. We do not direct which executing broker should be selected for client account trades, whether that is an affiliate of First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 19 of 29  our preferred custodian or another executing broker of our custodian’s choice. As a result, the client may pay higher commissions or other transaction costs, experience greater spreads, or receive less favorable net prices on transactions than might otherwise be the case. In addition, since we routinely recommend a custodian to our advisory clients, and that custodian may choose to use the execution services of its broker affiliate for some or all our client account transactions, there is an inherent conflict of interest involving our recommendation since our advisory firm receives various products or services described above from that custodian. Note that we are not compensated for trade routing/order flow, nor are we paid commissions on such trades. We do not receive interest on an account’s cash balance. Client accounts maintained at our custodian are unable to direct brokerage. As a result, they may pay higher commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case if they had the opportunity to direct brokerage. For accounts maintained at a custodian of the client’s choice (e.g., held-away accounts), the client may choose to request that a particular broker is used to execute some or all account transactions. Under these circumstances, the client will be responsible for negotiating, in advance of each trade, the terms and/or arrangements involving their account with that broker, and whether the selected broker is affiliated with their custodian of record or not. We will not be obligated to seek better execution services or prices from these other brokers, and we will be unable to aggregate transactions for execution via our custodian with other orders for accounts managed by our firm. As a result, the client may pay higher commissions or other transaction costs, potentially experience greater spreads, or receive less favorable net prices on transactions for their account than would otherwise be the case. Aggregating Securities Transactions Trade aggregation involves the purchase or sale of the same security for several clients/accounts at approximately the same time. This is also termed “blocked, “bunched” or “batched” orders. Aggregated orders are affected to obtain better execution, negotiate favorable transaction rates, or to allocate equitably among multiple client accounts should there be differences in prices, brokerage commissions or other transactional costs that might otherwise be unobtainable through separately placed orders. Our firm may but is not obligated to aggregate orders, and the firm does not receive additional compensation or remuneration because of aggregated transactions. Transaction charges and/or prices may vary due to account size and/or method of receipt. To the extent that the firm determines to aggregate client orders for the purchase or sale of securities, including securities in which a related person may invest, the firm will generally do so in accordance with the parameters set forth in SEC No-Action Letter, SMC Capital, Inc. Please note that when trade aggregation is not allowed or infeasible and necessitates individual transactions (e.g., withdrawal or liquidation requests, odd-lot trades, non-discretionary accounts, etc.), an account may potentially have higher costs or less favorable prices than those where aggregation has occurred. Item 13 - Review of Accounts Schedule for Periodic Review of Client Accounts Financial Planning Services Periodic financial check-ups or reviews are recommended if you are receiving our financial planning services, and we recommend that they occur at least on an annual basis whenever practical. Reviews will be First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 20 of 29  conducted by your assigned investment adviser representative and may involve analysis and possible revision of your previous financial plan or investment allocation. A copy of revised plans or asset allocation reports will be provided to the client upon request. Unless provided for in your engagement agreement, reviews are generally conducted under a new or amended agreement and will be assessed at our current fee rate. Portfolio Management Services Accounts are reviewed on a quarterly or frequent basis by Mr. Garmhausen. Client-level reviews are completed by your investment adviser representative, and we recommend that they occur on at least an annual basis. A copy of a revised investment guideline or asset allocation reports will be provided to the client upon request. Review of Client Accounts on Non-Periodic Basis Financial Planning Services You should contact our firm for additional reviews when you anticipate or have experienced changes in your financial situation (i.e., changes in employment, inheritance, the birth of a new child, etc.), or should you prefer to change requirements involving your investment account. Non-periodic reviews are generally conducted by your investment adviser representative, which may occur under a new or amended agreement, and will be assessed at our published rate. A copy of revised plans or asset allocation reports will be provided to the client upon request. Portfolio Management Services Additional reviews by your assigned investment adviser representative and/or firm supervisory personnel may be triggered by news or research related to a specific holding, a change in our view of the investment merits of a holding, or news related to the macroeconomic climate affecting a sector or holding within that sector. A portfolio may be reviewed for an additional holding or when an increase in a current position is under consideration. Account cash levels above or below what we deem appropriate for the investment environment, given the client's stated tolerance for risk and investment objectives, may also trigger a review. Content of Client Provided Reports and Frequency Whether you have opened and maintained an investment account on your own or with our assistance, you will receive account statements sent directly from mutual fund companies, transfer agents, custodians or brokerage companies where your investments are held. We urge you to carefully review these account statements for accuracy and clarity, and to ask questions when something is not clear. We do not provide performance reports through a financial planning engagement. Portfolio management services accounts may receive performance reports from our firm that have been generated from our custodian’s data systems. Clients are reminded to carefully review and compare account statements provided by their custodian of record with any report they have received from any source containing investment performance information. Item 14 - Client Referrals and Other Compensation Please refer to Item 12 for information with respect to our relationship with our preferred custodian and the conflicts of interest it presents. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 21 of 29  We do not engage in solicitation activities. If we receive or offer an introduction to a client, we do not pay or earn a referral fee, nor are there established quid pro quo arrangements. Each client has the right to accept or deny such referral or subsequent services. Item 15 – Custody Our firm does not take physical custody of a client account. Our clients’ accounts must be maintained by an unaffiliated, qualified custodian. Accounts are not to be maintained by our firm or any associate of our firm. In keeping with this policy involving our clients’ accounts, our firm: • restricts the firm or an associate from having general power of attorney over a client account • restricts the firm or an associate from serving as trustee over a client account (unless it is an immediate family member) • does not accept or forward client securities (i.e., stock certificates) erroneously delivered to our firm • prohibits the firm or an associate from having the client’s bank or investment account access information (i.e., passwords and user identification) • will not collect advance fees of $1,200 or more for services that are to be performed six months or more into the future, and • prohibits associates from having authority to directly withdraw securities or cash assets from a client account. Although we may be deemed to have limited (aka. constructive or indirect) custody of an account since we may request the withdrawal of advisory fees from an investment account, we will do so only on the following terms: o our firm will possess written authorization from the client to deduct advisory fees from an account held by their custodian of record o we will send the client’s qualified, unaffiliated custodian a notice of the amount of the fee to be deducted from the client’s account, and o the client must be able to receive an account statement directly from the account custodian. • does not allow standing letters of authority (SLOAs) unless the: o client provides written instruction to their qualified custodian that includes the client’s signature, the third party’s name, and either the third party’s address or the third party’s account number at a custodian to which the transfer should be directed o client authorizes the firm in writing on their qualified custodian’s form any power to direct transfers to the third party either on a specified schedule or from time to time o client’s qualified custodian performs appropriate verification of the client’s instructions, such as a signature review or other method to verify the client’s authorization and provides a transfer of funds notice to the client promptly after each transfer o client can terminate or change the instruction to the client’s qualified custodian o firm has no authority or ability to designate or change the identity of the third party, the address, or any other information about the third party contained in the client’s instruction o third party is not a related party to our firm and is located at a different address as the firm o client’s qualified custodian sends the client a written initial notice confirming the instruction, and o client is annually provided notice reconfirming their instructions. The client’s custodian of record will provide account transaction confirmations and account statements, which include debits and credits, as well as our firm’s advisory fee for that period. Statements are provided on at least a quarterly basis or as transactions occur within an account. We urge all our clients to inform us if First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 22 of 29  they are not receiving their trade confirmations or account statements from their custodian. Our firm will not create a separate account statement for a client nor serve as the sole recipient of a client account statement. Item 16 - Investment Discretion Portfolio Management Services We generally provide our portfolio management services on a discretionary basis. Via limited power of attorney signed by the client, discretionary authority allows our firm to determine the securities to be bought or sold for your account and the amount of securities to be bought or sold for the account without requiring your ongoing prior authorization for each transaction in order to meet stated investment objectives. This authority will be granted by you through the execution of both our engagement agreement and the selected custodian’s account documents. Note that the custodian will specifically limit our firm’s authority within your account to the placement of trade orders and the request for the deduction of our advisory fees. Our firm prefers not to manage client accounts on a non-discretionary basis, but we may accommodate such requests on a case-by-case basis. Such trading authority requires your ongoing prior approval involving investment and reinvestment of account assets, portfolio rebalancing, or for our firm to give instructions to the custodian maintaining your account (i.e., wire instructions, etc.). Should you find it necessary to require such restrictions, we may not offer a reduced fee due to the additional operational costs involved managing your account. You will be required to execute our firm’s client services agreement that describes our limited account authority, as well as the custodian of record’s account opening document that includes their limited power of attorney form or clause. Please note that considering the requirement for your pre-approval you must make yourself available and keep our firm updated on your contact information so that instructions can be efficiently affected on your behalf. Financial Planning Engagements If you ask us to assist you in any trade execution (including account rebalancing) under an investment consultation component of our financial planning engagement, such as assisting you with your held-away assets, it will only be accomplished on a non-discretionary basis. Item 17 - Voting Client Securities You may periodically receive proxies or other similar solicitations sent directly from your selected custodian or transfer agent. If we receive a duplicate copy, note that we do not forward these or any correspondence relating to the voting of your securities, class action litigation, or other corporate actions. Our firm does not vote proxies on your behalf, including accounts we have discretionary authority over; nor do we offer guidance on how to vote proxies. We will not offer guidance involving any claim or potential claim in any bankruptcy proceeding, class action securities litigation or other litigation or proceeding relating to securities held at any time in a client account, including, without limitation, to file proofs of claim or other documents related to such proceeding, or to investigate, initiate, supervise or monitor class action or other litigation involving client assets. However, we will answer limited questions with respect to what a proxy voting request or other corporate matter may be and how to reach the issuer or their legal representative. You maintain exclusive responsibility for directing the manner in which proxies solicited by issuers of securities that are beneficially owned by you shall be voted, as well as making all other elections relative to mergers, acquisitions, tender offers or other legal matters or events pertaining to your holdings. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 23 of 29  You should consider contacting the issuer or your legal counsel involving specific questions you may have with respect to a particular proxy solicitation or corporate action. Item 18 - Financial Information Our firm will not take physical custody of your assets. Fee withdrawals must be made through a qualified intermediary (e.g., your custodian of record), according to your prior written agreement. Engagements with our firm do not require that we collect fees from you of $1,200 or more for our advisory services that we have agreed to perform six months or more into the future. Neither our firm nor its management serve as general partner for a partnership or trustee for a trust in which the firm’s advisory clients are either partners of the partnership or beneficiaries of the trust. The firm and its management do not have a financial condition likely to impair its ability to meet commitments to clients, nor has the firm and its management been the subject of a bankruptcy petition. Due to the nature of our firm’s advisory services and operational practices, an audited balance sheet is not required nor included in this brochure. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 24 of 29  Form ADV Part 2B – John R. Garmhausen Item 1 – Cover Page Mailing Address 49 Gillaspey Ave. Crested Butte, CO 81224 Main Office 100 Teocalli Road/Suite #4 Crested Butte, CO 81224 (844) 377-8526 Extension #2 www.firstlookcm.com John R. Garmhausen, CFP®, CFA Managing Principal/Chief Compliance Officer Investment Adviser Representative Managing Member Form ADV Part 2B Brochure Supplement February 9, 2026 This brochure provides information about John R. Garmhausen that supplements the First Look Capital Management, LLC Form ADV Part 2A firm brochure. You should have received a copy of that brochure. Please contact our Chief Compliance Officer, Mr. Garmhausen, at (844) 377-8526 Extension #2 if you did not receive the full brochure or if you have any questions about the contents of this supplement. Additional information about John R. Garmhausen is available on the Securities and Exchange Commission’s (SEC) website at www.adviserinfo.sec.gov. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 25 of 29  Item 2 – Educational Background and Business Experience Regulatory guidance requires the firm to disclose relevant post-secondary education and professional training for each principal executive and associate of the firm, as well as their business experience for at least the most recent five years. Principal Executive Officers and Management Persons Managing Principal/Chief Compliance Officer/Investment Adviser Representative/Managing Member John Roth Garmhausen Year of Birth: 1972 CRD Number: 5316190 Educational Background Bachelor of Arts in Recreation Management, Appalachian State University; Boone, NC (1995) CERTIFIED FINANCIAL PLANNER® Practitioner,A CFP®, Certified Financial Planner Board of Standards, Inc. (2010) Chartered Financial Analyst (CFA),B CFA Institute (2008) Business Experience First Look Capital Management, LLC (09/2014-Present) Crested Butte, CO Managing Principal/Chief Compliance Officer/Investment Adviser Representative/Managing Member Stay-At-Home Parent (05/2014-09/2014) Crested Butte, CO Charles Schwab & Co., Inc./Charles Schwab Bank (07/2008-05/2014) San Francisco, CA (Austin, TX office) Vice President - Financial Consultant Item 3 – Disciplinary Information Registered investment advisers are required to disclose specific legal and disciplinary events presumed to be material about its associated personnel regarding certain legal or disciplinary events, including criminal or civil actions in a domestic, foreign, or military court of competent jurisdiction. Additionally, registered investment advisers are required to disclose administrative proceedings before the SEC, any other federal regulatory agency, any state regulatory agency, any foreign financial regulatory authority, or any self- regulatory organization in which the firm or any of its management was found to have been involved in a violation of an investment-related statute or regulation and was the subject of an order by the agency or authority or similar actions that would be material to a client’s or prospective client’s evaluation of the firm’s advisory business or the integrity of its management. These matters do not apply to Mr. Garmhausen. Item 4 – Other Business Activities Investment adviser representatives are required to disclose outside business activities that account for a significant portion of their time or income, or that may present a conflict of interest with their advisory activities. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 26 of 29  Mr. Garmhausen is not registered, nor does he have an application pending to register, as a registered representative of a broker/dealer or associated person of a futures commission merchant, commodity pool operator, or commodity trading adviser. He does not receive commissions, bonuses or other compensation based on the sale of securities, including that as a registered representative of a broker/dealer or the distribution or service fees (“trails”) from the sale of mutual funds. Neither he nor our advisory firm has a material relationship with the issuer of a security. Item 5 – Additional Compensation Neither our advisory firm nor Mr. Garmhausen are compensated for advisory services involving performance-based fees. In addition, firm policy does not allow associated persons to accept or receive additional economic benefit, such as sales awards or other prizes, for providing advisory services to firm clients. Item 6 – Supervision Mr. Garmhausen serves as the firm’s Chief Compliance Officer. The firm recognizes that not having all organizational duties segregated may potentially create a conflict of interest; however, the firm employs policies and procedures to ensure timely recordkeeping and supervision. Mr. Garmhausen adheres to these policies and our firm’s Code of Ethics. Mr. Garmhausen will monitor firm activities and the advice provided by performing the following ongoing reviews: • account opening documentation when the relationship is established • review of account transactions • assessments of the client’s financial situation, objectives, and investment needs • review of client correspondence on an as needed basis, and • periodic internal firm review. Questions relating to the firm, staff, its services, or this Form ADV Part 2 may be made for the attention of Mr. Garmhausen at (844) 377-8526 Extension #2. Additional information about the firm, other advisory firms, or an associated investment adviser representative is available on the Internet at www.adviserinfo.sec.gov. A search of this site for firms may be accomplished by firm name or a unique firm identifier, known as an IARD or CRD number. The IARD number for First Look Capital Management, LLC is 173040. The employment and disciplinary history, if any, of an investment advisory firm representative may be obtained by reviewing information available in their Form ADV Part 2B brochure supplement, as well as on the SEC’s website at www.adviserinfo.sec.gov, or by contacting the state securities commissioner where the client resides. If a representative is or has been associated as registered representative of a Financial Industry Regulatory Authority (FINRA) member broker/dealer, that representative’s information may also be found at https://brokercheck.finra.org/. If a representative is or has been an associated person of a National Futures Association (NFA) member firm, that person’s information may also be found at https://www.nfa.futures.org/BasicNet. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 27 of 29  Information about Professional Designations A The CERTIFIED FINANCIAL PLANNER®, CFP® and federally registered CFP (with flame design) marks (collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified Financial Planner Board of Standards, Inc. (“CFP Board”). The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial planners to hold CFP® certification. It is recognized in the United States and a number of other countries for its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and (3) ethical requirements that govern professional engagements with clients. To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements: • Education – Complete an advanced college-level course of study addressing the financial planning subject areas that CFP Board’s studies have determined as necessary for the competent and professional delivery of financial planning services, and attain a bachelor’s degree from a regionally accredited United States college or university (or its equivalent from a foreign university). CFP Board’s financial planning subject areas include insurance planning and risk management, employee benefits planning, investment planning, income tax planning, retirement planning, and estate planning; • Examination – Pass the comprehensive CFP® Certification Examination. The examination includes case studies and client scenarios designed to test one’s ability to correctly diagnose financial planning issues and apply one’s knowledge of financial planning to real world circumstances; • Experience – Complete at least three years of full-time financial planning-related experience (or the equivalent, measured as hours per year); and • Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents outlining the ethical and practice standards for CFP® professionals. Individuals who become certified must complete the following ongoing education and ethics requirements in order to maintain the right to continue to use the CFP® marks: • Continuing Education – Complete 30 hours of continuing education hours every two years, including two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain competence and keep up with developments in the financial planning field; and • Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards prominently require that CFP® professionals provide financial planning services at a fiduciary standard of care. This means CFP® professionals must provide financial planning services in the best interests of their clients. CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP Board’s enforcement process, which could result in suspension or permanent revocation of their CFP® certification. B The Chartered Financial Analyst (CFA) charter is a globally respected, graduate-level investment credential established in 1962 and awarded by CFA Institute — the largest global association of investment professionals. There are currently more than 170,000 CFA charterholders working in 134 countries. To earn the CFA charter, candidates must: 1) pass three sequential, six-hour examinations; 2) have at least four years of qualified professional investment experience; 3) join CFA Institute as members; and 4) commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and Standards of Professional Conduct. High Ethical Standards The CFA Institute Code of Ethics and Standards of Professional Conduct, enforced through an active professional conduct program, require CFA charterholders to: • Place their clients’ interests ahead of their own • Maintain independence and objectivity • Act with integrity First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 28 of 29  • Maintain and improve their professional competence • Disclose conflicts of interest and legal matters Global Recognition Passing the three CFA exams is a difficult feat that requires extensive study (successful candidates report spending an average of 300 hours of study per level). Earning the CFA charter demonstrates mastery of many of the advanced skills needed for investment analysis and decision making in today’s quickly evolving global financial industry. As a result, employers and clients are increasingly seeking CFA charterholders—often making the charter a prerequisite for employment. Additionally, regulatory bodies in over 30 countries and territories recognize the CFA charter as a proxy for meeting certain licensing requirements, and more than 125 colleges and universities around the world have incorporated a majority of the CFA Program curriculum into their own finance courses. Comprehensive and Current Knowledge The CFA Program curriculum provides a comprehensive framework of knowledge for investment decision making and is firmly grounded in the knowledge and skills used every day in the investment profession. The three levels of the CFA Program test a proficiency with a wide range of fundamental and advanced investment topics, including ethical and professional standards, fixed-income and equity analysis, alternative and derivative investments, economics, financial reporting standards, portfolio management, and wealth planning. The CFA Program curriculum is updated every year by experts from around the world to ensure that candidates learn the most relevant and practical new tools, ideas, and investment and wealth management skills to reflect the dynamic and complex nature of the profession. The CFA Institute recommends members complete a minimum of 20 hours of continuing education activities, including two hours in the content areas of Standards, Ethics, and Regulations each calendar year. To learn more about the CFA charter, visit www.cfainstitute.org. Passing an industry professional certification exam or holding a professional designation does not preclude the obligation for a person to be registered as an investment adviser representative in jurisdictions where required by statute. First Look Capital Management, LLC Form ADV Part 2 – 20260209 Page 29 of 29