Fort Point Capital Partners LLC

Item 1 – Cover Page Fort Point Capital Partners LLC 275 Sacramento Street, 8th Floor San Francisco, CA 94111 (415) 645-0909 www.fortpointcap.com March 31, 2026 This Brochure provides information about the qualifications and business practices of Fort Point Capital Partners LLC ("Fort Point"). If you have any questions about the contents of this Brochure, please contact us at (415) 645-6503 or email us at info@fortpointcap.com. The information in this Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Fort Point is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. Additional information about Fort Point is also is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2 – Material Changes Since the filing of our most recent amendment dated March 2025, we have no material changes to report. 2  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 ....................................................................................................................................8 Item 6 – Performance-Based Fees and Side-By-Side Management ........................................................... 10 Item 7 – Types of Clients .................................................................................................................................................... 10 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ....................................................... 11 Item 9 – Disciplinary Information .................................................................................................................................... 14 Item 10 – Other Financial Industry Activities and Affiliations ............................................................................ 14 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading .... 14 Item 12 – Brokerage Practices ........................................................................................................................................ 15 Item 13 – Review of Accounts .......................................................................................................................................... 17 Item 14 – Client Referrals and Other Compensation ............................................................................................ 18 Item 15 – Custody .................................................................................................................................................................. 18 Item 16 – Investment Discretion ..................................................................................................................................... 19 Item 17 – Voting Client Securities .................................................................................................................................. 19 Item 18 – Financial Information ....................................................................................................................................... 20 3  Item 4 – Advisory Business Fort Point Capital Partners LLC (“Fort Point”), a California Limited Liability Company established in October 2008, is an SEC-registered Investment Advisor. Fort Point is principally owned by Ralph Drybrough, Paul Touchstone, Tim McDowell, Robin Brinckerhoff, Roy Haya, and Chad DeMartini. Ralph M. Drybrough III founded Fort Point in 2008. Prior to founding Fort Point, Mr. Drybrough was a financial advisor and principal with Presidio Capital Advisors from 2005 to 2008. Between 1999 and 2005, Mr. Drybrough was a registered representative and financial advisor with Merrill Lynch & Co. Mr. Drybrough began his career in the financial industry at UBS/PaineWebber in Chicago, Illinois, where he worked as a registered representative and financial advisor. Mr. Drybrough received a B.A. in Journalism/History from Indiana University, Bloomington, Indiana in 1997. Mr. Drybrough holds FINRA Series 7 and 63 securities licenses and is a Registered Representative of Uhlmann Price Securities, LLC as described in Item 10 below. Paul R. Touchstone joined Fort Point in April 2012 and became a Managing Member in December 2017. Prior to joining Fort Point, Mr. Touchstone was a Vice President at Stifel Nicholas & Company from November 2011 to March 2012. Between 2009 and 2011, Mr. Touchstone was Vice President/Senior Investment Strategist with Stone & Youngberg. From 2007 to 2009, Mr. Touchstone was a Vice President/Portfolio Manager at First Bank. Mr. Touchstone began his career in the financial industry in 2002 at Schroeder Capital Management, LLC, where he served as a Securities Analyst/Director of Operations. Mr. Touchstone was at Schroeder Capital Management until he joined First Bank. Mr. Touchstone received a B.A. in Business with a minor in Computer Science in 2000 from Western State College of Colorado. Mr. Touchstone holds FINRA Series 7 and 63 securities licenses and is a Registered Representative of Uhlmann Price Securities, LLC as described in Item 10 below. Tim McDowell joined Fort Point as a Managing Member in December 2017 as a result of the merger of Fort Point and Cypress Point Capital Management, LLC (“Cypress Point”). Prior to Fort Point, Mr. McDowell was Managing Member of Cypress Point from 2013 to 2017. Prior to joining Cypress Point, Mr. McDowell held consulting roles at Aperture Ventures LLC and Crestline Investors, Inc. where he evaluated and completed hedge fund secondary investments. Previously, Mr. McDowell was an analyst at Group G Capital Partners, LLC, a hedge fund focused on distressed debt and special situation investments. Before Group G, Mr. McDowell was an associate at Tailwind Capital, a private equity fund focused on middle market transactions across 4  growth sectors of the economy. Mr. McDowell began his career as a financial analyst at Bowles Hollowell Conner & Co., an investment bank focused on mergers and acquisitions. Mr. McDowell received an MBA from Harvard Business School and a B.S. in Business Administration, with highest distinction, from the University of North Carolina at Chapel Hill. Mr. McDowell holds FINRA Series 7 and 66 securities licenses and is a Registered Representative of Uhlmann Price Securities, LLC as described in Item 10 below. Robin Brinckerhoff joined Fort Point as a Managing Director in July 2017 and became a Member in 2022. Prior to joining Fort Point, Mr. Brinckerhoff was a Vice President and Wealth Advisor at Wells Fargo Private Bank. Mr. Brinckerhoff received a B.A. in Art History from the University of Maryland and completed the Personal Financial Planning Program at the University of California, Berkeley. Mr. Brinckerhoff holds FINRA Series 7 and 63 securities licenses and is a Registered Representative of Uhlmann Price Securities, LLC as described in Item 10 below. Roy Haya joined Fort Point as a Managing Director and Head of Derivative Solutions in April 2019 and became a Member in 2023. Prior to joining Fort Point Mr. Haya was an Investment Advisor Representative of Twenty-First Tailored Solutions, Inc. and Managing Director/Head Derivatives Trader of Twenty-First Securities Corp. Prior to working with Twenty First, Mr. Haya was a Limited Partner Derivatives Trader for Spyglass Derivatives Fund. Mr. Haya received a BBA in Banking and Finance from Hofstra University and an MBA in Financial Engineering from New York University. Mr. Haya holds FINRA Series 4, 7, 24 and 63 securities licenses and is a Registered Representative of Uhlmann Price Securities, LLC as described in Item 10 below. Chad DeMartini joined Fort Point as a Managing Director in November 2022 and became a Member in 2025. Prior to joining Fort Point, Mr. DeMartini served as a Vice President and Wealth Advisor at Goldman Sachs Private Bank. Earlier in his career, he was a Senior Vice President in Equity Capital Markets at Friedman, Billings, Ramsey & Co. Mr. DeMartini received a B.A. in International Business Policy, with a minor in Philosophy, from Franklin & Marshall College. He holds FINRA Series 7 and Series 63 securities licenses and is a Registered Representative of Uhlmann Price Securities, LLC, as described in Item 10 below. Advisory Services Fort Point offers investment management services to family offices and high net worth individuals, referred to herein as “Clients.” Additionally, Fort Point is the Program Manager and provides investment management services to Investment Partners, LLC, a series of private funds. Each series herein referred to as a “Fort Point Private Investment” or “FPPI ” Fund. Fort Point acts 5  in a fiduciary role for its Clients and FPPI Funds and generally offers its investment services on a fully discretionary basis as described below. Fort Point provides financial planning and investment management and supervisory services regarding securities to Clients with individually managed accounts. At times, we may select other investment advisers to manage all or a portion of a Client’s account. We generally recommend a portion of Client assets be invested in private placements offered through the FPPI Funds or, in some cases, through non-affiliated private fund managers. With the exception of investments in FPPI Funds or other private funds, account supervision is typically on a discretionary basis with Clients granting Fort Point a limited power of attorney to trade Client securities. Client securities are held by qualified custodians, or in the case of private placements, are subject to an annual audit by an outside certified public accountant. Account supervision by us is guided by the stated objectives of the Client, taking into consideration the Client’s risk profile and financial status. Clients may impose restrictions on investing in certain securities or types of securities. Each Client’s financial goals and needs are assessed and the investment advice given is tailored towards those goals. We view ourselves as risk managers with a threefold approach to our management style including global diversification, active risk management and cost reduction through negotiating better pricing with our custodians, sub-advisors and third-party managers. In short, we seek to tightly control the controllable: risk, tax, cost and liquidity. As mentioned above, Fort Point is also the Program Manager and Managing Member of Investment Partners, LLC (“IP”), an alternative investment program. IP provides investors with individualized allocations to a variety of underlying managers (each an “Underlying Manager”) and their associated funds (each an “Underlying Fund”) which seek to provide exposures to a variety of asset classes including private credit, opportunistic credit, private equity (buyouts, venture capital, secondaries), and real estate. IP is structured as a Delaware multi-series LLC which seeks to provide liability protection across its multiple series while also promoting a more efficient cost structure by sharing Fund-level operating expenses and infrastructure across multiple private funds thus reducing the time and cost of launching and maintaining additional funds. As of January 1, 2026, IP was made up of the funds detailed below. • Alternative Yield Funds (“AYF,” “AYF II,” “AYF III”, and “AYF IV”): Fund-of-hedge funds designed to provide investors with exposure to various investment strategies with current income features that have minimal correlation to traditional fixed income securities. 6  • Growth Equity Opportunities Funds (“GEO I” and “GEO II”): Funds investing in a broad range of private equity strategies such as buyouts, growth equity, venture capital and secondaries which make investments into private companies across the business lifecycle. Each underlying investment in GEO I or GEO II is held in a segregated side pocket which investors must opt in to participate. As a result, each investor has unique exposure to the investments in each fund depending on his/her decision to opt in to an investment. • Real Estate Opportunities Funds (“REO I” and “REO II”): real estate-oriented funds investing in a broad range of real estate investments, either direct ownership of assets or private funds that make investments across the real estate spectrum. Each underlying investment in REO I or REO II is held in a segregated side pocket which investors must opt in to participate. As a result, each investor has unique exposure to the investments in each fund depending on his/her decision to opt in to an investment. • Credit Opportunities Funds (“COF I” and “COF II”): opportunistic credit fund-of-funds investing in a broad range of opportunistic credit investments through unaffiliated private funds. Fort Point also acts as a sub-advisor or co-advisor for Clients of other registered investment advisors. In some cases, in our capacity as sub-advisor or co-advisor, rather than providing investment management services, we implement various hedging and monetization strategies as recommended by the Client’s primary investment advisor. Investment Management Service to Retirement Investors When providing investment advice to ERISA-covered retirement plans, plan participants, or IRA owners, Fort Point may be considered a fiduciary under the Employee Retirement Income Security Act of 1974 (“ERISA”) or the Internal Revenue Code, depending on the nature of the advice and the circumstances of the relationship. When acting in a fiduciary capacity under ERISA or the Internal Revenue Code, Fort Point is required to act in the retirement investor’s best interest and to avoid misleading statements regarding fees, conflicts of interest, and investments. Fort Point maintains policies and procedures designed to address conflicts of interest and to help ensure that advice provided to retirement investors is in their best interest. Assets under Management As of December 31, 2025, Fort Point had approximately $2.3 billion under management on a discretionary basis and approximately $593 million on a non-discretionary basis for a total of $2.9 billion in regulatory assets under management. 7  Item 5 – Fees and Compensation Individually Managed Accounts Management Fees Below is our typical fee structure for individual Clients, though fees may vary by Client. Assets Under Advisement Fee $1,000,000 First $9,000,000 Next $40,000,000 Next Next $50,000,000 Over $ 100,000,000 1.25% 0.90% 0.60% 0.40% Negotiable We believe that our fees are competitive with those fees charged by other investment advisers for comparable services; however, comparable services may be available from other sources for lower fees than those that we charge. The fees charged by us are separate from and in addition to those fees which may be charged by a Client’s sub-adviser(s) or any private placement(s) in which Client assets may be invested. Fees are calculated on the gross asset value of the Client accounts as of the last day of the preceding calendar quarter, based on trade date values, or in the case of a private placement as of the last reported value. Fees are payable quarterly in advance. The specific manner in which fees are charged by us is established in a Client’s written agreement. Clients may elect to be billed for fees or to authorize us to directly debit fees from Client accounts. Accounts initiated during a calendar quarter will be charged a prorated fee. Upon termination of any account, any earned, unpaid fees will be due and payable, and any prepaid fees will not be refunded. In certain cases, Clients may request that we purchase or maintain pre-existing or other securities positions in custodial accounts maintained with us, or with limited partnerships and other private placements, that are not consistent with our investment strategy. In such cases, we typically agree not to charge a fee on such assets, but with the specific understanding that these are non-supervised assets for which the Client is responsible for determining the suitability of maintaining such a position. We will not sell such securities without specific instructions from the Client. Expenses Our fees on individually managed accounts are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the Client. These additional charges may include custodial fees, wire transfer and electronic fund transfer fees, and other transaction-related costs. 8  Mutual funds and exchange traded funds charge internal management fees, which are disclosed in a fund’s prospectus. Private placements and other pooled investment vehicles charge internal fees and expenses which are disclosed in the applicable offering memorandum or program documents. In addition, Clients may incur fees charged by third-party managers or sub-advisers engaged to manage all or a portion of a Client’s account. Item 12 further describes the factors that Fort Point considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). Fort Point Private Investment Funds Management and Incentive Fee For FPPI Funds, Fort Point may be compensated by a fund-level fee overlay under which Fort Point charges management and/or incentive fees, in addition to fees charged by the Underlying Managers. For investors who are a Fort Point Client, management fees are waived and certain Clients may receive discounted incentive fees. In addition, while an investor remains a Fort Point Client, Fort Point will charge its advisory fee on any assets invested in the FPPI Funds. The specific management and incentive fee terms for each FPPI Fund are described in the applicable offering documents. AYF, AYF II, AYF III, and AYF IV: Fort Point may receive an annual management fee of up to 1.0%, paid monthly in advance, based on the value of each investor's capital account as of the first day of the month. In addition, Fort Point may receive an incentive allocation of up to 10.0%. GEO I and GEO II: Fort Point does not receive any management fees and may receive an incentive fee of 10% for Class A interests, 10% for Class B interests, and 5% for Class C interests. Incentive fees are calculated separately for each underlying investment and realized upon the liquidation or distribution of the underlying investment and only paid after the return of all invested capital. REO I and REO II: Fort Point does not receive any management fees and may receive an incentive fee of 10% for Class A interests, 10% for Class B interests, and 5% for Class C interests. Incentive fees are calculated separately for each underlying investment and realized upon the liquidation or distribution of the underlying investment and only paid after the return of all invested capital. COF I and COF II: Fort Point receives an incentive fee of 5% on Class C and Class F interests. 9  if any; interest expenses; Expenses Each FPPI Fund is responsible for start-up expenses (amortized over 60 months) and Fund-level operational expenses including: expenses of the continuous offering of its interests, including the cost of producing and distributing its offering documents; any due diligence and other investment research expenses incurred on behalf of an FPPI Fund; filing fees and expenses; accounting, audit, and tax preparation expenses; computer software, licensing, programming, and operating expenses; data processing costs; legal fees and expenses; consultant fees; tax, litigation, insurance indemnification, and other extraordinary expenses, expenses, custody fees, bank charges, and other investment and operating expenses. Additionally, unless otherwise noted, the fees described above are solely fees charged by Fort Point and are not inclusive of fees and expenses incurred by Underlying Managers. Investors may not be made aware of the specifics of these expenses directly, but performance information presented will be net of all such fees and expenses. Item 6 – Performance-Based Fees and Side-By-Side Management Fort Point does not charge performance fees on individually managed accounts. For Point does receive performance-based fees or incentive allocations on some of the FPPI Funds as described above in Item 5 – Fees and Compensation. Performance-based fee arrangements create an incentive for us to recommend investments which may be riskier or more speculative than those which would be recommended under a different fee arrangement. Fort Point has implemented procedures designed to ensure that all Clients are treated fairly and equally, and to prevent this conflict from influencing the allocation of investment opportunities among Clients. Item 7 – Types of Clients We typically provide portfolio supervision services to high-net-worth individuals and family offices. Generally, account minimums are $1,000,000, although this minimum may be waived by us. Fort Point also provides investment management services to the FPPI Funds. Generally, investors in the FPPI Funds are also Fort Point Clients. However, non-Fort Point Client investors in an FPPI Fund must invest a minimum of $250,000 unless waived by us. Each investor must be an “accredited investor” as that term is defined in Rule 501(a) of Regulation D under the Securities Act of 1933, as amended; a “qualified client”, as that term is defined in Rule 205-3(d)(1) of the Investment Advisers Act of 1940; and/or a “qualified purchaser”, as applicable, as that term is 10  defined in Section 2(a)(51) of the U.S. Investment Company Act of 1940, as amended; and meet other criteria as specified in the offering documents of the FPPI Funds. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Investment Strategies We strive to provide each Client with a sustainable investment experience by pursuing a consistent strategy tailored to each Client’s risk tolerance as we build his/her portfolio. We take into consideration the following factors when building a Client’s portfolio: • Client’s risk tolerance • Client’s time horizon • Client’s liquidity needs • Market metrics which include volatility and correlation Utilizing Tax Alpha Another strategy that we employ is tax-loss harvesting which can be a predictable and reliable source of “alpha” in portfolio management. We pursue this strategy aggressively and systematically and it is best executed in a portfolio employing an indexed approach to asset class exposure, where fungible replacement instruments are available to limit tracking error. We find that the rapid growth in the exchange traded funds (“ETFs”) market has provided us with a deep taxonomy of ETFs available as swap candidates when a tax-loss harvesting opportunity presents itself. In some cases, we will also recommend Clients open a separately managed account managed by a third party with a specific strategy of tax loss harvesting. Risk of Loss Investing in securities involves risk of loss that Clients should be prepared to bear. There can be no assurance that Fort Point will achieve a client’s investment objectives or that any investment strategy will be successful. Clients may lose some or all of their invested capital. Investment strategies are subject to change based on market conditions and client circumstances and may not perform as intended in all market environments. Market and Economic Risk. The value of securities and other investments may fluctuate due to changes in market conditions, interest rates, inflation, economic trends, geopolitical events, and other factors. These changes may result in substantial volatility and potential losses. Asset Allocation Risk. Fort Point’s investment approach is based on asset allocation decisions. If the selected asset allocation or investment strategy does not perform as expected, a Client’s portfolio may underperform or experience losses. Exchange-Traded Funds and Mutual Funds. Investments in ETFs and mutual funds are subject to market risk and the performance of the underlying securities. ETFs may trade at a premium or 11  discount to their net asset value and may experience liquidity constraints or wider bid-ask spreads during periods of market stress. Certain funds may employ leverage or invest in less liquid securities, which can increase volatility and risk of loss. Tax-Aware Strategies. Tax-aware investment strategies, including tax-loss harvesting, are intended to improve after-tax outcomes but may not be successful in all market environments. These strategies may result in increased transaction costs, tracking error relative to benchmarks, or missed investment opportunities. The benefits of such strategies depend on each Client’s individual tax circumstances. In addition, tax laws and regulations are subject to change, and such changes may impact the effectiveness of these strategies. Third-Party Manager Risk. When Fort Point recommends or allocates assets to third-party managers or investment vehicles, the Client is subject to the risks associated with those managers and strategies. These risks include the potential for poor investment performance, changes in investment strategy or personnel, lack of transparency, and operational risks. Fort Point has limited ability to control the day-to-day investment decisions of such third-party managers, and there can be no assurance that they will achieve their stated objectives. Clients also bear additional fees and expenses associated with these investments including. Options Risk. Options strategies involve additional risks beyond those associated with traditional investments. When used for hedging concentrated positions, options may reduce potential losses but can also limit potential gains. Option strategies may involve costs, complexity, and the risk that the strategy does not perform as intended. Leverage and Margin Risk. The use of margin or leverage can amplify both gains and losses. Clients using margin may be required to deposit additional funds or liquidate positions at unfavorable times to meet margin calls, which can result in significant losses. Private Investment and Illiquidity Risk. Investments in private funds or other illiquid investment vehicles, whether accessed directly or through pooled vehicles such as fund-of-funds structures, involve additional risks, including limited liquidity, lack of transparency, reliance on the investment manager, and the potential for loss of capital. Such investments may have limited withdrawal rights and may be subject to extended lock-up periods or other restrictions. Valuations for such investments may be uncertain and based on estimates provided by the investment sponsor, which may not reflect actual realizable value. Risks Associated with Private Equity and Real Estate Investments. Investments in private equity and real estate-related assets involve additional risks beyond those associated with traditional liquid securities. 12  Private equity investments typically involve long holding periods, limited liquidity, and reliance on the management of the underlying portfolio companies. These investments may be highly illiquid, may not produce current income, and may be subject to significant uncertainty regarding valuation and ultimate realization of value. Real estate-related investments are subject to risks associated with the ownership and operation of real property, including changes in economic conditions, interest rates, property values, and local market conditions. These investments may also be affected by factors such as tenant performance, financing availability, regulatory changes, environmental issues, and other property-specific risks. Both private equity and real estate investments may involve the use of leverage, which can increase volatility and the risk of loss. These investments are generally suitable only for investors who can bear the risks associated with illiquidity and potential loss of capital. Additional Risks Associated with Fund-of-Funds Structures. In cases where Fort Point sponsors or recommends investments in pooled investment vehicles that allocate assets to multiple underlying funds or managers (“fund of funds”), Clients are subject to additional risks, including: Layered Fees and Expenses. Investors generally bear both the fees and expenses of the fund of funds as well as those of the underlying funds or managers, which may result in higher overall costs. Underlying Manager Risk. The performance of a fund of funds depends on the investment performance of the underlying managers. Fort Point has limited ability to control the investment decisions of these managers, and there can be no assurance that they will achieve their investment objectives. Allocation Risk. The success of a fund of funds depends on Fort Point’s ability to select and allocate assets among underlying managers and strategies. Poor selection or allocation decisions may result in underperformance or losses. Liquidity Risk. A fund of funds’ ability to meet redemption requests may be limited by the liquidity of the underlying investments. Underlying funds may impose restrictions such as lock-ups, gates, or suspension of withdrawals, which could delay or limit a client’s ability to access capital. Valuation Risk. Valuations are typically based on information provided by underlying managers, which may be delayed or based on estimates and may not reflect actual realizable value. 13  General Risks. Changes in investor sentiment, technological developments in trading markets, and market disruptions may lead to increased volatility and reduced liquidity. During periods of market stress, it may be difficult or impossible to sell certain investments at desired prices. Item 9 – Disciplinary Information Neither Fort Point nor any of Fort Point’s management persons has had any legal or disciplinary events that would be material to a client’s evaluation of Fort Point or the integrity of Fort Point’s management. Item 10 – Other Financial Industry Activities and Affiliations interest Ralph Drybrough, Paul Touchstone, Tim McDowell, Robin Brinckerhoff, Roy Haya, Chad DeMartini and certain supervised persons are also registered representatives of Uhlmann Price Securities, LLC (“Uhlmann Price”), an SEC-registered and FINRA member broker-dealer unaffiliated with Fort Point. From time to time, Fort Point may recommend that a Client execute certain transactions through Uhlmann Price. In those instances, a portion of the transaction fee paid by Clients to Uhlmann Price, for transactions executed by supervised persons of Fort Point in their capacity as registered representatives of Uhlmann Price, will be received by those supervised persons. Due to this arrangement, Fort Point has a conflict of in recommending Clients use the services of Uhlmann Price. Notwithstanding this conflict of interest, Fort Point will only recommend executing transactions through Uhlmann Price when it believes the transaction to be in the best interest of a Client. Supervised persons of Fort Point, in their capacity as registered representatives of Uhlmann Price, do not have the authority to proceed with any transactions without the consent of the Client. Activities conducted by supervised persons in their capacity as registered representatives of Uhlmann Price are separate from and not part of Fort Point’s advisory services. Refer to Item 12 below for more information regarding Fort Point’s selection of broker-dealers. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Fort Point has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its Clients. The Code of Ethics includes provisions relating to the confidentiality of Client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. 14  We anticipate that, in appropriate circumstances, consistent with Clients’ investment objectives, Fort Point will cause accounts over which we have management authority to effect, and will recommend to investment advisory Clients or prospective clients, the purchase or sale of securities in which we, our affiliates and/or Clients, directly or indirectly, have a position of interest. Our partners, employees and persons associated with us are required to follow our Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of Fort Point and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for Fort Point’s Clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of Fort Point will not interfere with (i) making decisions in the best interest of advisory Clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, transactions in certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of our Clients. Employees are required to report personal securities holdings annually and securities transactions quarterly. Certain affiliated accounts may trade in the same securities with Client accounts on an aggregated basis when consistent with Fort Point’s obligation of best execution. In such circumstances, the affiliated and Client accounts will share commission costs equally and receive securities at a total average price. Fort Point will retain records of the trade order (specifying each participating account) and its allocation, which will be completed prior to the entry of the aggregated order. Completed orders will be allocated as specified in the initial trade order. Partially filled orders will be allocated on a pro rata basis. Any exceptions will be explained on the Order. Our Clients or prospective clients may request a copy of the firm’s Code of Ethics by contacting Fort Point using the contact information on the cover page of this Brochure. Item 12 – Brokerage Practices Fort Point generally recommends Clients establish brokerage accounts with either Charles Schwab & Co, Inc (“Schwab,”) or Fidelity Brokerage Services, LLC (“Fidelity”), both unaffiliated SEC-registered broker-dealers, members FINRA/SIPC. However, in some cases, if Clients have a specific operational need or require a certain product or subadvisor, we may also recommend they open an account with RBC Capital Markets, LLC (“RBC”), an unaffiliated SEC-registered broker-dealer, member FINRA/SIPC. In selecting an account custodian/broker-dealer, Fort Point considers a number of factors, including: 15  • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts (wire transfers, check requests, bill payment, etc.) • Breadth of available investment products (stocks, bonds, mutual funds, exchange-traded funds (“ETFs”), etc.) • Quality of services • Competitiveness of the price of those services (commission rates, margin interest rates, other fees, etc.) and willingness to negotiate the prices • Reputation, financial strength, security, and stability • Prior service to us and our Clients • Availability of other products and services that benefit us, as discussed Brokerage and trading costs. Custodians generally do not charge Clients separately for custody services but are compensated by charging commissions or other fees on trades that they execute or that settle into the Client’s account. Certain trades (for example, many U.S. exchange- listed equities and ETFs) may not incur commissions or transaction fees. Custodians are also compensated by earning interest on the uninvested cash in Clients’ accounts. We are not required to select the broker or dealer that charges the lowest transaction cost, even if that broker provides execution quality comparable to other brokers or dealers. Although we are not required to execute all trades through Schwab, Fidelity or RBC, we have determined that having them execute most trades is consistent with our duty to seek “best execution” of trades. Best execution means the most favorable terms for a transaction based on all relevant factors, including those listed above. By using another broker or dealer, one may pay lower transaction costs. Custodial Services and Benefits The broker-dealers and custodians we recommend, including Schwab, Fidelity, and RBC, provide us and our Clients with access to institutional brokerage services, including trading, custody, reporting, and related services, many of which are not typically available to retail investors. These custodians also make available various support services. Some of these services assist us in managing and administering Client accounts, while others help us operate and grow our business. These services may include: • Access to Client account data (such as trade confirmations and account statements) • Trade execution and allocation of aggregated orders • Pricing and market data • Facilitation of fee billing from client accounts • Back-office support, recordkeeping, and client reporting 16  Investment research (their own and third-party) Custodians may also provide other services intended to support our business operations, including: • • Technology and software tools • Educational events and practice management resources • Access to third-party service providers Some of these services may not directly benefit Client accounts. These services are generally provided at no additional cost to us, and we do not have to produce or purchase them independently. The availability of these services from custodians creates a conflict of interest, as it provides an incentive for us to recommend those custodians. However, we believe our selection of custodians is based primarily on the overall quality of services, execution capabilities, and cost, and is in the best interest of our Clients. As mentioned in Item 10 - Other Financial Industry Activities and Affiliations, certain supervised persons of Fort Point are also registered representatives of Uhlmann Price, an SEC-registered and FINRA member broker-dealer unaffiliated with Fort Point. From time to time, Fort Point may recommend that Clients execute certain transactions through Uhlmann Price. In those instances, a portion of the transaction fee paid by Clients to Uhlmann Price for transactions executed by supervised persons of Fort Point in their capacity as registered representatives of Uhlmann Price will be received by the supervised person. Due to this arrangement, Fort Point has a conflict of interest in recommending Clients use the services of Uhlmann Price. Notwithstanding this conflict of interest, Fort Point will only recommend executing transactions through Uhlmann Price when it believes the transaction to be in the best interest of a Client. Principal and Cross Transactions It is policy that the Firm will not effect any principal or cross securities transactions for Client accounts. Item 13 – Review of Accounts Periodic Client Account Reviews and Meetings Fort Point will perform Client account reviews on at least a quarterly basis, or more frequently as a result of a dramatic change in economic or market conditions or changes in a Client’s personal or financial circumstances. Reviews are conducted by the Client’s primary Advisor at Fort Point. On at least an annual basis, Fort Point offers a meeting with each of its Clients. At that time, the Client is also asked to update changes in their risk profile, balance sheet, income statement, tax situation, and any investment objectives, as applicable. Fort Point reviews with the Client the 17  performance of the Client’s account(s) and discusses any changes to Client restrictions or portfolio rebalancing. Client Reports Fort Point provides Clients with access to an online portal where they can access information regarding holdings, transactions and portfolio performance on demand. Item 14 – Client Referrals and Other Compensation Fort Point has entered into arrangements with individuals or entities (“Promoters”) who provide endorsements or testimonials or refer Clients for investment advisory services. In return, Fort Point agrees to compensate the Promoter for the endorsement, testimonial, or referral. Compensation to the Promoter is based upon a percentage of Fort Point’s investment advisory fee. TD Ameritrade AdvisorDirect Fort Point previously participated in TD Ameritrade’s AdvisorDirect Program (the “referral program”). The referral program was established as a means for TD Ameritrade to refer its brokerage customers and other investors seeking fee-based personal investment management services or financial planning services to independent investment advisors. As a result of past participation in the referral program, Fort Point received Client referrals from TD Ameritrade. In 2023 Schwab completed its acquisition of TD Ameritrade. Although Fort Point is no longer participating in the referral program, it is obligated to pay Schwab an on-going fee for each successful Client relationship established because of past referrals under the AdvisorDirect Program. This fee is usually a percentage (not to exceed 25%) of the advisory fee that the Client pays to Fort Point. No Client referred to Fort Point through the referral program is charged fees or costs higher than Fort Point’s standard fee offered to its other Clients. Item 15 – Custody Client assets are generally held by a qualified custodian (e.g., Schwab, Fidelity, RBC or another custodian of the Client’s choice). Clients receive monthly or quarterly statements from the qualified custodian that holds and maintains the Client’s investment assets. We urge Clients to carefully review such statements and compare such official custodial records to any reports that we may provide to you. Our reports may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Standing Letters of Authorization (“SLOAs”) Fort Point is deemed to have custody of Client accounts due to SLOAs certain Clients have on file with the custodian which allow Fort Point to transfer funds or securities to a third party 18  designated in the SLOA. In some cases, the SLOA authorizes Fort Point to transfer funds to an FPPI Fund in order to meet the Clients capital commitments. In order to comply with the SEC Custody Rule 206(4)-2 Fort Point has engaged an independent public accountant to conduct an annual surprise examination of those assets. Investment Partners, LLC Fort Point, as Managing Member of Investment Partners, LLC, is deemed to have custody of assets maintained by the FPPI Funds. Fort Point complies with the Custody rule for these assets by meeting the conditions of the pooled vehicle annual audit provision. All FPPI Fund investors will receive audited financial statements of the FPPI Fund within 180 days of the end of the fiscal year. Item 16 – Investment Discretion Our Clients execute investment advisory agreements with Fort Point, which typically give Fort Point complete discretion over the selection and amount of securities to be bought or sold, without obtaining prior specific Client consent (except as noted in the above in Item 4 regarding private placements and non-supervised assets). In cases where Fort Point is engaged solely to supervise an options overlay strategy, Clients or their primary Advisor will maintain sole discretion over trading any underlying securities. Because Fort Point supervises more than one account, there may be conflicting demands on Fort Point’s time and potential conflicts regarding the allocation of investment opportunities. Fort Point will attempt to resolve all such conflicts in a manner that is generally fair to all of its Clients. However, Fort Point may take action with respect to any of its Clients which differs in timing or nature from the action taken with respect to another Client. Advice offered to one Client may differ from that offered to another for a variety of reasons. It is Fort Point’s policy, to the extent practical, to allocate investment opportunities over a period of time on a fair and equitable basis among its Clients. However, we use discretion to determine whether an investment is practical or desirable for any particular client. Fort Point may acquire securities for one Client that are not deemed appropriate for another. Fort Point takes into account Clients’ investment objectives when making investment decisions. Item 17 – Voting Client Securities The exercise of proxy voting authority in respect to Client securities is the responsibility of our Clients. As part of their agreements with custodians, Clients will direct custodians to send all 19  necessary proxy voting materials and notices directly to the Clients from the custodians holding such securities. Fort Point believes that Clients, after reviewing such proxy materials, can then decide and vote issues in their own best interest. Proxy Voting Policies for Private Funds Generally, FPPI Funds are Funds of Funds and Underlying Managers are responsible for voting with regard to securities they manage, as applicable. When the above is not applicable, Fort Point has adopted and implemented policies and procedures that we believe are reasonably designed to ensure that proxies are voted in the best interest of our FPPI Funds, in accordance with SEC Rule 206(4)-6 under the Investment Advisers Act of 1940. In situations where there may be a conflict of interest between Fort Point’s general proxy voting policy and the interests of the FPPI Fund, we will cast the vote in accordance with the FPPI Fund’s interests. Such conflicts will be reviewed by the CCO. Fort Point’s authority to vote the proxies of FPPI Funds is established in our Program Documents or comparable documents and our proxy voting guidelines have been tailored to reflect these specific contractual obligations. Investors are not permitted to direct Fort Point how to vote these proxies. In accordance with SEC Rule 206(4)-6, Fort Point will provide a copy of our proxy voting policy to any investor in a FPPI Fund, or any other Client or prospective client, upon request. Clients or investors may request a copy of our proxy voting policy, by contacting Fort Point using the contact information on the cover page of this brochure. Item 18 – Financial Information Fort Point has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to Clients. Additionally, Fort Point has not been the subject of a bankruptcy petition. 20