FPL CAPITAL MANAGEMENT, LLC

FPL Capital Management, LLC 3525 North Causeway Blvd. Suite 633 Metairie, LA 70002 (800) 835-1969 https://fplcm.com/ January 2026 This Brochure provides information about the qualifications and business practices of FPL Capital Management, LLC (“FPL Capital Management”). If you have any questions about the contents of this Brochure, please contact us at info@fplcm.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. FPL Capital Management, LLC is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about FPL Capital Management, LLC also is available on the SEC’s website at www.adviserinfo.sec.gov. i  Item 2 - Material Changes Since our last annual amendment filing in January 2025, there have been no material changes to this brochure. We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Virajith Wijeweera, Chief Compliance Officer and Director of Trading and Operations, at (888) 290-1969 or Info@fplcm.com. Our Brochure is also available on our web site https://fplcm.com/, also free of charge. Additional information about FPL Capital Management is also available via the SEC’s web site www.adviserinfo.sec.gov. The SEC’s web site also provides information about any persons affiliated with FPL Capital Management who are registered, or are required to be registered, as investment adviser representatives of FPL Capital Management. ii  Item 3 -Table of Contents Item 2 - Material Changes ............................................................................................................................. ii Item 3 -Table of Contents ............................................................................................................................. iii Item 4 - Advisory Business ............................................................................................................................. 4 Item 5 - Fees and Compensation ................................................................................................................... 7 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 ................................................................................................................ 11 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 11 Item 11 – Code of Ethics.............................................................................................................................. 12 Item 12 – Brokerage Practices ..................................................................................................................... 13 Item 13 – Review of Accounts ..................................................................................................................... 15 Item 14 – Client Referrals and Other Compensation ................................................................................... 15 Item 15 – Custody ....................................................................................................................................... 15 Item 16 – Investment Discretion ................................................................................................................. 17 Item 17 – Voting Client Securities ................................................................................................................ 17 Item 18 – Financial Information .................................................................................................................. 18 Item 1: Form ADV 2B: Michael George Cover Page ...................................................................................... 19 Item 1: Form ADV 2B: Virajith Wijeweera Cover Page .................................................................................. 22 Item 1: Form ADV 2B: Amanda Harrell Cover Page ....................................................................................... 24 iii  Item 4 - Advisory Business Michael D. George is the principal owner of FPL Capital Management, LLC. Michael George serves as the president and the senior portfolio manager. Michael George established FPL Capital Management in 2000. Michael George has more than 20 years of experience working in the investment advisory services industry. FPL Capital Management provides investment advisory services to individual clients, trusts, retirement plans, and business entities. FPL Capital Management, LLC was established in 2000 in the State of Louisiana. We are a fee-only firm. As of December 31st, 2025, we manage approximately $789,326,121 in discretionary assets and $293,339,871 in non-discretionary assets for a total of $1,082,665,992 in assets under management. FPL Capital Management is located in Metairie, LA. As a fiduciary, we seek to avoid conflicts of interest which may exist between our firm and clients. Some unavoidable conflicts may arise. In these rare cases, we seek to keep our clients’ best interest first, at all times. Wealth & Asset Management Services We offer our clients globally diversified customized and model portfolios. Model portfolios were created utilizing passively and actively managed index funds. We use these model portfolios as the base if a client would like to customize his or her portfolio. Clients may impose certain restrictions on investing in certain securities type or types of securities. FPL Capital Management reserves the right to accept or not to accept these restrictions. If accepting these restrictions hinders FPL Capital Management from achieving client’s investment objectives, FPL Capital Management also reserves the right to terminate the client/advisor relationship. Financial Planning & Consulting Services FPL Capital Management, LLC includes financial planning and consulting services as part of the discretionary Wealth & Asset Management services. However, non-discretionary Asset Management clients may also access our financial planning and consulting services in a separate agreement for an additional fee. Fees charged for financial planning or consulting services are based on the amount of planning or consulting time involved. It will either be an hourly rate or a quoted flat fee per specific project. ADV Part 2A – Firm Brochure Page 4 FPL Capital Management, LLC  The arrangement is selected and approved by the planning or consulting client before engagement. Our financial planning and consulting services cover the following areas:  Investment Planning  Retirement Planning  Risk Management (Insurance) Planning  Tax Planning  Estate Planning Periodically, we will retain or have the client retain outside specialists to assist in completing the project. This includes specialists such as, but not limited to, Certified Public Accountants and Attorneys. The client will either pay us or pay the specialist directly for the services rendered. The client has the option of selecting the payment method they prefer. To better serve our clients, we have established custodial relationships with discount brokers, such as Charles Schwab & Co., Inc. (“Schwab”), and Fidelity Institutional Wealth Services (“Fidelity”). FPL Capital Management does not have custody of the client assets at any point. To best complement the services we recommend and/or offer, we have built a professional network of estate and trust attorneys, certified public accountants, and insurance agents who offer no-load products. Keeping these services separate ensures that there will be no conflict of interest with respect to the services these professionals offer. Furthermore, FPL Capital Management also provides investment advisory services to clients as described in this brochure. As such, a potential conflict of interest exists between the adviser’s interests and the interests of the client. In any event, the client is under no obligation to act upon the investment adviser’s recommendation, and if the client elects to act on any of the recommendations, the client is under no obligation to affect the transactions through the investment adviser. Pension Consulting Services We mainly utilize our passive asset allocation models to provide investment advisory services to company retirement plans. Our asset allocation models were created utilizing carefully pre- selected asset classes to maximize returns while maintaining an acceptable level of risk. Asset classes and allocations used are backed by several years of back-tested research. Participants selecting asset allocation models may not achieve returns identical to that of Model Portfolios due ADV Part 2A – Firm Brochure Page 5 FPL Capital Management, LLC  to timing of contributions and distributions, advisory fees, timing of the deduction of the advisory fee, market fluctuations, trading costs, custodian fees, and frequency and precision of rebalancing. To keep participants informed of their portfolio holdings and activity, Recordkeepers provide periodic statements. In addition to the Recordkeeper statements, the plan sponsors will also receive a quarterly monitoring report from us, which includes a summary of funds selected and the performance of the funds in the plan. We recognize the importance of an informed and a knowledgeable participant. Once the plan is placed under our advisory, we will commence the participant enrollment process. We will schedule an on-site or a virtual meeting. Enrollment process will educate plan participants on our role in the plan, provide an overview of the capital markets, and elaborate how our asset allocation models tie into the Modern Portfolio Theory. Also, all participants will receive a Risk Tolerance Questionnaire that they must complete and sign. The questionnaire aids us in assessing the amount of risk the participant is willing to accept. Communication is a very integral part of our services. If participants have questions regarding the plan or their specific account, they will be able to call or e-mail us any time. Third-Party Administrators and Recordkeepers play a significant role in our interaction with the plan sponsor and its participants. We have established relationships several Third-Party Administrators and Recordkeepers that we feel bring the best value to the plan sponsors. Plan Sponsors may select one from our Third-Party Administrators or Recordkeepers. Plan Sponsors may select a TPA they prefer. With our open architecture platform, we can work with any Third- Party Administrator. Tailoring of Advisory Services FPL Capital Management offers individualized investment advice to our Wealth & Asset Management clients. General investment advice will be offered to our Financial Planning & Consulting and Retirement Plan Consulting clients. Wrap Fee Programs FPL Capital Management does not offer nor participate in Wrap Fee Programs. ADV Part 2A – Firm Brochure Page 6 FPL Capital Management, LLC  Item 5 - Fees and Compensation The specific manner in which fees are charged by FPL Capital Management is established in a client’s written agreement with FPL Capital Management. FPL Capital Management will generally bill its fees on a quarterly basis. Clients are billed in arrears at the end of the calendar quarter. Unless otherwise noted in writing, our firm bills on cash. The management fee is deducted from the client specified brokerage account. Management fees shall be prorated. Accounts initiated or terminated during a calendar year will be charged a prorated fee. Upon termination of any client relationship, all earned and unpaid fees will be due and payable. Some fees are negotiable. Lower fees for comparable services may be available from other sources. FPL Capital Management Fees are as follows: 1. For Wealth & Asset Management services, we charge an annual fee that ranges between $5,000 and $15,000. In certain situations, if applicable, we will charge 0.70% of assets under management until annual fee reaches max annual fee set for the level of service selected but not to exceed $15,000. 2. Additionally, our financial planning and consulting service rate is $250 per hour. This fee applies to all non-discretionary Asset Management clients, who are not included in our portfolio management programs. Our financial planning and consulting service is included for no additional fee for all discretionary Wealth & Asset Management clients. 3. We provide our clients with portfolio reporting on accounts we manage. For accounts that we do not manage, we are willing to provide portfolio reporting for an additional fee. This fee is a flat annual fee. The fee will depend on the number of accounts, transactions, and the types of securities. 4. For retirement and pension plans that strictly use self-directed brokerage accounts, an annual fee of $1,000 per Plan Participant. Our minimum annual fee for this type of retirement and pension plan is $3,000. Additionally, we are available for consulting services at an hourly rate of $150. 5. For the services we provide for retirement and pension plans that have participant- directed accounts, we now offer a discounted rate of 0.70% of assets under management for Plans below $357,000 in assets. Once the Plan assets reach $357,000, we charge based on the fee schedule outlined below. We are also available to engage in consulting services at an hourly rate of $150. ADV Part 2A – Firm Brochure Page 7 FPL Capital Management, LLC  We also charge a One-Time Setup fee service based on the initial base fee (see table below) plus $100 per Plan Participant. For one-time set-up flat fee option, the discounted rate of 0.70% for assets under management for Plans below $357,000 in assets does not apply. # Of Participants Annual/Initial Base Fee Fee per Participant 100 – 199 $7,500 $200 (*$100) 200 - 299 $12,500 $200 (*$100) 300 – 500 $17,500 $200 (*$100) 500+ Please Contact Please Contact *One-time setup fee per participant 6. For the services we provide for Defined Benefit Pension Plans and Cash Balance Pension Plans, we charge 70 bps (0.70%) of plan assets with a minimum annual fee of $2,500 and: Plan Assets Value Max Annual Fee Less than $5,000,000 $5,000 $10,000 Greater than $5,000,000 but less than $10,000,000 $15,000 Greater than $10,000,000 but less than $15,000,000 Greater than $15,000,000 $20,000 FPL Capital Management’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which may be incurred by the client. Depending on the security, client can incur transaction fees for trades executed by their chosen custodian via individual transaction charges. These transaction fees are separate from FPL Capital Management’s advisory fees and will be disclosed by the chosen custodian. Schwab does not charge transaction fees for U.S. listed equities and exchange traded funds. Fidelity eliminated transaction fees for U.S. listed equities and exchange traded funds for clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity. Clients who do not meet either criteria will be subject to transaction fees charged by Fidelity for U.S. listed equities and exchange traded funds. ADV Part 2A – Firm Brochure Page 8 FPL Capital Management, LLC  Clients may also incur certain charges imposed by custodians, brokers, third-party investment and other third parties such as fees charged by managers, custodial fees, deferred sales charges, odd- lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Such charges, fees and commissions are exclusive of and in addition to FPL Capital Management’s fee, and FPL Capital Management shall not receive any portion of these commissions, fees, and costs. Item 12 further describes the factors that FPL Capital Management considers in selecting or recommending broker-dealers for client transactions and determining the reasonableness of their compensation (e.g., commissions). FPL Capital Management and its representatives do not sell securities for a commission in advisory accounts. Item 6 – Performance-Based Fees and Side-By-Side Management FPL Capital Management does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). Item 7 – Types of Clients FPL Capital Management provides portfolio management services to individuals, high-net-worth individuals, corporate pension and profit-sharing plans, trusts, and business entities. Our minimum account size is $500,000. The client may aggregate household accounts to satisfy the required minimum. In some instances, we may reduce or waive the minimum for certain clients. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis We take a fundamental approach to analyzing securities. When analyzing mutual funds and ETF’s, FPL Capital Management may use various sources of information, including data provided by YCharts, Morningstar, FastTrack, Fi360, fund company resources, and other online and subscription resources. We also consider the following factors when selecting securities:  Investment objective;  Past performance;  Underlying assets;  Manager tenure;  Market cap; ADV Part 2A – Firm Brochure Page 9 FPL Capital Management, LLC   Dividend payments;  Consecutive annual dividend increases;  Earnings. Investment Strategies FPL Capital Management applies a passive investment strategy when investing client assets. We believe in investing in globally diversified portfolios while maintaining long-term investment horizons. By holding an array of equity asset classes across domestic, international, and emerging markets, investors can reduce the impact of underperformance in a single market or region of the world. Although markets may experience varying levels of return correlation, this diversification can further reduce volatility in a portfolio, which translates into higher compounded returns over time. Portfolio design advice we provide is based on long-term buy and hold investment strategies which incorporate principles of Modern Portfolio Theory. The aim of a well-constructed portfolio is to build a long-term design that reflects individual client’s goals, timeline, and financial situation. Thus, each portfolio design begins with a comprehensive overview of each client’s unique life/financial situation and risk tolerance. Risk of Loss Before investing, each client should carefully consider risks involved in investing in the capital markets. The client should be prepared to experience volatility and fluctuations in portfolio value. Securities investments are not guaranteed, and you may lose value in your investments. There are other principal risks involved when investing. They are as follows: Market Risk – Even a long-term investment approach cannot guarantee a profit. Economic, political, and issuer-specific events will cause the value of securities to rise or fall. Value Investment Risk – Value stocks may perform differently from the market as a whole and following a value-oriented strategy may cause the portfolio to at times underperform equity funds that use other investment strategies. Small Company Risk – Securities of small companies are often less liquid than those of large companies and this could make it difficult to sell a small company security at a desired time or price. As a result, small company stocks may fluctuate relatively more in price. In general, small ADV Part 2A – Firm Brochure Page 10 FPL Capital Management, LLC  capitalization companies are also more vulnerable than larger companies to adverse business or economic developments, and they may have limited resources. Risks of Concentrating in the Real Estate Industry – The value of securities in the real estate industry can be affected by changes in real estate values and rental income, property taxes, interest rates, and tax and regulatory requirements. Investing in REIT’s and REIT-like entities involves certain unique risks in addition to those risks associated with investing in the real estate industry in general. REIT’s and REIT-like entities are dependent upon management skill, may not be diversified, and are subject to heavy cash flow dependency and self-liquidation. REIT’s and REIT-like are also subject to the possibility of failing to qualify for tax free pass-through of income. Foreign Securities and Currencies Risk – Foreign securities prices may decline or fluctuate because of: (a) economic or political actions of foreign governments, and/or (b) less regulated or liquid securities markets. Investors holding these securities are also exposed to foreign currency risk (the possibility that foreign currency will fluctuate in value against the U.S. dollar). Emerging Markets Risk – Numerous emerging markets countries have a history of, and continue to experience serious, and potentially continuing, economic and political problems. Stock markets in many emerging market countries are relatively small, expensive to trade in and risky. Foreigners are often limited in their ability to invest in, and withdraw assets from, these markets. Additional restrictions may be imposed under other conditions. Interest Risk – Fixed income securities are subject to interest rate risk because the prices of fixed income securities tend to move in the opposite direction of interest rates. When interest rate rise, fixed income security prices fall. When interest rates fall, fixed income security prices rise. In general, fixed income securities with longer maturities are more sensitive to these price changes. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of FPL Capital Management or the integrity of FPL Capital’s management. FPL Capital Management has no information applicable to this Item. Item 10 – Other Financial Industry Activities and Affiliations FPL Capital Management does not have any arrangements or relationships with broker-dealers, mutual funds, or other investment advisers that may create any material conflict of interest for FPL Capital Management in providing our clients with investment advice. ADV Part 2A – Firm Brochure Page 11 FPL Capital Management, LLC  Item 11 – Code of Ethics FPL Capital Management 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, a prohibition of rumor mongering, 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. All supervised persons at FPL Capital Management must amended. the Code of Ethics acknowledge the terms of annually, or as FPL Capital Management anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which FPL Capital Management has management authority to effect, and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which FPL Capital Management, its affiliates and/or clients, directly or indirectly, have a position of interest. FPL Capital Management’s employees and persons associated with FPL Capital Management are required to follow FPL Capital Management’s Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of FPL Capital Management and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for FPL Capital Management’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities, and interests of the employees of FPL Capital Management 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 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 FPL Capital Management’s clients. In addition, the Code requires pre-clearance of many transactions, and restricts trading in close proximity to client trading activity. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between FPL Capital Management and its clients. Certain affiliated accounts may trade in the same securities with client accounts on an aggregated basis when consistent with FPL Capital Management'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. FPL Capital Management 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. FPL Capital Management’s clients or prospective clients may request a copy of the firm's Code of Ethics by contacting Virajith Wijeweera. ADV Part 2A – Firm Brochure Page 12 FPL Capital Management, LLC  Item 12 – Brokerage Practices FPL Capital Management recommends that all investment management accounts be maintained at brokers, such as Schwab and/or Fidelity. FPL Capital Management will be granted written discretionary authority with respect to securities purchased, the value of securities to be bought or sold, the broker or dealer to be used, and the commission rates paid. The Investment Management Services Agreement will define any limitations to FPL Capital Management’s discretionary authority. FPL Capital Management will utilize Schwab or Fidelity to execute its client transactions. Factors considered by FPL Capital Management for the selection of a broker-dealer include the broker's ability to provide professional services, competitive commission rates, and other services, which will help FPL Capital Management provide portfolio management services to its clients. Schwab and Fidelity may charge brokerage commissions for executing securities transactions. FPL Capital Management does not receive any compensation for these separate charges. Schwab recently eliminated transaction fees for U.S. listed equities and exchange traded funds. Fidelity recently eliminated transaction fees for U.S. listed equities and exchange traded funds for clients who opt into electronic delivery of statements or maintain at least $1 million in assets at Fidelity. Soft Dollars FPL Capital Management does not receive soft dollars in excess of what is allowed by Section 28(e) of the Securities Exchange Act of 1934. The safe harbor research products and services obtained by FPL Capital Management will generally be used to service all our clients but not necessarily all at any one particular time. Client Brokerage Commissions Neither Schwab nor Fidelity make client brokerage commissions generated by client transactions available for FPL Capital Management’s use. Client Transaction in Return for Soft Dollars FPL Capital Management does not direct client transactions to a particular broker-dealer in return for soft dollar benefits. ADV Part 2A – Firm Brochure Page 13 FPL Capital Management, LLC  Brokerage for Client Referrals FPL Capital Management does not receive brokerage for client referrals. Directed Brokerage In certain instances, clients may seek to limit or restrict our discretionary authority in making the determination of the brokers with whom orders for the purchase or sale of securities are placed for execution, and the commission rates at which such securities transactions are affected. Clients may seek to limit our authority in this area by directing that transactions (or some specified percentage of transactions) be executed through specified brokers in return for portfolio evaluation or other services deemed by the client to be of value. Any such client direction must be in writing (often through our advisory agreement) and may contain a representation from the client that the arrangement is permissible under its governing laws and documents if this is relevant. FPL Capital Management provides appropriate disclosure in writing to clients who direct trades to particular brokers, that with respect to their directed trades, they will be treated as if they have retained the investment discretion that we otherwise would have in selecting brokers to effect transactions and in negotiating commissions and that such direction may adversely affect our ability to obtain best price and execution. In addition, FPL Capital Management will inform clients in writing that the trade orders may not be aggregated with other clients’ orders and that direction of brokerage may hinder best execution. Special Consideration for ERISA Clients A retirement or ERISA plan client may direct all or part of portfolio transactions for its account through a specific broker or dealer to obtain goods or services on behalf of the plan. Such direction is permitted provided that the goods and services provided are reasonable expenses of the plan incurred in the ordinary course of its business for which it otherwise would be obligated and empowered to pay. ERISA prohibits directed brokerage arrangements when the goods or services purchased are not for the exclusive benefit of the plan. Consequently, our firm will request that plan sponsors who direct plan brokerage provide us with a letter documenting that this arrangement will be for the exclusive benefit of the plan. Client-Directed Brokerage FPL Capital Management does not allow client-directed brokerage outside our recommendations. ADV Part 2A – Firm Brochure Page 14 FPL Capital Management, LLC  Item 13 – Review of Accounts Accounts are reviewed on at least a quartlery basis by the senior portfolio manager of FPL Capital Management, Michael George, or a designated associated person. Periodically, a more frequent review may be required due to a client’s request, a change in the client's financial situation or a change in asset allocation, and market conditions. No less than annually, FPL Capital Management will conduct a review of each account to review performance, portfolio allocation, reallocation of assets, and client consultation. Clients receive transaction confirmations on all transactions in their account on a trade-by-trade basis. Depending on account activity, client receives a monthly or quarterly statements from the custodian that documents positions, balances, account activity, and current market value. FPL Capital Management also provides quarterly reports detailing performance of the account, positions and activity. Item 14 – Client Referrals and Other Compensation Client Referrals FPL Capital Management occasionally receives client referrals. The referrals come from current clients, accountants, physicians, attorneys, and personal contacts. FPL Capital Management does not compensate any individual or entity for client referrals. FPL Capital Management refers clients or prospective clients to other unaffiliated professionals for estate and trust planning, and accounting needs. Other Compensations FPL Capital Management does not receive other types of compensation. FPL Capital is entirely fee-only and is only compensated by the advisory fees charged to client. Item 15 – Custody Deduction of Advisory Fees While FPL Capital Management does not maintain physical custody of client assets (which are maintained by a qualified custodian, as discussed above), we are deemed to have custody of certain client assets if given the authority to withdraw assets from client accounts, as further ADV Part 2A – Firm Brochure Page 15 FPL Capital Management, LLC  described below under “Third Party Money Movement.” All our clients receive account statements directly from their qualified custodian(s) at least quarterly upon opening of an account. We urge our clients to carefully review these statements. Additionally, if FPL Capital Management decides to send its own account statements to clients, such statements will include a legend that recommends the client compare the account statements received from the qualified custodian with those received from us. Clients are encouraged to raise any questions with us about the custody, safety or security of their assets and our custodial recommendations. Third-Party Money Movement On February 21, 2017, the SEC issued a no-action letter (“Letter”) with respect to Rule 206(4) -2 (“Custody Rule”) under the Investment Advisers Act of 1940 (“Advisers Act”). The letter provided guidance on the Custody Rule as well as clarified that an adviser who has the power to disburse client funds to a third party under a standing letter of instruction (“SLOA”) is deemed to have custody. As such, our firm has adopted the following safeguards in conjunction with our recommended custodians:  The client provides instructions to the qualified custodian, in writing, which 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.  The client authorizes the investment adviser, in writing, either on the qualified custodian’s form or separately, to direct transfers to the third party either on a specified schedule or from time to time.  The client’s qualified custodian performs appropriate verification of the instruction, 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.  The client has the ability to terminate or change the instruction to the client’s qualified custodian.  The investment adviser 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.  The investment adviser maintains records showing that the third party is not a related party of the investment adviser or located at the same address as the investment adviser.  The client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an annual notice reconfirming the instruction. ADV Part 2A – Firm Brochure Page 16 FPL Capital Management, LLC  Item 16 – Investment Discretion FPL Capital Management mostly receives discretionary authority from the client at the outset of an advisory relationship to select the identity and value of securities to be bought or sold. In all cases, however, such discretion is to be exercised in a manner consistent with the stated investment objectives for the particular client account. When selecting securities and determining values, FPL Capital Management observes investment policies, limitations, and restrictions of the clients for whom it advises. FPL Capital Management utilizes both discretionary and non-discretionary management options over client accounts. Under the discretionary management option, at the outset of an advisory relationship with FPL Capital Management, the client agrees to an investment policy statement. Then, FPL Capital Management may place trades in the account without receiving client approval. Under the non-discretionary management option, at the outset of an advisory relationship with FPL Capital Management, the client agrees to an investment policy statement. Then, FPL Capital Management places trades in the account only with prior client approval. Item 17 – Voting Client Securities FPL Capital Management does have authority to and does vote proxies on behalf of advisory clients. However, a client who wishes to vote on his or her own proxies may do so by sending a written request to our office. FPL Capital Management also may provide advice to clients regarding the clients’ voting of proxies. In general, we will determine how to vote proxies based on our reasonable judgment of that vote most likely to produce favorable financial results for our clients. Proxy votes generally will be cast in favor of proposals that maintain or strengthen the shared interests of shareholders and management, increase shareholder value, maintain, or increase shareholder influence over the issuer's board of directors and management, and maintain or increase the rights of shareholders; proxy votes generally will be cast against proposals having the opposite effect. However, we will consider both sides of each proxy issue. Consistent with the Company’s paramount commitment to the financial investment goals of our clients, social considerations will not be considered absent contrary instructions by a client. If any vote would cause a possible conflict of interest, we will contact the client for consent prior to casting a vote on behalf of client. ADV Part 2A – Firm Brochure Page 17 FPL Capital Management, LLC  Clients may obtain information about how the proxies pertaining to the client’s account were voted by emailing us at Info@fplcm.com. Item 18 – Financial Information FPL Capital Management is not required to provide financial information in this Brochure because:  We do not require a prepayment of more than $1,200 in fees when services cannot be rendered within six months.  We do not take custody of client funds or securities.  We do not have a financial condition or commitment that impairs our ability to meet contractual and fiduciary obligations to clients.  We have never been the subject of a bankruptcy proceeding. ADV Part 2A – Firm Brochure Page 18 FPL Capital Management, LLC  Item 1: Cover Page Part 2B of Form ADV: Brochure Supplement January 2025 Michael George 3525 North Causeway Blvd. Suite 633 Metairie, Louisiana MDGeorge@fplcm.com https://fplcm.com/ Firm Contact: Virajith Wijeweera Chief Compliance Officer This brochure supplement provides information about Mr. George that supplements our brochure. You should have received a copy of that brochure. Please contact Virajith Wijeweera if you did not receive FPL Capital Management, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Mr. George is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #2162546. ADV Part 2A – Firm Brochure Page 19 FPL Capital Management, LLC  Item 2: Educational Background & Business Experience Michael David George Year of Birth: 1970 Educational Background:  1992: Tulane University; B.S. in Corporate Finance Business Background:  06/2012 – Present FPL Capital Management, LLC; Investment Adviser Representative Item 3: Disciplinary Information There are no legal or disciplinary events material to the evaluation of Mr. George. Item 4: Other Business Activities Michael George also serves as the president of George Properties, LLC. George Properties is a privately held real estate holding corporation. George Properties is a completely separate entity from FPL Capital Management, LLC. George Properties does not engage in any transactions or relationships with FPL Capital Management or any clients of FPL Capital Management. George Properties does not and will not solicit business from clients of FPL Capital Management. The only clients of FPL Capital Management that may have a relationship with George Properties would be members of Michael George’s family. Item 5: Additional Compensation Mr. George does not receive any other economic benefit for providing advisory services in addition to advisory fees. ADV Part 2A – Firm Brochure Page 20 FPL Capital Management, LLC  Item 6: Supervision Virajith Wijeweera, Chief Compliance Officer of FPL Capital Management, LLC, supervises and monitors Mr. George’s activities on a regular basis to ensure compliance with our firm’s Code of Ethics. Please contact Virajith Wijeweera if you have any questions about Mr. George’s brochure supplement at (800) 835-1969. ADV Part 2A – Firm Brochure Page 21 FPL Capital Management, LLC  Item 1: Cover Page Part 2B of Form ADV: Brochure Supplement January 2025 Virajith Wijeweera 3525 North Causeway Blvd. Suite 633 Metairie, Louisiana VGW@fplcm.com https://fplcm.com/ Firm Contact: Virajith Wijeweera Chief Compliance Officer This brochure supplement provides information about Mr. Wijeweera that supplements our brochure. You should have received a copy of that brochure. Please contact Virajith Wijeweera if you did not receive FPL Capital Management, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Mr. Wijeweera is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #5611570. ADV Part 2B – Brochure Supplement Page 23 FPL Capital Management, LLC  Item 2: Educational Background & Business Experience Virajith Yaminda Wijeweera Year of Birth: 1980 Educational Background:  2004: University of New Orleans; B.S. in Business Administration  Virajith has also completed the CFP® Executive Program at University of Georgia’s Terry School of Business. He has not obtained the CFP® designation. Business Background:  06/2004 – Present FPL Capital Management, LLC; Chief Compliance Officer & Retirement Plan Director Item 3: Disciplinary Information There are no legal or disciplinary events material to the evaluation of Mr. Wijeweera. Item 4: Other Business Activities Mr. Wijeweera does not have any outside business activities to report. Item 5: Additional Compensation Mr. Wijeweera does not receive any other economic benefit for providing advisory services in addition to advisory fees. Item 6: Supervision Michael George is the President of FPL Capital Management, LLC and as such supervises and monitors Mr. Wijeweera’s activities on a regular basis to ensure compliance with our firm’s Code of Ethics. Please contact Michael George if you have any questions about Mr. Wijeweera’s brochure supplement at (800) 835-1969. ADV Part 2B – Brochure Supplement Page 23 FPL Capital Management, LLC  Item 1: Cover Page Part 2B of Form ADV: Brochure Supplement January 2025 Amanda Harrell 3525 North Causeway Blvd. Suite 633 Metairie, Louisiana Amanda@fplcm.com https://fplcm.com/ Firm Contact: Virajith Wijeweera Chief Compliance Officer This brochure supplement provides information about Ms. Harrell that supplements our brochure. You should have received a copy of that brochure. Please contact Virajith Wijeweera if you did not receive FPL Capital Management, LLC’s brochure or if you have any questions about the contents of this supplement. Additional information about Ms. Harrell is available on the SEC’s website at www.adviserinfo.sec.gov by searching CRD #6456798. ADV Part 2B – Brochure Supplement Page 23 FPL Capital Management, LLC  Item 2: Educational Background & Business Experience Amanda Palamone Harrell Year of Birth: 1992 Educational Background:  2014: University of New Orleans; B.A. in Political Science Business Background: FPL Capital Management, LLC; Director of Client Service &  01/2017 – Present Development  01/2015 – 01/2017 Morgan Stanley; Financial Planning Associate and Registered Associate Item 3: Disciplinary Information There are no legal or disciplinary events material to the evaluation of Ms. Harrell. Item 4: Other Business Activities Ms. Harrell does not have any outside business activities to report. Item 5: Additional Compensation Ms. Harrell does not receive any other economic benefit for providing advisory services in addition to advisory fees. Item 6: Supervision Virajith Wijeweera, Chief Compliance Officer of FPL Capital Management, LLC, supervises and monitors Ms. Harrell’s activities on a regular basis to ensure compliance with our firm’s Code of Ethics. Please contact Virajith Wijeweera if you have any questions about Ms. Harrell’s brochure supplement at (800) 835-1969. ADV Part 2B – Brochure Supplement Page 23 FPL Capital Management, LLC