Jc Capital Advisors Group LLC

JC Capital Advisors Group LLC 60 Long Ridge Road STE 212 Stamford, CT 06902 www.jccapitaladvisors.com 203-889-3400 May 13, 2026 Firm Brochure (Form ADV Part 2A) Item 1: Cover Page This brochure provides information about the qualifications and business practices of JC Capital Advisors Group LLC. If you have any questions about the contents of this brochure, please contact us at the phone number listed above. 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. Registration (e.g. “registered investment advisor”) does not imply a certain level of skill or training. Additional information about JC Capital Advisors Group LLC also is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2: Material Changes Pursuant to SEC rules, JC Capital Advisors Group LLC will ensure that clients receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after the Firm’s fiscal year end, December 31. This means that if there were any material changes over the past year, clients will receive a summary of those changes no later than April 30. At that time, JC Capital Advisors Group LLC will also offer a copy of its most current disclosure brochure and may also provide other ongoing disclosure information about material changes as necessary. If there are no material changes over the past year, no notices will be sent. Clients and prospective clients can always receive the most current disclosure brochure for JC Capital Advisors Group LLC at any time by contacting their investment advisor representative. This is a new brochure as of May 13, 2026. 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 ......................................................................................................... 6 Item 6 Performance-Based Fees and Side-By-Side Management .................................................... 9 Item 7 Types of Clients ..................................................................................................................... 9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 10 Item 9 Disciplinary Information ..................................................................................................... 13 Item 10 Other Financial Industry Activities and Affiliations ......................................................... 14 Item 11 Code of Ethics, Conflicts of Interest, and Personal Trading ............................................. 14 Item 12 Brokerage Practices ........................................................................................................... 16 Item 13 Review of Accounts .......................................................................................................... 19 Item 14 Client Referrals and Other Compensation......................................................................... 19 Item 15 Custody .............................................................................................................................. 19 Item 16 Investment Discretion........................................................................................................ 20 Item 17 Voting Client Securities ..................................................................................................... 21 Item 18 Financial Information ........................................................................................................ 21 3  Item 4 Advisory Business A. Firm Description JC Capital Advisors Group LLC (“JCCA” or the “Firm”) is an investment adviser registered with the SEC. JC Capital Advisors Group LLC was registered on January 15, 2026. The Principal Owner and Chief Compliance Officer of JCCA is James Cook. B. Types of Advisory Services Portfolio Management Services JC Capital Advisors Group primarily focuses on asset allocation and investment selection for the investment management of its client accounts, on a discretionary basis, among our investment objective categories. The allocation and selection are customized to the client’s stated investment goals and objectives in conjunction with our assessment of risk conditions. We are authorized, without prior consultation or approval with a client, to buy, sell, trade and allocate in and among exchange traded funds (ETFs), open-end mutual funds, individual equities, individual bonds, and other securities and/or contracts relating to the same, on margin (only if written authorization has been granted) or otherwise, and to give instructions in furtherance of such authority to the registered broker-dealer and the custodian of the assets. The Firm assesses clients’ current holdings and ensures alignment with both short and long-term goals. The Firm performs ongoing reviews of investment performance and portfolio exposure to market conditions. Accordingly, the Firm is authorized to perform various functions without further approval from the client, such as the determination of securities to be purchased or sold without prior permission from the client for each transaction. Any and all trades are made in the best interest of the client as part of the Firm’s fiduciary duty. However, risk is inherent to any investing strategy. Therefore, the Firm does not guarantee any results or returns. Investment Objective Categories JC Capital Advisors Group offer customized portfolios with the below five general investment objective categories: Aggressive Growth - This investment objective category is best suited for aggressive long-term investors willing to accept higher volatility in the pursuit of potentially higher returns over a full market cycle. The focus is on using exchange traded funds (ETFs), open-end mutual funds, closed-end mutual funds, individual equities, and government securities with characteristics that management believes have the potential to meet the objectives. Although the target weighting is approximately 100% equity, changing market conditions and our assessment of risk conditions could cause those percentages to differ materially. Growth - This investment objective category is suited for investors with a long-term investment time horizon willing to tolerate above average risk and volatility with the goal of achieving above-average growth of principal. The focus is on using exchange traded funds (ETFs), open- end mutual funds, closed-end mutual funds, individual equities, and government securities with characteristics that management believes have the potential to meet the objectives. Although the 4  target weighting is approximately 100% equity, changing market conditions and our assessment of risk conditions could cause those percentages to differ materially. Growth Income - This investment objective category is designed with a combination of equity and fixed-income securities providing the potential for growth of a portion of the capital over time, with an allocation to fixed-income securities to provide a current income stream. The focus is on using exchange traded funds (ETFs), open-end mutual funds, closed-end mutual funds, individual equities, and government securities with characteristics that management believes have the potential to meet the objectives. Although the target weighting is approximately 75% equity and 25% fixed income, changing market conditions and our assessment of risk conditions could cause those percentages to differ materially. Balanced - This investment objective category is designed with a combination of equity and fixed-income securities providing the potential for growth of a portion of the capital over time, with an allocation to fixed-income securities to provide a current income stream. The focus is on using exchange traded funds (ETFs), open-end mutual funds, closed-end mutual funds, individual equities, and government securities with characteristics that management believes have the potential to meet the objectives. Although the target weighting is approximately 50% equity and 50% fixed income, changing market conditions and our assessment of risk conditions could cause those percentages to differ materially. Income - This investment objective category is designed for those seeking above-average income by investing in income producing securities. The focus is on using exchange traded funds (ETFs), open-end mutual funds, closed-end mutual funds, government securities, corporate securities, municipal securities, real estate investment trusts (REITs), and individual equities with characteristics that management believes have the potential to meet the objectives. Financial Planning Financial plans and financial planning services can range from broad-based financial planning to consultative or single subject planning. If you retain our firm for financial planning services, we will consult with you to gather information about your financial circumstances and objectives and determine your current financial position, and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we may develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm, we may deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. General Consulting To the extent specifically requested by the client, the Firm may be engaged to provide consulting services for a separate fee as described in Item 5 below. The Firm may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written agreement with the client. Services are offered in several areas of a client’s financial situation, depending on their goals and objectives. Generally, such consulting services involve rendering a specific financial consultation based on the Client’s financial goals and objectives. This consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a client’s financial situation. 5  Consulting recommendations pose a conflict between the interests of the Firm and the interests of the client. For example, the Firm has an incentive to recommend that clients engage the Firm for investment management services or to increase the level of investment assets with the Firm, as it would increase the amount of advisory fees paid to the Firm. Clients are not obliged to implement any recommendations made by the Firm or maintain an ongoing relationship with the Firm. If the client elects to act on any of the recommendations made by the Firm, the client is under no obligation to implement the transaction through the Firm. Prior to engaging the Firm to provide any investment advisory services, the Firm requires a written Investment Advisory agreement (“IAA”) signed by the client prior to the engagement of any services. The IAA will outline services to which the client is entitled and fees the client will incur. The Firm does not act as a custodian of client assets. The client always maintains asset control. The Firm places trades for clients under a limited power of attorney through a qualified custodian/broker. C. Services Tailored to Clients’ Needs Services are provided based on a client’s specific needs within the scope of the services provided as discussed above. A review of the information provided by the client regarding the client’s current financial situation, goals, and risk tolerances will be performed and advice will be provided that is in line with available information. D. Wrap Fee Program versus Portfolio Management Program JCCA does not offer a Wrap Fee Program. E. Assets Under Management As of January 14, 2026, the Firm has the following assets under management: $263,000,000 Discretionary assets: Non-discretionary assets: $0 Item 5 Fees and Compensation A. Fees Individually Managed Accounts: Fees for individually managed accounts are priced as follows: Equity based portfolios (Referring to accounts in the Aggressive Growth, Growth, Growth Income, and Balanced investment categories, as described in Item 4 above.) Assets Under Management Up to $500,000 1.50% 6  $500,001 to $750,000 1.25% $750,001 to $1,000,000 1.125% $1,000,001 to $2,000,000 1.00% $2,000,001 + 0.85% Income based portfolios (Referring to accounts in the Income investment category, as described in Item 4 above.) Asset Under Management Up to $500,000 0.50% $500,001 to $1,000,000 0.45% $1,000,001 + 0.40% All asset-based fees are deducted by the qualified custodian of record quarterly, in advance, based upon the market value of the account assets on the last business day of the previous quarter. All fees paid to the Firm for investment advisory services are separate and distinct from the expenses charged by third-party managers and Investment Companies to their shareholders. These fees and expenses are described to the client in separate disclosures. These fees will generally include third-party management fees, an Investment Company management fee, other fund expenses, and in some situations a possible distribution fee. The Firm will provide investment advisory services and portfolio management services but will not provide custodial or other administrative services. At no time will the Firm accept or maintain custody of a client’s funds or securities except for authorized fee deduction. The Client may contact the Custodian directly for disbursements, or account record changes, and may also do so in writing to the custodian. The Firm may act at the client’s convenience to facilitate such written communications to the Custodian, provided that such action is not construed to be custody of client assets. Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. Fees paid to the Firm are separate and distinct from the custodian and execution fees. Clients may request to terminate their advisory contract with the Firm, in whole or in part, by providing advance written notice. Upon termination, any fees paid in advance will be prorated to the date of termination and any excess will be refunded to client via a check within 30 days. Client’s advisory agreement with the Firm is non-transferable without Client’s written approval. Financial Planning Fees We charge a fixed fee for standalone financial planning services. The exact fixed fees for financial planning services offered by the firm will be determined in advance based on the agreement between the client and the firm and based on the information provided by the client at that time or the complexity of the plan. Fees may be waived or reduced at the Firm’s discretion. Fixed fees for financial planning will typically range from $1,000 - $5,000, depending on the scope and complexity of the work. All fixed fees for services offered by the firm will be determined in advance based on the agreement between the client and the firm and based on the information provided by the client at that time. 7  Financial planning fees are billed half in advance and half at the delivery of the financial plan. Where the firm may request a fee in advance, the amount paid in advance will not be more than $1,200 per client and 6 months in advance. In the event of early termination, the unearned portion of prepaid fees will be prorated based on the work completed and refunded to the client. Consulting Fees We charge a fixed fee for consulting services. The exact fixed fees for any consulting services offered by the firm will be determined in advance based on the agreement between the client and the firm and based on the information provided by the client at that time or the complexity of the services to be rendered. Fees may be waived or reduced at the Firm’s discretion. Fixed fees for consulting services will typically range from $1,000 - $10,000, depending on the scope and complexity of the work. All fixed fees for services offered by the firm will be determined in advance based on the agreement between the client and the firm and based on the information provided by the client at that time. Consulting fees are billed half in advance and half at the completion of the consulting project. Where the firm may request a fee in advance, the amount paid in advance will not be more than $1,200 per client and 6 months in advance. In the event of early termination, the unearned portion of prepaid fees will be prorated based on the work completed and refunded to the client. Right of Cancellation In addition to the right to terminate an agreement pursuant to its terms, a client may cancel an agreement with JCCA within five (5) business days of first receiving a copy of this disclosure brochure and supplement without penalty or fee. B. Fee Deduction Disclosure JCCA will generally deduct management fees directly from client accounts. In some cases, upon request by the client, the Firm may bill clients for fees incurred to be paid by check. Where the Firm deducts its management fee from client accounts utilizing a qualified custodian, the JCCA is required to meet the following requirements: a) Possess written authorization from the client to deduct advisory fees from an account held by a Qualified custodian; b) JCCA must have a reasonable basis, after due inquiry, for believing that the qualified custodian sends custodial statements to the client, which include the client’s transactions and holdings, on at least a quarterly basis. For clients that who have elected to pay management fees by check, these requirements do not apply. C. Other Fees and Expenses Broker-dealers charge brokerage commissions and/or transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity transactions, and mark-ups and mark-downs are charged for fixed income transactions). The amount of these commissions and/or transaction fees may vary depending upon a range of factors, which typically include the following: the brokerdealer/custodian utilized; the total value of regulatory assets under management held at the 8  applicable custodian; the type of asset (e.g., equity, ETF, mutual fund, fixed income product). In addition, client accounts may invest in open-end mutual funds (including money market funds) and ETFs that have various internal fees and expenses (i.e., management fees), which are paid by these funds but ultimately borne by clients as a fund shareholder. These internal fees and expenses are in addition to the fees charged by the Firm. D. Advance Payment of Fees and Termination The Firm’s investment management fees are payable quarterly, in advance, based upon the market value of the account assets on the last business day of the previous quarter. Clients may request to terminate their advisory contract with the Firm, in whole or in part, by providing advance written notice. Upon termination, any fees paid in advance will be prorated to the date of termination and any excess will be refunded to client by check issued to the customer within 30-days. E. Commissions The Firm is an asset-based fee investment management firm. The firm does not receive commissions for purchasing or selling stocks, bonds, mutual funds, real estate investment trusts, or other commissioned securities products for clients. Certain investment adviser representatives of the Firm are also licensed as insurance agents. These representatives will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these representatives are separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of the firm who are insurance agents will have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with our firm. Item 6 Performance-Based Fees and Side-By-Side Management JCCA does not charge or accept performance-based fees. JCCA does not engage in side-by-side management. Item 7 Types of Clients JCCA provides investment advice to many different types of clients. These clients generally include individuals, pensions, charitable organizations, trusts, estates, corporations, and other types of business entities. Minimum Account Size The Firm generally requires a minimum account size of $100,000 to establish and maintain an advisory relationship. However, the Firm reserves the discretion to waive or reduce this minimum based on individual circumstances. 9  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis & Investment Strategies The Firm’s investment strategy is based on a macroeconomic analysis framework. Macroeconomic analysis involves the study of broad economic trends and indicators that may impact the direction of financial markets. These indicators help assess the health of the overall economy and the potential risks or opportunities across asset classes. The Firm uses macroeconomic analysis to evaluate whether conditions may warrant adjustments to equity exposure. The Firm does not engage in short-term market timing and generally maintains long-term allocations. However, if a range of macroeconomic indicators collectively suggest a higher likelihood of a prolonged bear market, the Firm may consider a reduction in equity exposure as a risk management measure. The indicators monitored as part of this process include, but are not limited to, the following: • Monetary Policy: Analysis of interest rate levels and central bank actions (such as those by the Federal Reserve) to determine whether policy is stimulating or restricting economic growth. • Money Supply: Observing changes in the total amount of money circulating in the economy, which can affect inflation, interest rates, and overall economic activity. • Market Valuation (P/E Ratio): The price-to-earnings (P/E) ratio is used to evaluate whether equity markets are overvalued or undervalued relative to historical averages. • Economic Cycle (Recession/Expansion): Identifying where the economy stands in the business cycle—whether it is growing (expansion) or contracting (recession)—to assess potential market impact. • Employment Data: Monitoring trends in job growth, unemployment rates, and labor force • • participation as indicators of consumer strength and overall economic momentum. • Leading Economic Indicators (LEI): A composite of economic data points (such as new orders, building permits, and stock prices) designed to predict future economic activity. Institute for Supply Management (ISM) Indices: Surveys of purchasing managers in manufacturing and services sectors that signal growth or contraction in those areas. Investor and Advisor Sentiment: Gauging the mood and expectations of market participants, which can influence short- to medium-term market movements. • Technical Indicators (e.g., Dow Theory): Analyzing market trends and price movements to identify patterns that may signal changes in market direction. • Corporate Earnings: Tracking profitability and earnings trends of publicly traded • companies as a measure of business health and market valuation support. Industrial Production: Reviewing output from factories, mines, and utilities as an indicator of real economic activity and demand. These factors are reviewed collectively rather than in isolation. The Firm uses a structured and disciplined process to evaluate this data and make investment decisions. Adjustments, when made, are typically focused on risk mitigation. B. Risk of Loss 10  Investing inherently involves risk up to and including loss of the principal sum. Further, past performance of any security is not necessarily indicative of future results. Therefore, future performance of any specific investment or investment strategy based on past performance should not be assumed as a guarantee. The Firm does not provide any representation or guarantee that the financial goals of clients will be achieved. The potential return or gain and potential risk or loss of an investment varies, generally speaking, with the type of product invested in. Below is an overview of the types of products available on the market and the associated risks of each: General Risks. Investing in securities always involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives can or will be met. Past performance is in no way an indication of future performance. We also cannot assure that third parties will satisfy their obligations in a timely manner or perform as expected or marketed. General Market Risk. Investment returns will fluctuate based upon changes in the value of the portfolio securities. Certain securities held may be worth less than the price originally paid for them, or less than they were worth at an earlier time. Common Stocks. Investments in common stocks, both directly and indirectly through investment in shares of exchange traded funds (ETFs), open-end mutual funds, closed-end mutual funds, may fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject certain strategies to potential losses. During temporary or extended bear markets, the value of common stocks will decline, which could also result in losses for each strategy. Portfolio Turnover Risk. High rates of portfolio turnover could lower performance of an investment strategy due to increased costs and may result in the realization of capital gains. If an investment strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains and under current tax law you would be taxed on short-term capital gains at ordinary income tax rates, if held in a taxable account. Non-Diversified Strategy Risk. Some investment strategies may be non-diversified (e.g., investing a greater percentage of portfolio assets in a particular issuer and owning fewer securities than a diversified strategy). Accordingly, each such strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller positions sizes. ETF Risks, including Net Asset Valuations and Tracking Error. An ETF's performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the 11  ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depository Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory compensation – advisory fees charged by Adviser plus any advisory fees charged by the issuer of the ETF. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a Client purchased the ETF directly. An ETF typically includes embedded expenses that may reduce the ETF's net asset value, and therefore directly affect the ETF's performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the ETF may include investment advisor management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar-denominated assets primarily managed by Adviser may be affected by the risk that currency devaluations affect Client purchasing power. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert your investment to cash or other assets. Legislative and Tax Risk. Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for options, swaps, master limited partnerships, Real Estate Investment Trust, Exchange Traded Products/Funds/Securities. We do not engage in tax planning, and in certain circumstances a Client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for how the transactions in their account are reported to the IRS or any other taxing authority. Foreign Investing and Emerging Markets Risk. Foreign investing involves risks not typically associated with U.S. investments, and the risks maybe exacerbated further in emerging market countries. These risks may include, among others, adverse fluctuations in foreign currency values, as well as adverse political, social, and economic developments affecting one or more foreign countries. 12  In addition, foreign investing may involve less publicly available information and more volatile or less liquid securities markets, particularly in markets that trade a small number of securities, have unstable governments, or involve limited industry. Investments in foreign countries could be affected by factors not present in the U.S., such as restrictions on receiving the investment proceeds from a foreign country, foreign tax laws or tax withholding requirements, unique trade clearance or settlement procedures, and potential difficulties in enforcing contractual obligations or other legal rules that jeopardize shareholder protection. Foreign accounting may be less transparent than U.S. accounting practices and foreign regulation may be inadequate or irregular. Information Security Risk. We may be susceptible to risks to the confidentiality and security of its operations and proprietary and customer information. Information risks, including theft or corruption of electronically stored data, denial of service attacks on our website or websites of our third-party service providers, and the unauthorized release of confidential information are a few of the more common risks faced by us and other investment advisers. Data security breaches of our electronic data infrastructure could have the effect of disrupting our operations and compromising our customers' confidential and personally identifiable information. Such breaches could result in an inability of us to conduct business, potential losses, including identity theft and theft of investment funds from customers, and other adverse consequences to customers. We have taken and will continue to take steps to detect and limit the risks associated with these threats. Tax Risks. Tax laws and regulations applicable to an account with Adviser may be subject to change and unanticipated tax liabilities may be incurred by an investor as a result of such changes. In addition, customers may experience adverse tax consequences from the early assignment of options purchased for a customer's account. Customers should consult their own tax advisers and counsel to determine the potential tax-related consequences of investing. Advisory Risk. There is no guarantee that our judgment or investment decisions on behalf of particular any account will necessarily produce the intended results. Our judgment may prove to be incorrect, and an account might not achieve her investment objectives. In addition, it is possible that we may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to accounts’ custodians’ software. Adviser and its representatives are not responsible to any account for losses unless caused by Adviser breaching our fiduciary duty. Dependence on Key Employees. An accounts success depends, in part, upon the ability of our key professionals to achieve the targeted investment goals. The loss of any of these key personnel could adversely impact the ability to achieve such investment goals and objectives of the account. C. Recommending primarily a particular type of security The Firm does not primarily recommend a particular type of security. Item 9 Disciplinary Information Registered investment advisers are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the advisory business or integrity of the Firm’s management. 13  JCCA has no disciplinary disclosures. James Cook, the owner and operator of JCCA, has no disciplinary disclosures. Item 10 Other Financial Industry Activities and Affiliations Registration as a Broker/Dealer or Broker/Dealer Representative JCCA is not registered and does not have an application pending to register, as a broker dealer and its management persons are not registered as broker/dealer representative. Registration as a Futures Commission merchant, Commodity Pool Operator JCCA and its management persons are not registered and do not have application pending to register, as a futures commission merchant, commodity pool operator/advisor. Relationships Material to this Advisory Business and Possible Conflicts of Interest Investment adviser representatives of the Firm are licensed insurance agents and may from time to time offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. When an insurance policy is purchased by the client, the investment advisor representative is paid a commission for servicing as the agent on record. The Firm always acts in the best interest of the client, including the sale of commissionable products to advisory clients. James Cook is also the Managing Member of another registered investment adviser, TJT Capital Group LLC. In this role, James Cook provides investment advisory and management services to clients of that firm. James Cook is currently transitioning away from this Firm. Clients may obtain additional information regarding this outside business activity upon request. Selection of other Advisors JCCA does not recommend or utilize other advisors. Item 11 Code of Ethics, Conflicts of Interest, and Personal Trading Fiduciary Status A. According to the SEC, an investment advisor is considered a fiduciary. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts. In addition, an investment advisor has a duty of utmost good faith to act solely in the best interest of each of its clients. JCCA and its representatives have a fiduciary duty to all clients. JCCA and its representatives’ fiduciary duty to clients is considered the core underlying principle of the Firm’s Code of Ethics and represents the expected basis for all representatives’ dealings with clients. The Firm has the responsibility to ensure that the interests of clients are placed ahead of it or its representatives’ own investment interest. All representatives will conduct business in an honest, ethical, and fair manner. All representatives will comply with all federal 14  and state securities laws at all times. Full disclosure of all material facts and potential conflicts of interest will be provided to clients prior to services being conducted. All representatives have a responsibility to avoid circumstances that might negatively affect or appear to affect the representatives’ duty of complete loyalty to their clients. Investment Recommendations Involving a Material Financial Interest and Conflict of B. Interest The Firm does not recommend that clients buy or sell any security in which a related person to the Firm or the Firm has a material financial interest. If any material financial interests arise, clients will be notified by the Firm. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of C. Interest JCCA and/or its investment advisory representatives may from time-to-time purchase or sell products or investments that they may recommend to clients. JCCA has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all managers, officers, and employees of the Firm. In addition, the Code of Ethics governs personal trading by each employee of JCCA deemed to be an Access Person and is intended to ensure that securities transactions affected by Access Persons of the Firm are conducted in a manner that avoids any actual or potential conflict of interest between such persons and clients of the adviser or its affiliates. JCCA collects and maintains records of securities holdings and securities transactions affected by Access Persons. These records are reviewed to identify and resolve potential conflicts of interest. JCCA’s Code of Ethics is available upon request. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities D. Transactions and Conflicts of Interest The Firm’s employees may buy or sell securities at the same time they buy or sell securities for clients. In order to mitigate conflicts of interest such as front running, employees are required to disclose all reportable securities transactions as well as provide the Firm with copies of their brokerage statements. Front running is the illegal practice of purchasing a security based on advanced non-public information regarding an expected large transaction that will affect the price of a security. Client transactions always take priority to avoid front running and other manipulative practices. If a conflict is identified, it will be investigated and actions pursuant to our WSPs will be followed. 15  Item 12 Brokerage Practices Selection and Recommendation A. JCCA has a duty to select brokers, dealers and other trading venues that provide best execution for clients. The duty of best execution requires an investment adviser to seek to execute securities transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances, taking into account all relevant factors. The lowest possible commission, while very important, is not the only consideration. It is the policy of the Firm to seek best execution in all portfolio trading activities for all investment disciplines and products, regardless of whether commissions are charged. This applies to trading in any instrument, security, or contract including equities, bonds, and forward or derivative contracts. The standards and procedures governing best execution are set forth in several written policies. Generally, to achieve best execution, the Firm considers the following factors, without limitation, in selecting brokers and intermediaries: • Execution capability; • Order size and market depth; • Availability of competing markets and liquidity; • Trading characteristics of the security; • Availability of accurate information comparing markets; • Quantity and quality of research received from the broker dealer; • Financial responsibility of the broker-dealer; • Confidentiality; • Reputation and integrity; • Responsiveness; • Recordkeeping; • Ability and willingness to commit capital; • Available technology; and • Ability to address current market conditions. The Firm evaluates the execution, performance, and risk profile of the broker-dealers it uses at least annually. We typically recommend Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. JCCA is independently owned and operated and is not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as a custodian, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. Products and services available to the Firm from Schwab Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms like us. Schwab provides JCCA and our clients with access to institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our 16  business. Schwab’s support services described below are generally available on an unsolicited basis (i.e., we do not have to request them) and at no charge to us. Here is a more detailed description of Schwab’s support services: Services that Benefit Clients Directly Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit each client. Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit a specific client. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts. In addition to investment research, Schwab also makes available software and other technology that: • Provides access to client account data (such as trade confirmations and account statements); • Facilitates trade execution and allocate aggregated trade orders for multiple client accounts; • Provides pricing and other market data; • Facilitates payment of our fees from our clients’ accounts; and • Assists with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include (among others) the following: • Educational conferences and events • Technology, compliance, legal, and business consulting • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants and insurance providers Schwab will provide some of these services itself or will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third-party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our Interest in Schwab's Services The availability of the services described above from Schwab benefits us because we do not have to produce or purchase them. They are not contingent upon JCCA committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate our recommendation of Schwab as a 17  custodian and broker is in the best interest of our clients. Our selection is primarily supported by the scope, quality and price of Schwab’s services, and not Schwab’s services that benefit only us. B. Research and Other Soft Dollar Benefits Soft dollar practices are arrangements whereby an investment adviser directs transactions to a broker‐dealer in exchange for certain products and services that are allowable under SEC rules. Client commissions may be used to pay for brokerage and research services and products as long as they are eligible under Section 28(e) of the Exchange Act of 1934. Section 28(e) sets forth a “safe harbor,” which provides that an investment adviser that has discretion over a client account is not in breach of its fiduciary duty when paying more than the lowest commission rate available if the adviser determines in good faith that the rate paid is commensurate with the value of brokerage and research services provided by the broker‐dealer. JCCA does not currently have any soft dollar benefit arrangements. C. Brokerage for Client Referrals JCCA does not receive client referrals from third parties for recommending the use of specific broker-dealer brokerage services. D. Directed Brokerage As stated above, the Firm recommends Schwab as the Qualified Custodian. However, clients may be serviced on a client- directed brokerage basis, where the Firm will place trades within the established account(s) at the Custodian designated by the Client, however the Firm does utilize a recommended Custodian and may not be able to obtain best execution outside of our recommended Custodian. The Firm will not be obligated to seek the lowest available transaction costs. These costs are determined by the Custodian the client selects. E. Order Aggregation JCCA may, at times, aggregate sale and purchase orders of securities (“block trading”) for advisory accounts with similar orders in order to obtain the best pricing averages and minimize trading costs. This practice is reasonably likely to result in administrative convenience or an overall economic benefit to the client. Clients also benefit relatively from better purchase or sale execution prices, or beneficial timing of transactions or a combination of these and other factors. Aggregate orders will be allocated to client accounts in a systematic non-preferential manner. JCCA may aggregate or “bunch” transactions for a client’s account with those of other clients in an effort to obtain the best execution under the circumstances. F. Trade Error Policy JCCA maintains a record of any trading errors that occur in connection with investment activities of its clients. Both gains and losses that result from a trading error made by JCCA will be borne or realized by JCCA. 18  Item 13 Review of Accounts A. Periodic Reviews The Firm regularly reviews and evaluates client accounts for compliance with each client’s investment objectives, policies and restrictions. The Firm analyzes rates of return and allocation of assets to determine strategy effectiveness. Such reviews are conducted by the Chief Compliance Officer of JCCA and shall occur at least once per calendar year. B. Intermittent Review Factors Intermittent reviews may be triggered by substantial market fluctuation, economic or political events, or changes in the client’s financial status (such as retirement, termination of employment, relocation, inheritance, etc.). Clients are advised to notify JCCA promptly if there are any material changes in their financial situation, investment objectives, or in the event they wish to place restrictions on their account. C. Reports Clients may receive confirmations of purchases and sales in their accounts and will receive, at least quarterly, statements containing account information such as account value, transactions, and other relevant information. Confirmations and statements are prepared and delivered by the custodian. Item 14 Client Referrals and Other Compensation Client Referrals A. The Firm will not receive any economic benefit from another person or entity for soliciting or referring clients. Other Compensation B. The Firm will not pay another person or entity for referring or soliciting clients for the Firm. Item 15 Custody A. Custodian of Assets Custody means holding, directly or indirectly, client funds or securities or having any authority to obtain possession of them. JCCA does not have direct custody of any client funds and/or securities. The Firm will not maintain physical possession of client funds and securities. Instead, clients’ funds and securities are held by a qualified custodian. 19  While the Firm does not have physical custody of client funds or securities, payments of fees may be paid by the custodian from the custodial brokerage account that holds client funds pursuant to the client’s account application. In certain jurisdictions, the ability of the Firm to withdraw its management fees from the client’s account may be deemed custody. Prior to permitting direct debit of fees, each client provides written authorization permitting fees to be paid directly from the custodian. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. As part of the billing process, the client’s custodian is advised of the amount of the fee to be deducted from that client’s account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. The custodian does not calculate the amount of the fee to be deducted and does not verify the accuracy of the Firm’s advisory calculation. Therefore, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation. Clients should contact the Firm directly if they believe that there may be an error in their statement. Standing Letters of Authorization The Firm may have custody due to clients giving the Firm limited power of attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017, which includes (in summary): i. client will provide instruction for the SLOA to the custodian; ii. client will authorize the Firm to direct transfers to the specific third party; iii. the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv. the client will have the ability to terminate or change the instruction; v. the Firm will have no authority or ability to designate or change the identity or any information about the third party; vi. the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii. the custodian will send the client an initial and annual notice confirming the SLOA instructions. Item 16 Investment Discretion JCCA may exercise full discretionary authority to supervise and direct the investments of a client’s account. This authority will be granted by clients upon completion of the investment agreement. This authority allows the Firm and its affiliates to implement investment decisions without prior consultation with the client. Such investment decisions are made in the client’s best interest and in accordance with the client’s investment objectives. Other than agreed upon management fees, this discretionary authority does not grant the Firm the authority to have custody of any assets in the client’s account or to direct the delivery of any securities or the payment of any funds held in the account. The discretionary authority granted by the client to the 20  Firm does not allow the Firm to direct the disposition of such securities or funds to anyone except the account holder. Item 17 Voting Client Securities The Firm does not perform proxy voting services on the client’s behalf. Clients are encouraged to read through the information provided with the proxy voting documents and to make a determination based on the information provided. Upon the client’s request, Firm representatives may provide limited clarifications of the issues presented in the proxy voting materials based on his or her understanding of issues presented in the proxy voting materials. However, clients have the ultimate responsibility for making all proxy voting decisions. Item 18 Financial Information A. Balance Sheet Requirement JCCA is not the qualified custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, six (6) months or more in advance. B. Financial Condition JCCA does not have any financial impairment that would prevent the Firm from meeting contractual commitments to clients. C. Bankruptcy Petition JCCA has not been the subject of a bankruptcy petition at any time during the last 10 years. 21 

JC Capital Advisors Group LLC 60 Long Ridge Road STE 212 Stamford, CT 06902 www.jccapitaladvisors.com 203-889-3400 May 13, 2026 Firm Brochure (Form ADV Part 2A) Item 1: Cover Page This brochure provides information about the qualifications and business practices of JC Capital Advisors Group LLC. If you have any questions about the contents of this brochure, please contact us at the phone number listed above. 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. Registration (e.g. “registered investment advisor”) does not imply a certain level of skill or training. Additional information about JC Capital Advisors Group LLC also is available on the SEC’s website at www.adviserinfo.sec.gov.  Item 2: Material Changes Pursuant to SEC rules, JC Capital Advisors Group LLC will ensure that clients receive a summary of any material changes to this and subsequent disclosure brochures within 120 days after the Firm’s fiscal year end, December 31. This means that if there were any material changes over the past year, clients will receive a summary of those changes no later than April 30. At that time, JC Capital Advisors Group LLC will also offer a copy of its most current disclosure brochure and may also provide other ongoing disclosure information about material changes as necessary. If there are no material changes over the past year, no notices will be sent. Clients and prospective clients can always receive the most current disclosure brochure for JC Capital Advisors Group LLC at any time by contacting their investment advisor representative. This is a new brochure as of May 13, 2026. 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 ......................................................................................................... 6 Item 6 Performance-Based Fees and Side-By-Side Management .................................................... 9 Item 7 Types of Clients ..................................................................................................................... 9 Item 8 Methods of Analysis, Investment Strategies and Risk of Loss ........................................... 10 Item 9 Disciplinary Information ..................................................................................................... 13 Item 10 Other Financial Industry Activities and Affiliations ......................................................... 14 Item 11 Code of Ethics, Conflicts of Interest, and Personal Trading ............................................. 14 Item 12 Brokerage Practices ........................................................................................................... 16 Item 13 Review of Accounts .......................................................................................................... 19 Item 14 Client Referrals and Other Compensation......................................................................... 19 Item 15 Custody .............................................................................................................................. 19 Item 16 Investment Discretion........................................................................................................ 20 Item 17 Voting Client Securities ..................................................................................................... 21 Item 18 Financial Information ........................................................................................................ 21 3  Item 4 Advisory Business A. Firm Description JC Capital Advisors Group LLC (“JCCA” or the “Firm”) is an investment adviser registered with the SEC. JC Capital Advisors Group LLC was registered on January 15, 2026. The Principal Owner and Chief Compliance Officer of JCCA is James Cook. B. Types of Advisory Services Portfolio Management Services JC Capital Advisors Group primarily focuses on asset allocation and investment selection for the investment management of its client accounts, on a discretionary basis, among our investment objective categories. The allocation and selection are customized to the client’s stated investment goals and objectives in conjunction with our assessment of risk conditions. We are authorized, without prior consultation or approval with a client, to buy, sell, trade and allocate in and among exchange traded funds (ETFs), open-end mutual funds, individual equities, individual bonds, and other securities and/or contracts relating to the same, on margin (only if written authorization has been granted) or otherwise, and to give instructions in furtherance of such authority to the registered broker-dealer and the custodian of the assets. The Firm assesses clients’ current holdings and ensures alignment with both short and long-term goals. The Firm performs ongoing reviews of investment performance and portfolio exposure to market conditions. Accordingly, the Firm is authorized to perform various functions without further approval from the client, such as the determination of securities to be purchased or sold without prior permission from the client for each transaction. Any and all trades are made in the best interest of the client as part of the Firm’s fiduciary duty. However, risk is inherent to any investing strategy. Therefore, the Firm does not guarantee any results or returns. Investment Objective Categories JC Capital Advisors Group offer customized portfolios with the below five general investment objective categories: Aggressive Growth - This investment objective category is best suited for aggressive long-term investors willing to accept higher volatility in the pursuit of potentially higher returns over a full market cycle. The focus is on using exchange traded funds (ETFs), open-end mutual funds, closed-end mutual funds, individual equities, and government securities with characteristics that management believes have the potential to meet the objectives. Although the target weighting is approximately 100% equity, changing market conditions and our assessment of risk conditions could cause those percentages to differ materially. Growth - This investment objective category is suited for investors with a long-term investment time horizon willing to tolerate above average risk and volatility with the goal of achieving above-average growth of principal. The focus is on using exchange traded funds (ETFs), open- end mutual funds, closed-end mutual funds, individual equities, and government securities with characteristics that management believes have the potential to meet the objectives. Although the 4  target weighting is approximately 100% equity, changing market conditions and our assessment of risk conditions could cause those percentages to differ materially. Growth Income - This investment objective category is designed with a combination of equity and fixed-income securities providing the potential for growth of a portion of the capital over time, with an allocation to fixed-income securities to provide a current income stream. The focus is on using exchange traded funds (ETFs), open-end mutual funds, closed-end mutual funds, individual equities, and government securities with characteristics that management believes have the potential to meet the objectives. Although the target weighting is approximately 75% equity and 25% fixed income, changing market conditions and our assessment of risk conditions could cause those percentages to differ materially. Balanced - This investment objective category is designed with a combination of equity and fixed-income securities providing the potential for growth of a portion of the capital over time, with an allocation to fixed-income securities to provide a current income stream. The focus is on using exchange traded funds (ETFs), open-end mutual funds, closed-end mutual funds, individual equities, and government securities with characteristics that management believes have the potential to meet the objectives. Although the target weighting is approximately 50% equity and 50% fixed income, changing market conditions and our assessment of risk conditions could cause those percentages to differ materially. Income - This investment objective category is designed for those seeking above-average income by investing in income producing securities. The focus is on using exchange traded funds (ETFs), open-end mutual funds, closed-end mutual funds, government securities, corporate securities, municipal securities, real estate investment trusts (REITs), and individual equities with characteristics that management believes have the potential to meet the objectives. Financial Planning Financial plans and financial planning services can range from broad-based financial planning to consultative or single subject planning. If you retain our firm for financial planning services, we will consult with you to gather information about your financial circumstances and objectives and determine your current financial position, and to define and quantify your long-term goals and objectives. Once we specify those long-term objectives (both financial and non-financial), we may develop shorter-term, targeted objectives. Once we review and analyze the information you provide to our firm, we may deliver a written plan to you, designed to help you achieve your stated financial goals and objectives. General Consulting To the extent specifically requested by the client, the Firm may be engaged to provide consulting services for a separate fee as described in Item 5 below. The Firm may determine to charge for such additional services, the dollar amount of which shall be set forth in a separate written agreement with the client. Services are offered in several areas of a client’s financial situation, depending on their goals and objectives. Generally, such consulting services involve rendering a specific financial consultation based on the Client’s financial goals and objectives. This consulting may encompass one or more areas of need, including but not limited to, investment planning, retirement planning, personal savings, education savings, insurance needs, and other areas of a client’s financial situation. 5  Consulting recommendations pose a conflict between the interests of the Firm and the interests of the client. For example, the Firm has an incentive to recommend that clients engage the Firm for investment management services or to increase the level of investment assets with the Firm, as it would increase the amount of advisory fees paid to the Firm. Clients are not obliged to implement any recommendations made by the Firm or maintain an ongoing relationship with the Firm. If the client elects to act on any of the recommendations made by the Firm, the client is under no obligation to implement the transaction through the Firm. Prior to engaging the Firm to provide any investment advisory services, the Firm requires a written Investment Advisory agreement (“IAA”) signed by the client prior to the engagement of any services. The IAA will outline services to which the client is entitled and fees the client will incur. The Firm does not act as a custodian of client assets. The client always maintains asset control. The Firm places trades for clients under a limited power of attorney through a qualified custodian/broker. C. Services Tailored to Clients’ Needs Services are provided based on a client’s specific needs within the scope of the services provided as discussed above. A review of the information provided by the client regarding the client’s current financial situation, goals, and risk tolerances will be performed and advice will be provided that is in line with available information. D. Wrap Fee Program versus Portfolio Management Program JCCA does not offer a Wrap Fee Program. E. Assets Under Management As of January 14, 2026, the Firm has the following assets under management: $263,000,000 Discretionary assets: Non-discretionary assets: $0 Item 5 Fees and Compensation A. Fees Individually Managed Accounts: Fees for individually managed accounts are priced as follows: Equity based portfolios (Referring to accounts in the Aggressive Growth, Growth, Growth Income, and Balanced investment categories, as described in Item 4 above.) Assets Under Management Up to $500,000 1.50% 6  $500,001 to $750,000 1.25% $750,001 to $1,000,000 1.125% $1,000,001 to $2,000,000 1.00% $2,000,001 + 0.85% Income based portfolios (Referring to accounts in the Income investment category, as described in Item 4 above.) Asset Under Management Up to $500,000 0.50% $500,001 to $1,000,000 0.45% $1,000,001 + 0.40% All asset-based fees are deducted by the qualified custodian of record quarterly, in advance, based upon the market value of the account assets on the last business day of the previous quarter. All fees paid to the Firm for investment advisory services are separate and distinct from the expenses charged by third-party managers and Investment Companies to their shareholders. These fees and expenses are described to the client in separate disclosures. These fees will generally include third-party management fees, an Investment Company management fee, other fund expenses, and in some situations a possible distribution fee. The Firm will provide investment advisory services and portfolio management services but will not provide custodial or other administrative services. At no time will the Firm accept or maintain custody of a client’s funds or securities except for authorized fee deduction. The Client may contact the Custodian directly for disbursements, or account record changes, and may also do so in writing to the custodian. The Firm may act at the client’s convenience to facilitate such written communications to the Custodian, provided that such action is not construed to be custody of client assets. Client is responsible for all custodial and securities execution fees charged by the custodian and executing broker-dealer. Fees paid to the Firm are separate and distinct from the custodian and execution fees. Clients may request to terminate their advisory contract with the Firm, in whole or in part, by providing advance written notice. Upon termination, any fees paid in advance will be prorated to the date of termination and any excess will be refunded to client via a check within 30 days. Client’s advisory agreement with the Firm is non-transferable without Client’s written approval. Financial Planning Fees We charge a fixed fee for standalone financial planning services. The exact fixed fees for financial planning services offered by the firm will be determined in advance based on the agreement between the client and the firm and based on the information provided by the client at that time or the complexity of the plan. Fees may be waived or reduced at the Firm’s discretion. Fixed fees for financial planning will typically range from $1,000 - $5,000, depending on the scope and complexity of the work. All fixed fees for services offered by the firm will be determined in advance based on the agreement between the client and the firm and based on the information provided by the client at that time. 7  Financial planning fees are billed half in advance and half at the delivery of the financial plan. Where the firm may request a fee in advance, the amount paid in advance will not be more than $1,200 per client and 6 months in advance. In the event of early termination, the unearned portion of prepaid fees will be prorated based on the work completed and refunded to the client. Consulting Fees We charge a fixed fee for consulting services. The exact fixed fees for any consulting services offered by the firm will be determined in advance based on the agreement between the client and the firm and based on the information provided by the client at that time or the complexity of the services to be rendered. Fees may be waived or reduced at the Firm’s discretion. Fixed fees for consulting services will typically range from $1,000 - $10,000, depending on the scope and complexity of the work. All fixed fees for services offered by the firm will be determined in advance based on the agreement between the client and the firm and based on the information provided by the client at that time. Consulting fees are billed half in advance and half at the completion of the consulting project. Where the firm may request a fee in advance, the amount paid in advance will not be more than $1,200 per client and 6 months in advance. In the event of early termination, the unearned portion of prepaid fees will be prorated based on the work completed and refunded to the client. Right of Cancellation In addition to the right to terminate an agreement pursuant to its terms, a client may cancel an agreement with JCCA within five (5) business days of first receiving a copy of this disclosure brochure and supplement without penalty or fee. B. Fee Deduction Disclosure JCCA will generally deduct management fees directly from client accounts. In some cases, upon request by the client, the Firm may bill clients for fees incurred to be paid by check. Where the Firm deducts its management fee from client accounts utilizing a qualified custodian, the JCCA is required to meet the following requirements: a) Possess written authorization from the client to deduct advisory fees from an account held by a Qualified custodian; b) JCCA must have a reasonable basis, after due inquiry, for believing that the qualified custodian sends custodial statements to the client, which include the client’s transactions and holdings, on at least a quarterly basis. For clients that who have elected to pay management fees by check, these requirements do not apply. C. Other Fees and Expenses Broker-dealers charge brokerage commissions and/or transaction fees for effecting certain securities transactions (i.e., transaction fees are charged for certain no-load mutual funds, commissions are charged for individual equity transactions, and mark-ups and mark-downs are charged for fixed income transactions). The amount of these commissions and/or transaction fees may vary depending upon a range of factors, which typically include the following: the brokerdealer/custodian utilized; the total value of regulatory assets under management held at the 8  applicable custodian; the type of asset (e.g., equity, ETF, mutual fund, fixed income product). In addition, client accounts may invest in open-end mutual funds (including money market funds) and ETFs that have various internal fees and expenses (i.e., management fees), which are paid by these funds but ultimately borne by clients as a fund shareholder. These internal fees and expenses are in addition to the fees charged by the Firm. D. Advance Payment of Fees and Termination The Firm’s investment management fees are payable quarterly, in advance, based upon the market value of the account assets on the last business day of the previous quarter. Clients may request to terminate their advisory contract with the Firm, in whole or in part, by providing advance written notice. Upon termination, any fees paid in advance will be prorated to the date of termination and any excess will be refunded to client by check issued to the customer within 30-days. E. Commissions The Firm is an asset-based fee investment management firm. The firm does not receive commissions for purchasing or selling stocks, bonds, mutual funds, real estate investment trusts, or other commissioned securities products for clients. Certain investment adviser representatives of the Firm are also licensed as insurance agents. These representatives will earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these representatives are separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of the firm who are insurance agents will have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with our firm. Item 6 Performance-Based Fees and Side-By-Side Management JCCA does not charge or accept performance-based fees. JCCA does not engage in side-by-side management. Item 7 Types of Clients JCCA provides investment advice to many different types of clients. These clients generally include individuals, pensions, charitable organizations, trusts, estates, corporations, and other types of business entities. Minimum Account Size The Firm generally requires a minimum account size of $100,000 to establish and maintain an advisory relationship. However, the Firm reserves the discretion to waive or reduce this minimum based on individual circumstances. 9  Item 8 Methods of Analysis, Investment Strategies and Risk of Loss A. Methods of Analysis & Investment Strategies The Firm’s investment strategy is based on a macroeconomic analysis framework. Macroeconomic analysis involves the study of broad economic trends and indicators that may impact the direction of financial markets. These indicators help assess the health of the overall economy and the potential risks or opportunities across asset classes. The Firm uses macroeconomic analysis to evaluate whether conditions may warrant adjustments to equity exposure. The Firm does not engage in short-term market timing and generally maintains long-term allocations. However, if a range of macroeconomic indicators collectively suggest a higher likelihood of a prolonged bear market, the Firm may consider a reduction in equity exposure as a risk management measure. The indicators monitored as part of this process include, but are not limited to, the following: • Monetary Policy: Analysis of interest rate levels and central bank actions (such as those by the Federal Reserve) to determine whether policy is stimulating or restricting economic growth. • Money Supply: Observing changes in the total amount of money circulating in the economy, which can affect inflation, interest rates, and overall economic activity. • Market Valuation (P/E Ratio): The price-to-earnings (P/E) ratio is used to evaluate whether equity markets are overvalued or undervalued relative to historical averages. • Economic Cycle (Recession/Expansion): Identifying where the economy stands in the business cycle—whether it is growing (expansion) or contracting (recession)—to assess potential market impact. • Employment Data: Monitoring trends in job growth, unemployment rates, and labor force • • participation as indicators of consumer strength and overall economic momentum. • Leading Economic Indicators (LEI): A composite of economic data points (such as new orders, building permits, and stock prices) designed to predict future economic activity. Institute for Supply Management (ISM) Indices: Surveys of purchasing managers in manufacturing and services sectors that signal growth or contraction in those areas. Investor and Advisor Sentiment: Gauging the mood and expectations of market participants, which can influence short- to medium-term market movements. • Technical Indicators (e.g., Dow Theory): Analyzing market trends and price movements to identify patterns that may signal changes in market direction. • Corporate Earnings: Tracking profitability and earnings trends of publicly traded • companies as a measure of business health and market valuation support. Industrial Production: Reviewing output from factories, mines, and utilities as an indicator of real economic activity and demand. These factors are reviewed collectively rather than in isolation. The Firm uses a structured and disciplined process to evaluate this data and make investment decisions. Adjustments, when made, are typically focused on risk mitigation. B. Risk of Loss 10  Investing inherently involves risk up to and including loss of the principal sum. Further, past performance of any security is not necessarily indicative of future results. Therefore, future performance of any specific investment or investment strategy based on past performance should not be assumed as a guarantee. The Firm does not provide any representation or guarantee that the financial goals of clients will be achieved. The potential return or gain and potential risk or loss of an investment varies, generally speaking, with the type of product invested in. Below is an overview of the types of products available on the market and the associated risks of each: General Risks. Investing in securities always involves risk of loss that you should be prepared to bear. We do not represent or guarantee that our services or methods of analysis can or will predict future results, successfully identify market tops or bottoms, or insulate clients from losses due to market corrections or declines. We cannot offer any guarantees or promises that your financial goals and objectives can or will be met. Past performance is in no way an indication of future performance. We also cannot assure that third parties will satisfy their obligations in a timely manner or perform as expected or marketed. General Market Risk. Investment returns will fluctuate based upon changes in the value of the portfolio securities. Certain securities held may be worth less than the price originally paid for them, or less than they were worth at an earlier time. Common Stocks. Investments in common stocks, both directly and indirectly through investment in shares of exchange traded funds (ETFs), open-end mutual funds, closed-end mutual funds, may fluctuate in value in response to many factors, including, but not limited to, the activities of the individual companies, general market and economic conditions, interest rates, and specific industry changes. Such price fluctuations subject certain strategies to potential losses. During temporary or extended bear markets, the value of common stocks will decline, which could also result in losses for each strategy. Portfolio Turnover Risk. High rates of portfolio turnover could lower performance of an investment strategy due to increased costs and may result in the realization of capital gains. If an investment strategy realizes capital gains when it sells its portfolio investments, it will increase taxable distributions to you. High rates of portfolio turnover in a given year would likely result in short-term capital gains and under current tax law you would be taxed on short-term capital gains at ordinary income tax rates, if held in a taxable account. Non-Diversified Strategy Risk. Some investment strategies may be non-diversified (e.g., investing a greater percentage of portfolio assets in a particular issuer and owning fewer securities than a diversified strategy). Accordingly, each such strategy is subject to the risk that a large loss in an individual issuer will cause a greater loss than it would if the strategy held a larger number of securities or smaller positions sizes. ETF Risks, including Net Asset Valuations and Tracking Error. An ETF's performance may not exactly match the performance of the index or market benchmark that the ETF is designed to track because 1) the ETF will incur expenses and transaction costs not incurred by any applicable index or market benchmark; 2) certain securities comprising the index or market benchmark tracked by the ETF may, from time to time, temporarily be unavailable; and 3) supply and demand in the market for either the ETF and/or for the securities held by the ETF may cause the 11  ETF shares to trade at a premium or discount to the actual net asset value of the securities owned by the ETF. Certain ETF strategies may from time to time include the purchase of fixed income, commodities, foreign securities, American Depository Receipts, or other securities for which expenses and commission rates could be higher than normally charged for exchange-traded equity securities, and for which market quotations or valuation may be limited or inaccurate. Clients should be aware that to the extent they invest in ETF securities they will pay two levels of advisory compensation – advisory fees charged by Adviser plus any advisory fees charged by the issuer of the ETF. This scenario may cause a higher advisory cost (and potentially lower investment returns) than if a Client purchased the ETF directly. An ETF typically includes embedded expenses that may reduce the ETF's net asset value, and therefore directly affect the ETF's performance and indirectly affect a Client’s portfolio performance or an index benchmark comparison. Expenses of the ETF may include investment advisor management fees, custodian fees, brokerage commissions, and legal and accounting fees. ETF expenses may change from time to time at the sole discretion of the ETF issuer. ETF tracking error and expenses may vary. Inflation, Currency, and Interest Rate Risks. Security prices and portfolio returns will likely vary in response to changes in inflation and interest rates. Inflation causes the value of future dollars to be worth less and may reduce the purchasing power of an investor’s future interest payments and principal. Inflation also generally leads to higher interest rates, which in turn may cause the value of many types of fixed income investments to decline. In addition, the relative value of the U.S. dollar-denominated assets primarily managed by Adviser may be affected by the risk that currency devaluations affect Client purchasing power. Liquidity Risk. Liquidity is the ability to readily convert an investment into cash to prevent a loss, realize an anticipated profit, or otherwise transfer funds out of the particular investment. Generally, investments are more liquid if the investment has an established market of purchasers and sellers, such as a stock or bond listed on a national securities exchange. Conversely, investments that do not have an established market of purchasers and sellers may be considered illiquid. Your investment in illiquid investments may be for an indefinite time, because of the lack of purchasers willing to convert your investment to cash or other assets. Legislative and Tax Risk. Performance may directly or indirectly be affected by government legislation or regulation, which may include, but is not limited to: changes in investment advisor or securities trading regulation; change in the U.S. government’s guarantee of ultimate payment of principal and interest on certain government securities; and changes in the tax code that could affect interest income, income characterization and/or tax reporting obligations, particularly for options, swaps, master limited partnerships, Real Estate Investment Trust, Exchange Traded Products/Funds/Securities. We do not engage in tax planning, and in certain circumstances a Client may incur taxable income on their investments without a cash distribution to pay the tax due. Clients and their personal tax advisors are responsible for how the transactions in their account are reported to the IRS or any other taxing authority. Foreign Investing and Emerging Markets Risk. Foreign investing involves risks not typically associated with U.S. investments, and the risks maybe exacerbated further in emerging market countries. These risks may include, among others, adverse fluctuations in foreign currency values, as well as adverse political, social, and economic developments affecting one or more foreign countries. 12  In addition, foreign investing may involve less publicly available information and more volatile or less liquid securities markets, particularly in markets that trade a small number of securities, have unstable governments, or involve limited industry. Investments in foreign countries could be affected by factors not present in the U.S., such as restrictions on receiving the investment proceeds from a foreign country, foreign tax laws or tax withholding requirements, unique trade clearance or settlement procedures, and potential difficulties in enforcing contractual obligations or other legal rules that jeopardize shareholder protection. Foreign accounting may be less transparent than U.S. accounting practices and foreign regulation may be inadequate or irregular. Information Security Risk. We may be susceptible to risks to the confidentiality and security of its operations and proprietary and customer information. Information risks, including theft or corruption of electronically stored data, denial of service attacks on our website or websites of our third-party service providers, and the unauthorized release of confidential information are a few of the more common risks faced by us and other investment advisers. Data security breaches of our electronic data infrastructure could have the effect of disrupting our operations and compromising our customers' confidential and personally identifiable information. Such breaches could result in an inability of us to conduct business, potential losses, including identity theft and theft of investment funds from customers, and other adverse consequences to customers. We have taken and will continue to take steps to detect and limit the risks associated with these threats. Tax Risks. Tax laws and regulations applicable to an account with Adviser may be subject to change and unanticipated tax liabilities may be incurred by an investor as a result of such changes. In addition, customers may experience adverse tax consequences from the early assignment of options purchased for a customer's account. Customers should consult their own tax advisers and counsel to determine the potential tax-related consequences of investing. Advisory Risk. There is no guarantee that our judgment or investment decisions on behalf of particular any account will necessarily produce the intended results. Our judgment may prove to be incorrect, and an account might not achieve her investment objectives. In addition, it is possible that we may experience computer equipment failure, loss of internet access, viruses, or other events that may impair access to accounts’ custodians’ software. Adviser and its representatives are not responsible to any account for losses unless caused by Adviser breaching our fiduciary duty. Dependence on Key Employees. An accounts success depends, in part, upon the ability of our key professionals to achieve the targeted investment goals. The loss of any of these key personnel could adversely impact the ability to achieve such investment goals and objectives of the account. C. Recommending primarily a particular type of security The Firm does not primarily recommend a particular type of security. Item 9 Disciplinary Information Registered investment advisers are required to disclose any legal or disciplinary events that are material to a client’s or prospective client’s evaluation of the advisory business or integrity of the Firm’s management. 13  JCCA has no disciplinary disclosures. James Cook, the owner and operator of JCCA, has no disciplinary disclosures. Item 10 Other Financial Industry Activities and Affiliations Registration as a Broker/Dealer or Broker/Dealer Representative JCCA is not registered and does not have an application pending to register, as a broker dealer and its management persons are not registered as broker/dealer representative. Registration as a Futures Commission merchant, Commodity Pool Operator JCCA and its management persons are not registered and do not have application pending to register, as a futures commission merchant, commodity pool operator/advisor. Relationships Material to this Advisory Business and Possible Conflicts of Interest Investment adviser representatives of the Firm are licensed insurance agents and may from time to time offer clients advice or products from those activities. Clients should be aware that these services pay a commission and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. When an insurance policy is purchased by the client, the investment advisor representative is paid a commission for servicing as the agent on record. The Firm always acts in the best interest of the client, including the sale of commissionable products to advisory clients. James Cook is also the Managing Member of another registered investment adviser, TJT Capital Group LLC. In this role, James Cook provides investment advisory and management services to clients of that firm. James Cook is currently transitioning away from this Firm. Clients may obtain additional information regarding this outside business activity upon request. Selection of other Advisors JCCA does not recommend or utilize other advisors. Item 11 Code of Ethics, Conflicts of Interest, and Personal Trading Fiduciary Status A. According to the SEC, an investment advisor is considered a fiduciary. As a fiduciary, it is an investment advisor’s responsibility to provide fair and full disclosure of all material facts. In addition, an investment advisor has a duty of utmost good faith to act solely in the best interest of each of its clients. JCCA and its representatives have a fiduciary duty to all clients. JCCA and its representatives’ fiduciary duty to clients is considered the core underlying principle of the Firm’s Code of Ethics and represents the expected basis for all representatives’ dealings with clients. The Firm has the responsibility to ensure that the interests of clients are placed ahead of it or its representatives’ own investment interest. All representatives will conduct business in an honest, ethical, and fair manner. All representatives will comply with all federal 14  and state securities laws at all times. Full disclosure of all material facts and potential conflicts of interest will be provided to clients prior to services being conducted. All representatives have a responsibility to avoid circumstances that might negatively affect or appear to affect the representatives’ duty of complete loyalty to their clients. Investment Recommendations Involving a Material Financial Interest and Conflict of B. Interest The Firm does not recommend that clients buy or sell any security in which a related person to the Firm or the Firm has a material financial interest. If any material financial interests arise, clients will be notified by the Firm. Advisory Firm Purchase of Same Securities Recommended to Clients and Conflicts of C. Interest JCCA and/or its investment advisory representatives may from time-to-time purchase or sell products or investments that they may recommend to clients. JCCA has adopted a Code of Ethics that sets forth the basic policies of ethical conduct for all managers, officers, and employees of the Firm. In addition, the Code of Ethics governs personal trading by each employee of JCCA deemed to be an Access Person and is intended to ensure that securities transactions affected by Access Persons of the Firm are conducted in a manner that avoids any actual or potential conflict of interest between such persons and clients of the adviser or its affiliates. JCCA collects and maintains records of securities holdings and securities transactions affected by Access Persons. These records are reviewed to identify and resolve potential conflicts of interest. JCCA’s Code of Ethics is available upon request. Client Securities Recommendations or Trades and Concurrent Advisory Firm Securities D. Transactions and Conflicts of Interest The Firm’s employees may buy or sell securities at the same time they buy or sell securities for clients. In order to mitigate conflicts of interest such as front running, employees are required to disclose all reportable securities transactions as well as provide the Firm with copies of their brokerage statements. Front running is the illegal practice of purchasing a security based on advanced non-public information regarding an expected large transaction that will affect the price of a security. Client transactions always take priority to avoid front running and other manipulative practices. If a conflict is identified, it will be investigated and actions pursuant to our WSPs will be followed. 15  Item 12 Brokerage Practices Selection and Recommendation A. JCCA has a duty to select brokers, dealers and other trading venues that provide best execution for clients. The duty of best execution requires an investment adviser to seek to execute securities transactions for clients in such a manner that the client’s total cost or proceeds in each transaction is the most favorable under the circumstances, taking into account all relevant factors. The lowest possible commission, while very important, is not the only consideration. It is the policy of the Firm to seek best execution in all portfolio trading activities for all investment disciplines and products, regardless of whether commissions are charged. This applies to trading in any instrument, security, or contract including equities, bonds, and forward or derivative contracts. The standards and procedures governing best execution are set forth in several written policies. Generally, to achieve best execution, the Firm considers the following factors, without limitation, in selecting brokers and intermediaries: • Execution capability; • Order size and market depth; • Availability of competing markets and liquidity; • Trading characteristics of the security; • Availability of accurate information comparing markets; • Quantity and quality of research received from the broker dealer; • Financial responsibility of the broker-dealer; • Confidentiality; • Reputation and integrity; • Responsiveness; • Recordkeeping; • Ability and willingness to commit capital; • Available technology; and • Ability to address current market conditions. The Firm evaluates the execution, performance, and risk profile of the broker-dealers it uses at least annually. We typically recommend Charles Schwab & Co., Inc. (“Schwab”), a registered broker-dealer, member SIPC, as the qualified custodian. JCCA is independently owned and operated and is not affiliated with Schwab. Schwab will hold your assets in a brokerage account and buy and sell securities when we instruct them to. While we recommend that you use Schwab as a custodian, you will decide whether to do so and will open your account with Schwab by entering into an account agreement directly with them. We do not open the account for you, although we may assist you in doing so. Products and services available to the Firm from Schwab Schwab Advisor Services™ is Schwab's business serving independent investment advisory firms like us. Schwab provides JCCA and our clients with access to institutional brokerage – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help us manage or administer our clients’ accounts while others help us manage and grow our 16  business. Schwab’s support services described below are generally available on an unsolicited basis (i.e., we do not have to request them) and at no charge to us. Here is a more detailed description of Schwab’s support services: Services that Benefit Clients Directly Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which we might not otherwise have access or that would require a significantly higher minimum initial investment by our clients. Schwab’s services described in this paragraph generally benefit each client. Services that May Not Directly Benefit Clients Schwab also makes available to us other products and services that benefit us but may not directly benefit a specific client. These products and services assist us in managing and administering our clients’ accounts. They include investment research, both Schwab’s own and that of third parties. We use this research to service all or a substantial number of our clients’ accounts. In addition to investment research, Schwab also makes available software and other technology that: • Provides access to client account data (such as trade confirmations and account statements); • Facilitates trade execution and allocate aggregated trade orders for multiple client accounts; • Provides pricing and other market data; • Facilitates payment of our fees from our clients’ accounts; and • Assists with back-office functions, recordkeeping and client reporting. Services that Generally Benefit Only Us Schwab also offers other services intended to help us manage and further develop our business enterprise. These services include (among others) the following: • Educational conferences and events • Technology, compliance, legal, and business consulting • Publications and conferences on practice management and business succession • Access to employee benefits providers, human capital consultants and insurance providers Schwab will provide some of these services itself or will arrange for third-party vendors to provide the services to us. Schwab may also discount or waive its fees for some of these services or pay all or a part of a third-party’s fees. Schwab may also provide us with other benefits, such as occasional business entertainment of our personnel. Our Interest in Schwab's Services The availability of the services described above from Schwab benefits us because we do not have to produce or purchase them. They are not contingent upon JCCA committing any specific amount of business to Schwab in trading commissions or assets in custody. The fact that we receive these benefits from Schwab is an incentive for us to recommend the use of Schwab rather than making such a decision based exclusively on your interest in receiving the best value in custody services and the most favorable execution of your transactions. This is a conflict of interest. We believe, however, that taken in the aggregate our recommendation of Schwab as a 17  custodian and broker is in the best interest of our clients. Our selection is primarily supported by the scope, quality and price of Schwab’s services, and not Schwab’s services that benefit only us. B. Research and Other Soft Dollar Benefits Soft dollar practices are arrangements whereby an investment adviser directs transactions to a broker‐dealer in exchange for certain products and services that are allowable under SEC rules. Client commissions may be used to pay for brokerage and research services and products as long as they are eligible under Section 28(e) of the Exchange Act of 1934. Section 28(e) sets forth a “safe harbor,” which provides that an investment adviser that has discretion over a client account is not in breach of its fiduciary duty when paying more than the lowest commission rate available if the adviser determines in good faith that the rate paid is commensurate with the value of brokerage and research services provided by the broker‐dealer. JCCA does not currently have any soft dollar benefit arrangements. C. Brokerage for Client Referrals JCCA does not receive client referrals from third parties for recommending the use of specific broker-dealer brokerage services. D. Directed Brokerage As stated above, the Firm recommends Schwab as the Qualified Custodian. However, clients may be serviced on a client- directed brokerage basis, where the Firm will place trades within the established account(s) at the Custodian designated by the Client, however the Firm does utilize a recommended Custodian and may not be able to obtain best execution outside of our recommended Custodian. The Firm will not be obligated to seek the lowest available transaction costs. These costs are determined by the Custodian the client selects. E. Order Aggregation JCCA may, at times, aggregate sale and purchase orders of securities (“block trading”) for advisory accounts with similar orders in order to obtain the best pricing averages and minimize trading costs. This practice is reasonably likely to result in administrative convenience or an overall economic benefit to the client. Clients also benefit relatively from better purchase or sale execution prices, or beneficial timing of transactions or a combination of these and other factors. Aggregate orders will be allocated to client accounts in a systematic non-preferential manner. JCCA may aggregate or “bunch” transactions for a client’s account with those of other clients in an effort to obtain the best execution under the circumstances. F. Trade Error Policy JCCA maintains a record of any trading errors that occur in connection with investment activities of its clients. Both gains and losses that result from a trading error made by JCCA will be borne or realized by JCCA. 18  Item 13 Review of Accounts A. Periodic Reviews The Firm regularly reviews and evaluates client accounts for compliance with each client’s investment objectives, policies and restrictions. The Firm analyzes rates of return and allocation of assets to determine strategy effectiveness. Such reviews are conducted by the Chief Compliance Officer of JCCA and shall occur at least once per calendar year. B. Intermittent Review Factors Intermittent reviews may be triggered by substantial market fluctuation, economic or political events, or changes in the client’s financial status (such as retirement, termination of employment, relocation, inheritance, etc.). Clients are advised to notify JCCA promptly if there are any material changes in their financial situation, investment objectives, or in the event they wish to place restrictions on their account. C. Reports Clients may receive confirmations of purchases and sales in their accounts and will receive, at least quarterly, statements containing account information such as account value, transactions, and other relevant information. Confirmations and statements are prepared and delivered by the custodian. Item 14 Client Referrals and Other Compensation Client Referrals A. The Firm will not receive any economic benefit from another person or entity for soliciting or referring clients. Other Compensation B. The Firm will not pay another person or entity for referring or soliciting clients for the Firm. Item 15 Custody A. Custodian of Assets Custody means holding, directly or indirectly, client funds or securities or having any authority to obtain possession of them. JCCA does not have direct custody of any client funds and/or securities. The Firm will not maintain physical possession of client funds and securities. Instead, clients’ funds and securities are held by a qualified custodian. 19  While the Firm does not have physical custody of client funds or securities, payments of fees may be paid by the custodian from the custodial brokerage account that holds client funds pursuant to the client’s account application. In certain jurisdictions, the ability of the Firm to withdraw its management fees from the client’s account may be deemed custody. Prior to permitting direct debit of fees, each client provides written authorization permitting fees to be paid directly from the custodian. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. As part of the billing process, the client’s custodian is advised of the amount of the fee to be deducted from that client’s account. On at least a quarterly basis, the custodian is required to send to the client a statement showing all transactions within the account during the reporting period. The custodian does not calculate the amount of the fee to be deducted and does not verify the accuracy of the Firm’s advisory calculation. Therefore, it is important for clients to carefully review their custodial statements to verify the accuracy of the calculation. Clients should contact the Firm directly if they believe that there may be an error in their statement. Standing Letters of Authorization The Firm may have custody due to clients giving the Firm limited power of attorney in a standing letter of authorization (“SLOA”) to disburse funds to one or more third parties as specifically designated by the client. In such circumstances, the Firm will implement the steps in the SEC’s no-action letter on February 21, 2017, which includes (in summary): i. client will provide instruction for the SLOA to the custodian; ii. client will authorize the Firm to direct transfers to the specific third party; iii. the custodian will perform appropriate verification of the instruction and provide a transfer of funds notice to the client promptly after each transfer; iv. the client will have the ability to terminate or change the instruction; v. the Firm will have no authority or ability to designate or change the identity or any information about the third party; vi. the Firm will keep records showing that the third party is not a related party of the Firm or located at the same address as the Firm; and vii. the custodian will send the client an initial and annual notice confirming the SLOA instructions. Item 16 Investment Discretion JCCA may exercise full discretionary authority to supervise and direct the investments of a client’s account. This authority will be granted by clients upon completion of the investment agreement. This authority allows the Firm and its affiliates to implement investment decisions without prior consultation with the client. Such investment decisions are made in the client’s best interest and in accordance with the client’s investment objectives. Other than agreed upon management fees, this discretionary authority does not grant the Firm the authority to have custody of any assets in the client’s account or to direct the delivery of any securities or the payment of any funds held in the account. The discretionary authority granted by the client to the 20  Firm does not allow the Firm to direct the disposition of such securities or funds to anyone except the account holder. Item 17 Voting Client Securities The Firm does not perform proxy voting services on the client’s behalf. Clients are encouraged to read through the information provided with the proxy voting documents and to make a determination based on the information provided. Upon the client’s request, Firm representatives may provide limited clarifications of the issues presented in the proxy voting materials based on his or her understanding of issues presented in the proxy voting materials. However, clients have the ultimate responsibility for making all proxy voting decisions. Item 18 Financial Information A. Balance Sheet Requirement JCCA is not the qualified custodian for client funds or securities and does not require prepayment of fees of more than $1,200 per client, six (6) months or more in advance. B. Financial Condition JCCA does not have any financial impairment that would prevent the Firm from meeting contractual commitments to clients. C. Bankruptcy Petition JCCA has not been the subject of a bankruptcy petition at any time during the last 10 years. 21