LIG CAPITAL MANAGEMENT, LLC

Form ADV, Part 2A: Firm Brochure LIG Capital Management, LLC (LIG Capital Management or "LIGCM") 3503 N.W. 63rd Street, Suite 100 Oklahoma City, OK 73116 Telephone: (405) 463-3334 Facsimile: (405) 463-3394 www.ligcam.com March 19, 2026 This brochure provides information about the qualifications and business practices of LIG Capital Management. If you have any questions about the contents of this brochure, please contact us at (405) 463-3334 and/or by mail. 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. LIG Capital Management is a Registered Investment Adviser. The registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about LIG Capital Management also is available on the SEC's website at www.adviserinfo.sec.gov. You can search for us by Firm Name or Firm IARD / CRD Number (130489). 1  Item 2: Summary of Material Changes Form ADV Part 2 requires registered investment advisers to amend their brochure when information becomes materially inaccurate. If there are any material changes to an adviser's disclosure brochure, the adviser is required to notify you and provide you with a description of the material changes. Since June 16, 2025, we have the following material changes to report: • Item 4: Advisory Business – On 03/19/2026, Megan Brown replaced Matthew Reynolds as CCO • Item 5: Fees and Compensation – Revisions were made in regard to the financial planning offered • Item 10: Other Financial Industry Activities and Affiliations – There have been changes to certain outside affiliations and third-party relationships. • Item 13: Review of Accounts – Clarifications have been made as to who is responsible for account reviews and portfolio monitoring within the Firm. • Item 20: Additional Information – This section has been revised for clarity about the trade error and correction procedures the Firm follows. 2  Item 3: Table of Contents Page 1 Item 1: Cover Page Page 2 Item 2: Summary of Material Changes Page 3 Item 3: Table of Contents Page 4 Item 4: Advisory Business Page 6 Item 5: Fees and Compensation Page 10 Item 6: Performance-Based Fees and Side-By-Side Management Page 11 Item 7: Types of Clients Page 11 Item 8 : Methods of Analysis, Investment Strategies and Risk of Loss Page 12 Item 9: Disciplinary Information Page 12 Item 10: Other Financial Industry Activities and Affiliations Page 13 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Page 15 Item 12: Brokerage Practices Page 17 Item 13: Review of Accounts Page 17 Item 14: Client Referrals and Other Compensation Page 18 Item 15: Custody Page 18 Item 16: Investment Discretion Page 19 Item 17: Voting Client Securities Page 19 Item 18: Financial Information Page 19 Item 19: Requirements for State-Registered Advisers Page 19 Item 20: Additional Information 3  Item 4: Advisory Business Firm History and Ownership LIG Capital Management, LLC (LIGCM) is an SEC-registered investment adviser and is located in Oklahoma City, Oklahoma. LIGCM was founded in January 2004. The firm's principals are Mark R. Humphreys, President and Christopher Lorenzen Vice- President. They, along with Stuart McCuan, are members of LIG Capital Management, LLC, each Officer owning approximately 33% of the LLC. The firm's Chief Compliance Officer, Megan Brown, has no ownership. For information about LIGCM's services, please contact any of the above listed principals at (405) 463-3334. The following paragraphs describe our services and fees. Refer to the description of each investment advisory service listed below for information on how we tailor our advisory services to your individual needs. As used in this brochure, the words "LIGCM," "we," "our," and "us" refer to LIG Capital Management, LLC and the words "you," "your," and "client" refer to you as either a client or prospective client of our firm. Overview LIGCM offers investment management, portfolio management, investment advisory, financial planning and consulting services to individuals, small businesses & institutional investors. The company may from time to time publish a market update newsletter. Investment Management Services Include: • • • Target Stock Strategy • ETF Allocation Program • Core Discretionary Program Investment Advisory & Consulting Services Include: • Investment Advisory Services • Other Advisory Services • Retirement Plan Consulting & Advice • Financial Planning Investment Management Services The Target Stock Strategy, ETF Allocation Program, and Core Discretionary Program are discretionary fee-based investment portfolios. The Target Stock Strategy is an equity-based portfolio that we describe as employing "trend following with risk management techniques in an attempt to provide positive absolute returns consistent with preservation of capital." We use charting, fundamental and technical analyses to actively manage this portfolio. The ETF Allocation Program has the same return objective and uses similar methodologies, while utilizing a wide range of Exchange Traded Funds (ETFs). The Core Discretionary Program is a comprehensive discretionary investment management solution with objectives tailored to each client. 4  For all programs, LIGCM uses domestic (US) exchange-traded and over-the-counter equity securities, as well as cash and equivalents (generally money market funds). For further information about our investment philosophy and investment process, please see "Item 8: Methods of Analysis, Investment Strategies and Risk of Loss." Investment Advisory & Consulting Services The Investment Advisory Services are generally non-discretionary fee-based advisory accounts, with portfolio advice based on the broad principles of Modern Portfolio Theory (MPT), asset allocation & diversification. Retirement Plan Consulting & Advice encompasses helping companies decide on an appropriate retirement plan for their business, finding and choosing a plan administrator (if the recommended plan requires one) and being available to advise enrolled employees on basic investment options, thus allowing them to then make informed investment decisions. Services to the Client (Plan Sponsor) or Participants (employees of Client) can include: • Retirement plan design consulting; • Advice on selection of Third Party Administrator and/or custodian; • Ongoing or on-demand liaison between plan provider, Third Party Administrator, and custodian; and, • Participant education. Other Advisory Services can include historical portfolio valuations, tailored asset allocation advice, transfer or registration services, or other contracted investment advisory services, billed hourly or by flat fee, including but not limited to: • Asset allocation and diversification recommendations tailored to client's investment goals. • Historical securities valuation, transfer and / or registration services. • Other financial or investment advisory services. Other Information Target Stock, ETF & Core Discretionary accounts are managed on a discretionary basis. Client accounts are separately managed. Clients own the individual stocks and/ or ETFs held in their account. Because we provide continuous asset management in our discretionary accounts, portfolios are regularly monitored. Where we use model portfolios, a change in the model portfolio leads to those changes being implemented in client accounts. Since individual securities have different risk profiles, they are only recommended to a client when consistent with the client's stated investment objective(s), risk tolerance, financial situation, and time horizon for investment. Our investment advice is not exclusive. We act as an adviser to other clients and may give advice and/ or take action(s) for those clients different from the advice given to you, as well as its timing and nature. We have no obligation to purchase or sell for your portfolio any security which the firm, its principals, or employees purchase or sell for themselves or for any other client(s). Transactions in a specific security may not be accomplished for all client accounts at the same time or at the same price. For detailed information on advisory services pricing, please see "Item 5: Fees & Compensation." 5  Wrap Fee Programs We do not participate in wrap fee programs. IRA Rollover Recommendations Effective December 20, 2021 (or such later date as the US Department of Labor "DOL" Field Assistance Bulletin 2018-02 ceases to be in effect) for purposes of complying with the DOL's Prohibited Transaction Exemption 2020-02 ("PTE 2020-02" where applicable) we are providing the following acknowledgment to you. When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule's provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. We benefit financially from the rollover of your assets from a retirement account to an account that we manage or provide investment advice on because the assets increase our assets under management and, in turn, our advisory fees. As a fiduciary, we only recommend a rollover when we believe it is in your best interest. Amount of Managed Assets As of December 31, 2025, we provide continuous management services for approximately $77 million in client assets on a discretionary basis, and $173 million in client assets on a non- discretionary basis. Item 5: Fees and Compensation Investment Management Fee For the Target Stock Strategy, the ETF Allocation Program, and the Core Discretionary Program LIGCM charges an asset-based investment management fee – a percentage of each account's assets under management. Account minimums are noted but are negotiable. The asset custodian may also charge an asset-based, or per trade, fee for trading; however, this fee never benefits LIGCM, directly or indirectly. 6  Target Stock & ETF Allocation Strategies Core Discretionary Investment Advisory Fees For Investment Advisory or accounts LIGCM charges an asset-based advisory fee -- a percentage of each account's assets under management. Annual fee minimums are noted but are negotiable. The asset custodian may also charge a fee per trade; however, this fee never benefits LIGCM, directly or indirectly. 7  Retirement Plan Consulting & Advice Fees For Retirement Plan Consulting & Advice, LIGCM may charge administrative fees based on employee and participant numbers and an asset-based fee using a percentage of plan assets. The Plan Asset Fees may be paid by the Plan Sponsor or Participants. Fee Methodology: Quarterly fee= Plan Assets Balance x Annual Fee x Daily Rate x Number of Days in the period. The Daily Rate is 1/365 in normal years and 1/366 in leap years. Other Advisory Services Fees LIGCM may also charge hourly fees of $250 (with a one hour minimum) for various financial or investment advisory services, as requested by clients and agreed to by a signed consulting agreement. 8  Financial Planning LIGCM provides financial planning services only as they relate to investment management. These services are limited to understanding a client’s financial situation, investment objectives, and time horizon for the purpose of constructing and managing investment portfolios. We do not offer comprehensive financial planning services such as insurance analysis, estate planning, tax preparation, or cash flow modeling. Any financial planning discussions are incidental to our investment advisory services and are not delivered as standalone or separately billed engagements. Valuation, Billing, & Invoicing Valuation of Securities: Where accounts are billed based upon market value, LIGCM shall determine the fair market value of the assets being billed upon. We use the closing price of exchange-traded and over-the-counter equity securities provided by each exchange - that is their fair market value. Our portfolio accounting system is updated with the security prices provided by them each day. To ensure the accuracy of our invoice, we reconcile each account the investment to the custodian's electronic record(s) or statement before calculating management fee. Billing: Accounts are generally billed quarterly in advance. Account valuations for billing purposes are based upon the previous quarter closing value (trade date valuation). The quarterly fee is approximately one quarter of the annual fee but is calculated to precisely reflect the actual number of days in the calendar quarter by using a defined "daily rate." The daily rate is equal to 1/365 in normal years and 1/366 in leap years. As an example, the first quarter of a non-leap year would be billed on January 1 using the account value on December 31. This is then multiplied by the annual fee rate, the daily rate of 1/365 and the number of days in the first quarter (90 in this example). Minimum Annual Fee: Where there is a stated minimum annual fee, and an account's calculated quarterly fee is less than one quarter of the stated minimum annual fee, then one quarter of the minimum annual fee shall be charged for that quarterly time period. Clients are subject to the minimum annual fee and minimum account requirements at the time their account was established with LIGCM. Therefore, the minimum annual fee and/or minimum account requirements may differ among clients. See "Item 7: Types of Clients" for further information. Negotiability / Exceptions to the Fee Schedule: We may make exceptions to the fee schedules based upon a number of factors, for example, the responsibilities involved in managing the account (e.g., meeting and reporting requirements), the nature of the client's relationship with LIGCM, and the size of the account or group of related accounts. The fee schedule may be altered for a group of clients or any particular client, so long as both LIGCM and the client agree in writing. Payment of Fees: Our fees are generally deducted from clients' assets. As noted above, while our management fees are stated on an annualized basis, they are pro-rated, billed, and deducted from client accounts quarterly. Where a fee is separately invoiced, we request full payment within 30 days. Other Types of Fees or Expenses That You May Pay "Embedded Fees": You may pay what are referred to as embedded fees in addition to the investment management fee you pay us. If, for example, we invest your portfolio in an independently managed Mutual Fund or Exchange Trade Fund (ETF), you will pay an investment 9  management fee to the manager of the Mutual Fund or ETF in addition to the fee you pay us. Mutual Funds and ETFs have expense ratios within the structure of the securities. Custodian and Other Broker-Dealer Fees: A custodian and / or broker-dealer may charge other fees and expenses to your account, including, transaction charges, wire fees, etc. Please see "Item 12: Brokerage Practices" for additional information. Pre-Paid Investment Management Fee: LIGCM does not require or solicit prepayment of more than $1,200 in fees per client, six months or more in advance. Deposits to and Withdrawals From Your Account: The investment management fee of a client will be adjusted for deposits to their account of $10,000 or more during any calendar quarter. Deposits will be billed for the balance of the quarter. There will be no adjustment for appreciation or depreciation in account asset value during any quarter, nor shall any adjustment or refund be made with respect to partial withdrawals by the client during the billed quarter. • Sample Calculation for a Deposit Fee: A client makes a deposit of $25,000 on March 15th to an account paying an annual fee of 1.75%. The annual fee would be $25,000 times 1.75% per annum or $437.50. The fee is pro-rated for the time remaining in the quarter, in this case, 16 days. (We use the days in the month, in this case 31, minus the date of deposit, here the 15th, to calculate the days remaining.) In a year with 365 days, the pro-rated fee would be calculated as: $25,000 x 1.75% x 1/365 x 16 days = $19.18. Termination of the Investment Advisory Relationship: Our contract with you can be terminated by you or us at any time with 30 days prior written notice, which is effective when received by the other party, and the client is entitled to receive a pro-rated refund of the unearned fee.Sample Calculation of a Termination Refund: Pro-rated refunds are calculated as follows: [Amount paid at the beginning of the quarter] x [(days remaining in the quarter on termination date, minus 30 days "notice period") divided by (total days in the quarter)]. For example, a client pays a fee of $1,000 on January 1 and terminates the relationship by written notice received on January 28. We, per contract, bill through the date 30 days after notice of termination is received, in this case February 27. The amount of the refund would be calculated as: $1,000 multiplied by days remaining in the quarter on termination date, minus 30 days (32), divided by the total days in the quarter (90). Therefore, $1,000 x (32 days / 90 days) = $355.55 fee refund. Item 6: Performance - Based Fees and Side-By-Side Management LIGCM does not offer a "performance-based fee" – that is, a fee based on a share of an account's capital gains or capital appreciation of the client's assets. We only manage accounts for an "asset- based fee," as described in "Item 5: Fees and Compensation." LIGCM does not engage in "side-by-side management" – that is, the practice of managing both asset- based fee and performance-based fee accounts. 10  Item 7: Types of Clients LIGCM may provide investment advice or guidance to the following types of clients: • Individuals & high net worth individuals • Pension, profit sharing plans, defined contribution plans (including plan participants) • Non-ERISA pension and profit-sharing plans • Trusts and estates • Charitable organizations including foundations and endowments • Corporations and other business entities Requirements for Opening or Maintaining an Account: Minimum account sizes vary. Please refer to "Item 5: Fees and Compensation" for further information. We do not have any requirements for maintaining an account. If the account is subject to ERISA, LIGCM acknowledges that it is a "fiduciary" as that term is defined by ERISA with respect to the Account. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis: LIGCM may use the following methods of security analysis: • Charting - Analysis performed on the graphical representation of historical prices • Fundamental - Analysis performed on historical and present data, with the goal of making financial forecasts • Technical - Analysis performed on the historical price, volume, or other attributes of a security or index Investment Strategies: LIGCM may use the following investment strategies: • Long term purchases (securities held at least a year) • Short term purchases (securities sold within a year) • Trading (securities sold within 30 days) • Short sales • Margin transactions • Option writing, including covered options, uncovered options or spreading strategies Our "Discipline" or Security Selection Process: Target Stock Strategy: We have a well-defined security selection process (our "discipline") that's designed to uncover industries and companies whose price has the potential for appreciation. Primarily a trend-following approach for individual stocks, we are also willing and able to buy ETFs when we believe that the markets may move in a broad fashion before we are able to identify appropriate individual stock candidates. ETF Allocation Program: We use our trend-following approach with only ETFs (and occasionally open- ended mutual funds) for this program. Our other investment management & advisory programs are broadly influenced by MPT with traditional asset allocation and diversification strategies. 11  Material Risks Investing in securities involves the risk of financial loss, including the loss of principal invested. Clients should be prepared to bear this risk. An investor in a common stock is, by definition, purchasing an unsecured interest in a company. In the event of bankruptcy, common shareholders have only a residual claim to assets. Past performance is not a guarantee of future results. The investment results for the Target Stock program or ETF Allocation Program shown to prospective clients may not be representative of an individually managed account's rate of return. Material Risks to Our Methods of Analysis: Our analysis may be compromised by inaccurate or misleading information. In order to determine the "value" of securities, LIGCM relies upon publicly available financial information. Material Risks to Our Investment Strategies: Client accounts are actively managed. While our investment strategy does not routinely involve frequent trading of securities, clients should be aware that frequent trading can negatively affect investment performance by increasing brokerage, other transaction costs, and taxes. We may manage concentrated portfolios. We may hold a small number of equity issues which we believe will, over time, outperform the broad market. Portfolios may not be numerically diversified. Since a single issue may represent a large portion of a client's portfolio, a client's portfolio (a) may periodically, substantively underperform the broad market and/ or (b) suffer a significant loss of principal if a single issue declines in value. Item 9: Disciplinary Information We are required to disclose legal or disciplinary events that are material to a client's or prospective client's evaluation of our advisory business or the integrity of our management. Neither LIGCM, nor LIGCM's personnel, have reportable disciplinary events to disclose. Item 10: Other Financial Industry Activities and Affiliations The principal business of LIGCM is to provide investment-related services. These services may include investment portfolio management, financial planning and investment consulting. LIGCM's executive officers spend approximately 100% of their time in this capacity. Julie Mahanay, an investment adviser representative of the firm, is also the owner of Stonecrest Advisory Solutions, LLC, which provides operational and consulting services to registered investment advisers, including LIG Capital Management. Stonecrest does not provide investment advice to the firm’s clients and is compensated through consulting fees that are not tied to advisory client assets or investment performance. Certain investment adviser representatives of LIGCM may hold insurance licenses and may offer insurance products through unaffiliated insurance carriers or agencies outside of their advisory activities with LIGCM. If a client purchases an insurance product through one of these representatives, the representative 12  may receive a commission directly from the insurance carrier or through an unaffiliated insurance agency or intermediary. LIGCM does not sell insurance products and does not receive any commissions or other compensation from the sale of insurance products. This arrangement creates a potential conflict of interest because the representative has a financial incentive to recommend insurance products based on the commissions they may receive. Clients are under no obligation to purchase insurance products through the firm’s representatives and may purchase such products through other insurance agents or agencies. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Client Transactions and Personal Trading Code of Ethics: A copy of LIGCM's current Code of Ethics is available to any client or prospective client upon request. To request a copy, please call us at (405) 463-3334 or write to us, Attn: Chief Compliance Officer at the firm's address on the cover page of this firm brochure. LIGCM has adopted a Code of Ethics pursuant to the US Securities & Exchange Commission's requirement that we establish, maintain, and enforce a written code of ethics: (a) to protect the firm's clients by deterring misconduct, inadvertent or otherwise; (b) to remind employees that they are trusted by clients and must act with complete propriety at all times; and (c) to protect the reputation of the firm. In General: As a fiduciary, LIGCM (the firm) has an affirmative duty to act in the best interests of clients. Supervised persons are also expected to act in the best interests of clients and place clients' interests before their own interests. 1. They have an obligation to protect the firm's reputation by conducting business with the honesty and integrity expected of an investment professional. 2. They should use particular care in determining the applicable fiduciary duty and shall comply with such duty as to those persons and interests to whom the duty is owed. Therefore, supervised persons shall not engage in any conduct involving dishonesty, fraud, deceit, or misrepresentation, or commit any act that reflects adversely on their honesty, trustworthiness, or professional competence. All supervised persons are expected to: 1. Place the interests of clients first. 2. Avoid (a) actual or potential conflicts of interest, (b) abusing a client's trust, or (c) taking inappropriate advantage of their position with the firm when making personal securities transactions. 3. Maintain the confidentiality of information (a) concerning client's financial circumstances, identity of their security holdings, etc., and (b) regarding the firm's research, the recommendations, and portfolio holdings. 4. Use reasonable care and judgment to achieve and maintain independence and objectivity when making investment recommendations or taking investment actions. Internal Controls: Our Code of Ethics includes oversight, enforcement, and recordkeeping provisions. We require delivery to and acknowledgment of receipt of the Code of Ethics by every employee. Supervised persons are required to report any violations of the Code of Ethics (or suspected violations 13  thereof) promptly to the firm's Chief Compliance Officer. Failure to comply with the firm's Compliance Policies, including the firm's Code of Ethics, may result in disciplinary action, including termination of employment. Important Provisions Privacy Policy: LIGCM has adopted a Privacy Policy that applies to consumers who apply for investment advisory services as well as customers who establish an account with the firm. Our Privacy Policy applies to both current and former consumers and customers. We collect nonpublic personal information, that is, "personally identifiable financial information" that identifies you or your accounts in the normal course of business as we manage your assets and administer your account(s). We do not disclose any nonpublic personal information about our customers or former customers to anyone unless: • A client directs that we make the disclosure; • A client consents to the disclosure; or • We believe in good faith that disclosure is required or permitted under law. We restrict access to nonpublic personal information about you to those employees and agents who need to know that information to provide investment advisory services to you. We maintain physical, electronic, and procedural safeguards that comply with federal and state standards to guard your nonpublic personal information. We will provide clients with timely notice of any change to our Privacy Policy. Prospective and current clients may obtain a copy of the firm's Privacy Policy upon request. To request a copy, please contact the Chief Compliance Officer by phone at (405) 463-3334 or by writing to us, Attn: Chief Compliance Officer, at the firm's address on the cover page of this firm brochure. Conflicts of Interest: Supervised persons should avoid conflicts of interest and situations that reflect poorly on the individual or firm, that is, situations that a client might perceive as a conflict. When conflicts arise, all material facts that might impair the supervised person's ability to make to the client(s), firm, and / or unbiased and objective recommendations should be disclosed prospective clients. Supervised persons should comply with any prohibitions on their activities that are imposed by the firm when a conflict of interest exists. Insider Trading: "Insider trading" refers to (a) trading in securities on the basis of material, non-public information or (b) the communication of material, non-public information to others. • Supervised persons are prohibited from communicating material nonpublic information, whether attributable to the firm or a third-party, to others in violation of the law. • Supervised persons are prohibited from trading (either for themselves or on behalf of others) or causing others to trade in securities based on material nonpublic information. • Supervised persons should make reasonable efforts to achieve public dissemination of material nonpublic information disclosed in breach of a duty, e.g., material nonpublic information disclosed by the executive of a public company. 14  Participation or Interest in Client Transactions: The firm and its employees are prohibited from engaging in principal transactions. More formally, neither LIGCM, its employees, or a related person recommends to clients, or buys or sells for client accounts, securities in which we or a related person have a material financial interest. Personal Trading: LIGCM, its employees, or a related person may invest in the same securities (or related securities, for example, warrants, options, or futures) that LIGCM or a related person recommends to its clients. To mitigate our conflict of interest when trading securities that may also be owned by clients, our Code of Ethics describes appropriate trading guidelines that should be followed, including the use of aggregated block trading where possible. These guidelines attempt to ensure fair and equal pricing and are designed to help preclude the possibility of an undue benefit to the employee, advisor representative, or their immediate family. Item 12: Brokerage Practices Factors that LIGCM Considers When Selecting or Recommending Broker-Dealers When LIGCM is granted discretionary authority, an investment adviser representative of the firm will determine which securities are bought and sold, the total amount to be bought and sold, and the timing of the transaction(s). The transaction will be effected at the broker-dealer who has custody of the client account, at a commission rate (if applicable) agreed to between the client and broker-dealer. LIGCM may recommend that clients establish brokerage accounts with the Schwab Advisor Services division of Charles Schwab & Co. ("Schwab Advisor Services"), a registered broker- dealer, to maintain custody of clients' assets and to effect trades for their accounts. Although LIGCM may recommend that clients establish accounts at Schwab, it is the client's decision to custody assets with Schwab. LIGCM and Schwab Advisor Services are separate, unaffiliated entities. Schwab Advisor Services provides LIGCM with access to its institutional trading and operations services typically not available to Schwab's retail customers. These services are generally available to independent investment advisors at no charge to them, as long as a total of at least $10 million of the advisor's clients account assets are maintained at Schwab Advisor Services. Schwab Advisor Services' services include brokerage, custody, research, access to mutual funds and other investments that are otherwise available only to institutional investors or that would require a significantly higher minimum initial investment than any of LIGCM's account minimums. Schwab Advisor Services also makes available to LIGCM other products and services that benefit LIGCM. Some of these other products or services assist LIGCM in managing and administering clients' accounts. These include software and other technology that provide access to client account data (such as trade confirmation and account statements), facilitate trade execution (and allocation of aggregate trade orders for multiple client accounts), provide research, pricing information and other market data, facilitate payment of LIGCM's fees from its clients' accounts, and assist with back-office support, recordkeeping, and client reporting. Many of these services may be used to service all or a substantial number of LIGCM's accounts, including accounts not maintained at Schwab Advisor Services. Research and Other Soft Dollar Benefits: LIGCM has no formal "soft dollar" agreements, nor any other formal referral or solicitation arrangement as described in Section 206(4)-3 of the Investment Advisers Act, in place with any broker-dealers which require or reward LIGCM for directing any 15  specified level of brokerage / commissions to any broker-dealers. Several broker-dealers offer electronic trading interfaces for client accounts, electronic delivery of client transaction detail, and other information to facilitate management of their clients' accounts. Brokerage for Client Referrals: LIGCM does not consider, when selecting or recommending a broker- dealer, whether we or a related person receive client referrals from the broker-dealer or third party. During our last fiscal year, we did not direct any client transactions to a particular broker-dealer in return for client referrals. LIGCM has no formal "soft dollar" agreements, nor any other formal referral or solicitation arrangement as described in Section 206(4)-3 of the Investment Advisers Act, in place with any broker-dealers which require or reward LIGCM for directing any specified level of brokerage / commissions to any broker-dealers. A client may direct LIGCM to execute all transactions for the client's account through a particular broker-dealer because the client is receiving the benefit of certain consulting services from the broker- dealer. The client will acknowledge their understanding and agreement that (1) by directing brokerage, the client may pay higher commissions on some or all transactions than might otherwise be attainable by LIGCM for the client's account, or may receive less favorable execution of some or all transactions, or both, and (2) in determining whether to instruct LIGCM to utilize a particular broker- dealer the client will compare the possible increase in costs or disadvantages of such an arrangement with the value of the services provided by the broker- dealer. See also, "The Cost of Not Aggregating" below. Aggregation of the Purchase or Sale of Securities Aggregating trades, a practice commonly referred to as "block trading," lets us execute trades in a more timely, equitable manner, at an average price. LIGCM will typically aggregate trades for clients whose accounts can be traded at a given broker-dealer. When we aggregate trades and more than one broker-dealer must be used, we will (a) rotate between the broker-dealers or (b) vary the order of clients for whom trades are placed in a given security on any particular day in order to ensure that no client is favored over another. When and Under What Conditions: For discretionary accounts we manage, it is our practice to aggregate orders for the purchase or sale of a particular security in several client accounts and execute a single transaction, in order to seek a lower commission or more advantageous net price. The benefit, if any, obtained as a result of such aggregation, is allocated pro-rata among the accounts of the clients who participate in the aggregated transaction. The Cost of Not Aggregating: LIGCM aggregates trade orders whenever feasible. It may not be feasible to aggregate trade orders when, for example, a client directs their brokerage. By directing LIGCM to use a particular broker-dealer to execute transactions, (1) the client's account may be unable to participate in aggregated orders and, when the client's account does participate in an aggregated order with broker-dealer they designate, the client's specification of a particular commission rate with the broker-dealer will preclude the client from receiving the benefit, if any, of a lower commission resulting from the aggregation, and the accounts of other clients participating in the aggregated order may receive a correspondingly greater benefit, (2) the transactions of other clients typically will be executed through other broker-dealers and some or all of the transactions for other clients might be executed at a better price and receive better execution through another broker- dealer, and (3) the commissions paid may not be competitive. Other clients might pay less for similar transactions through other broker-dealers. 16  Item 13: Review of Accounts Periodic Reviews Client accounts are reviewed periodically by the firm’s Investment Adviser Representatives to ensure that portfolio holdings and asset allocations remain consistent with the client’s stated investment objectives, risk tolerance, and financial circumstances. Formal account reviews are conducted at least annually by the IAR responsible for the client relationship. In addition, accounts are generally monitored on an ongoing basis and reviewed periodically throughout the year, typically quarterly, or as market conditions warrant. Review Triggers Accounts may also be reviewed at other times when triggered by events such as significant market fluctuations, deposits or withdrawals of funds, changes in a client’s financial situation, changes in investment objectives or risk tolerance, or upon client request. Compliance Oversight The firm’s Chief Compliance Officer monitors the firm’s supervisory processes to help ensure that account reviews are conducted in accordance with the firm’s policies and that advisory personnel fulfill their fiduciary obligations to clients. Client Reports Clients receive account statements directly from their qualified custodian at least quarterly. The firm may also provide written performance reports, portfolio reports, or access to an online client portal showing account information and portfolio holdings. Clients should carefully review all statements received from their custodian and compare them to any reports provided by the firm. Reports to Clients LIGCM may provide written reports to clients at the beginning of each quarter or send written or email notice that online reports are available. Such reports would generally consist of investment performance and a portfolio appraisal (an inventory of the client's investments). Similar reports may be provided by a client's consultant and / or custodian. Trade confirmations are provided by the broker-dealer handling the transaction. Upon request, LIGCM will provide transaction detail for taxable accounts, specifically a schedule of realized gains and losses for the preceding calendar year. LIGCM does not assume responsibility for the accuracy of information furnished by a client (for example, cost basis information) or any other party. Item 14: Client Referrals and Other Compensation Additional Compensation LIGCM's only compensation for its services is the asset-based investment management fee, or other agreed upon fee, paid by clients. We do not accept an "economic benefit" from someone who is not a client for providing investment advice or other advisory services to clients (e.g., a sales award or other prize). 17  Client Referrals LIGCM or a related person does not currently directly or indirectly compensate any person who is not a supervised person of the firm for client referrals. LIGCM may, in the future, pay referral fees to third parties ("solicitors") for introducing clients to us. Any such arrangement will be pursuant to a solicitation agreement that complies fully with Rule 206(4)-1 under the Investment Advisers Act of 1940. Item 15: Custody The account's assets will be held by a bank, trust company, broker-dealer or other entity designated and appointed by each client (and acceptable to LIGCM) as custodian of the account. The custodian shall be responsible (a) for the physical custody of the assets of the account, (b) for the collection of interest, dividends and other income attributable to the assets of the account, and (c) for the exercise of rights and tenders on assets of the account. LIGCM will not be responsible for any loss incurred by reason of any act or omission of the custodian. We will make reasonable efforts to require that the custodian perform its obligations with respect to the account. As discussed in "Item 5: Fees and Compensation," LIGCM directly debits investment advisory fees from client accounts. Because the custodian does not independently re- calculate the investment advisory fee to be deducted from your account, you should carefully review your custodian's statement(s) in order to verify the accuracy of the calculation, among other things. Please contact us directly if you believe that there is an error in any fee calculation. We receive trade confirmations and monthly account statements from your custodian, so we have a reasonable basis for believing that "the qualified custodian sends an account statement, at least quarterly, to each of your [our] clients for which it maintains funds or securities, identifying the amount of funds and of each security in the account at the end of the period and setting forth all transactions in the account during that period." Item 16: Investment Discretion LIGCM accepts discretionary authority to manage some securities accounts on behalf of clients. Under our contract, we have full power to supervise and direct the investment of the account, make and implement investment decisions, without prior consultation with you, in accordance with the written investment objective(s) you provide us. Where we have discretionary authority over an account, such authority includes the ability to do the following without contacting you: • Determine the security to buy or sell; and/or • Determine the amount of the security to buy or sell. In general, any requested limits on LIGCM's discretionary authority will be covered in the investment advisory agreement. We may also rely upon information collected by a broker- dealer. 18  Item 17: Voting Client Securities LIG Capital Management does not and will not vote proxies. Item 18: Financial Information LIGCM does not have any financial condition or impairment that would prevent the firm from meeting contractual commitments to the client. LIGCM does not take physical custody of client funds or securities, or serve as trustee or signatory for client accounts, and does not require the prepayment of more than $1,200 in fees six or more months in advance. Therefore, LIGCM is not required to include a financial statement with this brochure. LIGCM has not been the subject of a bankruptcy petition at any time during the past ten years. Item 19: Requirements for State-Registered Advisers We are a federally registered investment adviser; therefore, we are not required to respond to this item. Item 20: Additional Information Trade Errors In the event a trading error occurs in a client account, LIGCM will take prompt steps to correct the error and seek to ensure that the client’s account is restored as closely as possible to the position it would have been in had the error not occurred. Trade errors are typically addressed in coordination with the executing broker-dealer or custodian. Depending on the circumstances, corrective actions may include canceling or adjusting the trade, reallocating securities, or other corrective measures recommended by the broker-dealer or custodian. LIGCM will not benefit financially from trade errors. Any corrections will be handled in a manner designed to avoid disadvantaging the affected client. Class Action Lawsuits We do not determine if securities held by you are the subject of a class action lawsuit or whether you are eligible to participate in class action settlements or litigation nor do we initiate or participate in litigation to recover damages on your behalf for injuries as a result of actions, misconduct, or negligence by issuers of securities held by you. 19