OPTIMA CAPITAL MANAGEMENT

Item 1: Cover Page OPTIMA Capital Management Firm Brochure – Form ADV Part 2A April 22, 2026 Optima Capital Management LLC 222 S Mill Ave Ste 800 Tempe, AZ 85281 480-757-9052 info@optimacapitalmgt.com https://www.optimacapitalmgt.com Item 1: Cover Page This brochure provides information about the qualifications and business practices of Optima Capital Management LLC. If you have any questions about the contents of this brochure, please contact Jonathan Elliott, Managing Partner and Chief Compliance Officer at 480- 776-1770 or by email at: jonathan_elliott@optimacapitalmgt.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Registration as an investment adviser does not imply a certain level of skill or training. The oral and written communications of an investment adviser provide you with information from which you determine to hire or retain an investment adviser. Additional information about Optima Capital Management LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. Optima Capital Management LLC’s CRD number is: 306036. The SEC’s website also provides information about any persons affiliated with Optima Capital Management LLC who are registered, or are required to be registered, as investment adviser representatives of Optima Capital Management LLC.  Finally, we are committed to providing our clients with in-depth financial knowledge, transparency, and a high-touch family office experience. Item 3: Table of Contents Item 1: Cover Page ............................................................................ 1 Item 2: Material Changes On January 15, 2026, Optima Capital Management LLC (“OCM” and the “Firm”) filed its annual update to this firm brochure. This summary of material changes informs our clients of changes since the last annual update to our brochure. These changes relate to our policies, practices, or conflicts of interest. It does not describe all the changes we periodically make to revise, clarify, and improve our brochure. Our brochure is delivered annually to clients. In addition to the annual update, we may provide you with a revised brochure to inform you of specific material changes or information required by the Securities and Exchange Commission (SEC) or state regulations. You may request a current brochure without charge by contacting Jonathan Elliott at jonathan_elliott@optimacapitalmgt.com or 480-776-1770. Advisory Services • We added information for the sub-adviser services that we provide to third-party investment services. These services do not involve advisory clients and do not change client services or fees. • We added information related to 3(38) retirement plan services. Item 2: Material Changes ................................................................ 2 Item 4: Advisory Business ............................................................... 3 Item 5: Fees and Compensation ................................................... 6 Item 7: Types of Clients ................................................................... 7 Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss ................................................................................................. 8 Item 9: Disciplinary Information .................................................. 11 Item 10: Other Financial Industry Activities and Affiliations . 11 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ........................................... 12 Item 12: Brokerage Practices ....................................................... 12 Item 13: Review of Accounts ........................................................ 13 Item 14: Client Referrals and Other Compensation ............... 13 Item 15: Custody ............................................................................. 14 Item 16: Investment Direction ..................................................... 14 Item 17: Voting Client Securities ................................................. 15 Item 18: Financial Information .................................................... 15 Brokerage Practices We updated our directed brokerage section to disclose that we do not allow directed brokerage. Fees and Compensation We added information regarding our compensation for sub- adviser services. Investment Strategies We updated the Services Limited to Specific Types of Investments and Investment Strategies sections to reflect that we do not offer private funds. Risks of Specific Securities Utilized We added a section for Buffered Exchange-Traded Funds. Other Financial Industry Activities and Affiliations We updated Todd Bendell’s role with Amphibian Capital and our association with the funds. About Us Optima Capital Management LLC is a modern wealth management firm and an independent fiduciary that provides objective advice based solely on your best interests. We use a goals-based approach for financial planning and work to simplify key areas of clients’ financial lives. Our thinking goes beyond traditional investments, incorporating diverse ideas and recommendations to build and protect your wealth. With access to our custodian’s renowned resources and sophisticated investment opportunities, we help our clients develop and maintain process-driven investment strategies. Page 2 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  provided by Trust & Will, a third-party service provider. You may obtain these services through the firm or directly from the provider at a reduced cost. Item 4: Advisory Business A. Description of the Advisory Firm Optima Capital Management LLC is a Limited Liability Company (LLC) founded in Arizona in September 2019 by Todd Bendell, Managing Partner, and Jonathan Elliott, Managing Partner, as a partnership. In certain cases, the firm may pay for or subsidize the cost of these services. This creates a financial incentive for the firm to recommend that you utilize this provider, and for you to accept the recommendation. This arrangement presents a conflict of interest because the firm has an economic interest in your use of the service. You are not obligated to use this provider and may obtain similar services from other providers. When we use the terms “firm,” “we,” “us,” or “associates” in this brochure, we are referring to Optima Capital Management LLC. For purposes of this brochure, ‘associates’ includes all employees and supervised persons of the firm. We do not provide legal or tax advice, and you should consult your own legal or tax professional regarding these matters. B. Types of Advisory Services Wealth Management We provide wealth management advisory services focusing on our clients’ needs and concerns. Advisory services may include financial planning and education, investment advice and related matters, and guidance through life events and transitions. Portfolio Management We offer ongoing portfolio management services based on your goals, objectives, time horizon, and risk tolerance. In addition, we create an Investment Policy Statement for each client, which outlines your current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to help you select a portfolio that matches your specific situation. Our portfolio management services include, but are not limited to, the following: Investment strategy These services include an initial discussion with our team to understand your financial goals, objectives, and risk tolerance. We will assess your relevant financial information to formulate a personalized investment solution. Furthermore, our process may include preparing a financial plan with specific written recommendations for you. Our initial consultation is complimentary and may be obtained separately from our portfolio management services. • • Asset allocation • Risk tolerance • Personal investment policy • Asset selection and cash management • Institutional investment managers • Regular portfolio monitoring Financial Planning Financial planning services are provided in connection with portfolio management and may be offered on a standalone basis at no additional cost. We do not offer fixed-fee financial planning services. Our financial analysis may include, but is not limited to, the following: • We evaluate your current investments based on your risk tolerance and time horizon. Clients can specify their risk tolerance levels in the Investment Policy Statement section of our Investment Agreement. In addition, we require your discretionary authority to select securities and execute transactions without your prior approval. • We seek to make investment decisions for our clients in accordance with our fiduciary duties, without considering our own economic, investment, or other financial interests. • • • To meet our fiduciary obligations, we attempt to avoid, among other things, investment, or trading practices that systematically advantage or disadvantage specific client portfolios. Financial Overview: Net Worth, Balance Sheet, Liquidity, Budget, Liabilities, Student Loans Investments: Asset Allocation, Sector, and Sector Concentration Retirement: Income Planning, Scenario Modeling, Executive Compensation, Social Security, Medicare, Cash Flows Education Funding Tax Estimate: Distribution and conversion of retirement assets Estate Analysis • In offering financial planning, a conflict exists between the interests of the investment adviser and the client’s interests. The client is not obligated to act upon the investment adviser’s recommendation. If the client elects to act on any of the recommendations, the client is under no obligation to effect the transaction through the investment adviser. Accordingly, our policy is to seek fair and equitable allocation of investment opportunities and transactions among our clients to avoid favoring one client over another over time. Our policy is to allocate investment opportunities and transactions we identify as appropriate and prudent, including initial public offerings (“IPOs”) and other investment opportunities that may have limited availability among our clients, on a fair and equitable basis over time. Estate Planning We may refer you to estate planning and probate services In addition, we ask clients to promptly notify us in writing of any material changes to their financial condition, including, but not Page 3 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  limited to, investment objectives, risk tolerance, investment time horizon, net worth, or annual income. • Plan. Investment Fiduciary: We will serve as co-fiduciary as an investment adviser with the Plan Sponsor, or if established under the Plan, with the Plan’s fiduciary investment committee (“Investment Committee”). Services Limited to Specific Types of Investments Our investment advice is generally limited to the following types of investments, which include: • Publicly exchange-traded securities (including US equities and shares of American Depository Receipts ADRs of non- U.S. companies) • Fixed-income securities (treasury inflation- • Participant Communications: We will help develop an education and communication strategy for the Plan’s participants, along with the custodian. This includes creating a calendar of educational initiatives, determining appropriate topics, and establishing meeting dates and schedules. protected/inflation-linked bonds) Institutional Investment Managers • Plan Evaluation: We will help the Plan Sponsor assess the • • Mutual funds • Exchange-traded funds ETFs (including alternative asset sector/class ETFs and closed-end funds) • Exchange-traded notes ETNs (including commodities and other alternative asset class ETNs) • Fee-based annuities may comprise equities, ETFs, and mutual funds. Plan’s benefit design and recommend ways to improve the Plan’s overall effectiveness as a retirement savings vehicle for Plan participants. We will assist the Plan Sponsor in selecting a recordkeeper, a third-party administrator, and a qualified custodian to serve as Plan trustee. Furthermore, we will help the Plan Sponsor assess and review progress for goals established concerning Plan participation and participant contributions. Plan-Level Investment Services • Retirement Plan Services We offer employer retirement plan services to small and medium-sized businesses, covering plan advisory, investment management, and educational services for plan participants. • Our plan-level fiduciary services will address your company’s needs to adopt a comprehensive retirement plan, provide an overview of the various plan design characteristics, assist with selecting a recordkeeper and third-party administrator, and provide ongoing guidance for meeting plan compliance requirements. • Our plan-level investment services are governed by the Employee Retirement Income Security Act of 1974 (“ERISA”), which sets forth rules under which plan fiduciaries may retain investment advisers to provide various services for plan assets. Investment Policy Statement (“IPS”): We will review, evaluate, and, if necessary, work with the custodian to create or revise the IPS for adoption by the Plan Sponsor or Investment Committee. Investment Menu Design: We will design an investment menu with a broad and diversified range of asset classes and investment categories of an appropriate size for the Plan’s participants. Investment Options: We will recommend a broad range of investment funds with different risk and return characteristics for the plan’s investment menu, designed to offer each participant an opportunity to construct an investment portfolio consistent with their risk profile, investment objective, and individual preferences. In addition, we will guide the Plan Sponsor or Investment Committee in selecting investment options at reasonable costs. As defined by ERISA, we may provide non-discretionary investment advisory fiduciary services as a Section 3(21) investment adviser or discretionary services as an “investment manager”, as defined in Section 3(38) of ERISA. Finally, we strive to improve financial wellness and retirement outcomes by collaborating with your plan participants on retirement planning and investment advice, offering one-on-one virtual meetings, and providing periodic communication and educational webinars. Our initial consultation with you and your company is complimentary and may be obtained separately from our portfolio management services. • Non-Discretionary 3(21) Services Plan Level Fiduciary Services • Fiduciary Education: We will periodically educate the plan • Portfolio Strategies: We will construct asset allocation strategies consistent with the Plan’s Investment Policy Statement (“IPS”). We will monitor the Plan’s portfolio strategy to determine whether a strategy’s asset allocation deviates from its target allocation and, as needed, recommend how the Investment Committee should reallocate the strategy’s investments to rebalance the asset allocation. Investment Monitoring and Reporting: We will assist the Plan Sponsor in regularly analyzing the overall performance of the Plan’s investments. As described in the IPS, the custodian will provide the Investment Committee with reports comparing the investments’ performance against the appropriate benchmarks. Furthermore, we will continuously review the investment options and recommend changes, as committee on current ERISA topics. As part of our guidance, we will educate the committee about its fiduciary responsibilities and investment-related duties under the Page 4 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  necessary, including removing or replacing any underperforming options. investment options offered to Plan participants and/or used for administrative purposes under the Plan, according to the criteria outlined in guidelines selected by the Plan Sponsor. • Qualified Default Investment Alternative (“QDIA”): If the Plan is a defined contribution plan with participant-directed investments and intends to offer a QDIA, we will evaluate and advise on the appropriateness of the Plan’s QDIA. Participant Level Services The following services are only for defined contribution plans with participant-directed investments. In addition, the Plan Sponsor retains all authority, responsibility, and decision-making for investment options not available on the Plan record-keeper’s platform (i.e., “noncore” investment options, such as employer stock, plan loans, Self-Directed Brokerage Accounts, frozen guaranteed investment contracts, and life insurance). We will retain final decision-making authority regarding the removal and/or replacement of investments in the core lineup. The Plan Sponsor will not be responsible for communicating instructions to any third party, custodian, or third-party administrator. Furthermore, we will provide the following services to Plan participants, with the Plan Sponsor’s or Investment Committee’s understanding that we will provide these services only to participants who are willing to accept our assistance. • Periodic Information We offer periodic market updates and educational content on timely financial topics to clients and prospects, delivered digitally or by postal mail. You may obtain these complimentary services separately from our portfolio management services. Investment Advice: We will help Plan participants determine their investment objectives, risk tolerance, time horizon, and other preferences and recommend a suitable asset allocation strategy. In addition, we are available for remote participant meetings at times reasonably agreed upon by the Plan participants and us. Educational Seminars/Workshops/Webinars We offer periodic in-person or video-conference educational sessions for our clients and prospective clients. These complimentary services may be obtained separately from our portfolio management services. Third-Party Investment Strategy Services We offer investment strategy services to third-party investment platforms and registered investment advisers (“third-party services”). Through these arrangements, we provide standardized investment strategies that the third-party service may offer to its subscribers or clients who elect to follow them in their taxable brokerage accounts. These services do not involve client accounts of the firm. • Financial Education: We will provide Plan participants with financial and investment education through the custodian. In partnership with the custodian, we will provide investment materials, such as worksheets and questionnaires, to help participants estimate future income needs and assess asset allocation strategies. In addition, we will educate participants about the overall benefits of Plan participation, the impact of pre-retirement withdrawals on retirement income, investment objectives and philosophies, time horizon, and risk/return characteristics. In addition, we will meet with participant groups, regularly or as requested, to present information on the following topics: Personal Finance, Retirement Planning, Investment Strategy, and Social Security. • Retirement Planning: We will provide Plan participants with additional retirement planning upon request. Upon receipt of a completed financial questionnaire, we will offer the following analysis, which may include, but is not limited to: Financial Overview, Investments, Retirement, Education Funding, Tax Estimate, and Estate Analysis. We do not provide individualized investment advice to subscribers or clients of third-party services, nor do we enter into an advisory relationship with them. We do not manage, monitor, or execute trades in any accounts associated with these programs, and we do not have discretionary or non- discretionary authority over such accounts. These services are separate from and not offered to our advisory clients. • Self-Directed Brokerage Account: Plan participants may be able to use a Self-Directed Brokerage Account (SDBA). Participants may choose to manage their SDBA with another investment adviser or us. C. Client Tailored Services and Client Imposed Restrictions We will tailor a service program for each client. Our program begins with a financial discussion to understand your specific needs and requirements, and help us formulate a strategy we will execute on your behalf. We may use asset allocation strategies and specific recommendations for each client based on their investment restrictions, needs, and targets. Discretionary 3(38) Services When a client engages us to perform 3(38) Services, we are appointed by the Plan Sponsor or trustee, granted discretion over plan assets, and assume full responsibility and liability for fiduciary functions related to plan-asset decisions. You may impose restrictions on specific securities or types of securities according to their values or beliefs. However, if the restrictions prevent us from adequately servicing your account or the conditions require us to deviate from our standard suite of services, we reserve the right to end our relationship. We will review the investment options available to the Plan through documents provided by the Plan Sponsor and notify the Plan’s record-keeper and/or the Plan Sponsor of our instructions to add, remove and/or replace these specific Page 5 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  D. Wrap Fee Programs A wrap fee program is an investment program in which the investor pays a single stated fee that covers management, transaction, and other administrative costs. We calculate your monthly fee based on the total value of all assets across all your accounts on the last business day of the prior billing period. We multiply the total value of your billable assets by your fee rate to determine your account’s daily rate, which is your account’s annualized fee amount divided by 365. We do not participate in wrap-fee programs. Financial Planning Financial planning services are provided in connection with portfolio management services and may be offered on a standalone basis at no additional cost. We do not offer fixed-fee financial planning services. E. Assets Under Management We have the following assets under management, which are managed on a discretionary basis. We calculate our regulatory assets under management using the methodologies applied in our Form ADV Part 1. We define discretionary as all assets over which we have investment discretion and trading authority. Discretionary Amount Date $150,319,761 12/31/2025 Estate Planning Trust & Will is a third-party estate-planning platform that offers state-specific legal documents across all 50 states. Trust & Will offers individual will plans for $170, and couples’ plans for $255. Retirement Plan Services Our Retirement Plan Services Agreement outlines our fee, which is determined by the total value of Plan assets and the number of Plan participants. Item 5: Fees and Compensation A. Fee Schedule Our fees are negotiable, and each service we offer is governed by a separate agreement that specifies the applicable fee schedule. The specific billing methodology and fee calculations are detailed in each client’s agreement. Total Assets Under Management $0 to $1 Million $1 Million to $10 Million $10 Million + Maximum Annual Fee 1.00% 0.50% 0.25% We reserve the right to waive fees for all or part of our services, and to determine whether to include specific securities and cash in a client’s billable assets. We rely on the custodian’s estimate of the Plan’s included total assets to determine the fee applicable to the Plan. In addition, we may propose fee increases in the future and will provide you with thirty (30) days’ prior notice. Any proposed fee increase will not be effective until we receive your signed agreement. Fees are billed monthly or quarterly, in advance or in arrears, based on the total value of includable assets held in the Plan, as determined by the Plan’s custodian on the last day of the billing quarter. The fee is calculated by multiplying the annual fee rate by the total asset value at the end of the period to determine the Plan’s daily rate, which is defined as the Plan’s total assets’ annualized fee amount divided by 365. Account Valuation We determine the market value of your account’s investments based on the securities listed on a national securities exchange, subject to the current last-sale reporting price, which will be valued at the amount reported on the statement you receive from the custodian. In addition, excluded Assets will not be included in the calculation of our fee payable to us. Any securities not traded or subject to last-sale reporting will be valued at the latest available bid price reflected by quotations furnished to us by appropriate sources. Finally, any other security of your account will be valued in such a manner that you and we will determine in good faith to reflect its fair market value. Portfolio Management We determine an appropriate fee schedule for each client’s portfolio based on its size, complexity, and investment objectives, as outlined in our Investment Agreement. Third-Party Investment Strategy Services We receive compensation from third-party investment services for our role as an investment strategy provider. This compensation is generally based on a percentage of subscription or program fees paid by subscribers who choose to follow our investment strategies through these services. The percentage of revenue we receive may vary based on factors determined by the third-party service, including whether a subscriber is an existing platform subscriber or enrolls through a designated marketing channel. Third-party services may modify their subscription pricing or revenue-sharing arrangements at their discretion upon notice to us. Total Assets Under Management All Assets Maximum Annual Fee 1.50% Third-party investment services may charge our firm onboarding, marketplace, or ongoing participation fees for making investment strategies available through their programs. Your portfolio management fee is billed monthly in advance. If you terminate our services, we will refund any unearned fees paid in advance on a prorated basis. Page 6 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  Retirement Plan Services Our fees for Retirement Plan Services are billed monthly or quarterly in arrears, depending on the Plan Sponsor. These services may offset, withhold, or deduct such fees from amounts otherwise payable to us. In addition, third-party services may withhold or deduct amounts related to marketing or promotional expenses, refunds, chargebacks, or other costs attributable to our participation in the program. During a partial billing period, we will bill the Plan in arrears for the days on which we provided services. The amount billed will be in accordance with the fee schedule in your Retirement Plan Services Agreement. These compensation arrangements create potential conflicts of interest, as they may incentivize us to design, maintain, or make available investment strategies that are more likely to attract or retain subscribers to a third-party service, or to influence the number or type of strategies offered through such programs. Third-Party Investment Strategy Services The fee arrangements described above apply solely to our portfolio management and retirement plan services. The applicable third-party service provider compensates us for our third-party investment strategy services and is not billed to, deducted from, or paid directly by subscribers. Subscribers of third-party investment services do not pay any fees directly to our firm, and our advisory clients are neither required nor encouraged to use these services. We periodically review these compensation arrangements and the associated conflicts of interest in connection with our participation in third- party investment strategy programs. E. Outside Compensation for the Sale of Securities to Clients Neither Optima Capital Management LLC nor our associates accept compensation for selling investment products, including asset-based sales charges or service fees from mutual fund sales. B. Payment of Fees Portfolio Management We withdraw our asset-based portfolio management fees from your accounts at the custodian each month, in accordance with your written authorization in the Investment Agreement. Furthermore, we will not accept 12b-1 fees or direct revenue from Plan Investments in connection with Retirement Plan Services. Retirement Plan Services The Plan Sponsor may choose to pay our fees from the Plan Sponsor’s assets, the Plan’s assets, or other sources under the Plan’s or the Plan Sponsor’s ownership and control. F. Termination of Services Portfolio Management You may terminate your Investment Agreement immediately upon written notice. We will refund any unearned fees paid in advance on a prorated basis. Your refund will be delivered within fourteen (14) days via check or deposit into your account. C. Client Responsibility of Third-Party Fees Portfolio Management Clients are responsible for all third-party fees (e.g., custodian, brokerage, mutual fund, exchange-traded fund, closed-end fund, transaction fees). These fees are separate and distinct from our portfolio management fees. Retirement Plan Services You may terminate your Retirement Plan Services Agreement by providing us with at least thirty (30) days prior written notice. We recommend certain custodians and broker-dealers. A detailed list of account fees, commissions, and limits is available on their websites. We can also provide this information upon request. If termination does not coincide with the end of a quarterly billing period, the Plan will be obligated to pay a prorated portion of the last quarterly fee installment in arrears. Retirement Plan Services The custodian will charge the Plan fees and, if applicable, expenses for its services, in addition to our fee. Please refer to your agreement with your custodian for more information. If applicable, the Plan will be entitled to a prorated refund of any prepaid advisory fee for the last quarterly billing period, based upon the number of days remaining after the effective termination date. Finally, the Plan may use funds to cover internal management fees and ongoing operating expenses, in addition to our fee, and these costs vary by investment. Item 6: Performance-Based Fees and Side-By-Side Management Neither Optima Capital Management LLC nor our associates accept performance-based fees or other fees based on a share of a client’s capital gains or capital appreciation of assets. D. Prepayment of Fees Portfolio Management We bill our asset-based fees for individual clients in advance. During a partial billing period, we will charge your account in advance for the remaining days of the month. Furthermore, the amount billed will be in accordance with the fee schedule in your Investment Advisory Agreement. Item 7: Types of Clients We provide advisory services to the following types of clients: Page 7 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  cross-checking it with other methods. Using charting analysis without fundamental analysis assumes that past performance will predict future performance, which may not hold. Individuals • Corporations and other businesses • High-net-worth individuals and families • • Retirement plans • Trusts Cyclical Analysis This analysis method assumes that the markets react in cyclical patterns, which, once identified, can be leveraged to provide performance. The risks with this strategy are two-fold. First, the markets do not always repeat cyclical patterns. Secondly, if too many investors adopt this strategy, the cycles they aim to exploit will change. We do not impose minimum account sizes or investment amounts. However, minimum investable asset requirements may apply to certain client relationships, as determined by the individual investment adviser representative responsible for the account, based on capacity, service scope, and relationship complexity. Fundamental Analysis Fundamental analysis focuses on factors that determine a company’s value and expected future earnings. The risk assumed is that the market will fail to reach expectations of perceived value. This strategy would encourage equity purchases in undervalued stocks or stocks priced below their perceived value. Item 8: Methods of Analysis, Investment Strategies, and Risk of Loss A. Methods of Analysis Our investment strategy evaluation methods include chart analysis, cyclical analysis, fundamental analysis, Modern Portfolio Theory, quantitative analysis, and technical analysis. • Charting analysis involves the use of patterns in performance charts. We use this technique to search for ways that may help predict favorable conditions for buying and selling securities. • Cyclical analysis involves the analysis of economic and business cycles to find favorable conditions for buying and selling securities. • Fundamental analysis involves the analysis of financial statements, the general economic health of companies, and the analysis of management or competitive advantages. • Modern Portfolio Theory is a theory of investment that Modern Portfolio Theory This theory assumes investors are risk-averse, meaning that, given two portfolios offering the same expected return, they prefer the lower-risk option. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor seeking higher expected returns must accept greater risk. The exact trade-off will be the same for all investors, but individual risk aversion will lead them to evaluate it differently. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile—for example, if an alternative portfolio exists for that level of risk with better-than- expected returns. attempts to maximize the expected return of a portfolio for a given amount of portfolio risk or, equivalently, minimize risk for a given level of expected return, each by carefully choosing the proportions of the various assets. • Quantitative analysis uses measurable factors different from Quantitative Analysis Quantitative analysis relies on strategies that may not perform as expected due to factors such as the factors used, the weights assigned to each factor, deviations from historical trends, and technical issues in strategy construction and implementation. • qualitative considerations, such as the character of management or employee morale, the value of assets, the cost of capital, and historical sales projections. Technical analysis involves the analysis of past market data, primarily price and volume. Investment Strategies We may use long-term, short-term, short-sales, and margin transactions. Technical Analysis Technical analysis aims to predict future stock prices or direction based on market trends. It assumes that the market follows discernible patterns. If investors can identify these patterns, they may predict market trends or stock price movements. The risk is that markets do not always follow historical patterns, and investors relying solely on this method may overlook emerging patterns. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Investment Risks Call Risk Call risk is the risk that a bond issuer will redeem a callable bond before maturity. Bondholders will receive payment on the bond’s value and, in most cases, will reinvest in a less favorable environment—one with a lower interest rate. Credit Risk Methods of Analysis Risk Charting Analysis Charting involves using and comparing charts to predict short- and long-term performance and market trends. The risk of using this method is that it relies on past performance data without Page 8 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  triggering a margin call. A margin call may force the account holder to allocate more funds to the account or sell assets in a shorter time frame than desired. Corporations and governments that issue debt to investors are subject to the timely repayment of principal and interest to bondholders. During periods of sharp economic decline, short- term debt obligations or bonds may be quickly repriced downward and lose value if the issuer’s ability to repay or financial viability is questioned. Short Sales A short sale strategy entails the possibility of infinite loss. An increase in the prices of the applicable securities will result in a loss, and the market has historically trended upward. Short-Term Trading Short-term trading risks include liquidity, economic stability, and inflation. Long-term risks include market volatility, credit risk, and interest rate risk. Frequent trading can affect investment performance by increasing brokerage fees, transaction costs, and taxes. Economic Risk From time to time, economic, political, and financial trends and developments may lead to periods of volatility or other adverse effects that could negatively impact investors. Domestic and international markets, including the sectors and companies within them, may respond in significant and unforeseen ways to public health issues, geopolitical events, natural disasters, and social unrest. Those matters and others not listed here may increase shareholders’ risk of loss. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Inflation Risk Inflation risk refers to the chance that inflation, which is a decline in an investor’s purchasing power over time, can also result in a realized return on an investment or the future value of an asset that is less than the expected value. C. Risks of Specific Securities Utilized Short sales and margin transactions may hold a greater risk of capital loss. Clients should be aware of the material risk of loss using any investment strategy. The investment types listed below (except for US Treasury Inflation-Protected/Inflation- Linked bonds) are not insured by the FDIC or other government agencies. Liquidity Risk Liquidity is the ability to convert an investment into cash readily. Generally, assets are more liquid when investors are interested in standardized products traded in easily accessible markets with low trading costs and broad participation. Alternative Investments Alternative investments, including real estate investments, currencies, notes and debentures, hedge funds, and private equity, are highly speculative and involve substantial risk. Political Risk Political risk is the risk that an investment’s return could be affected by political changes or instability in a country. The instability affecting investment returns could stem from unforeseen changes in government, legislative bodies, foreign policymakers, or military control. Regulatory Risk Regulatory risk is the risk that changes in government laws or regulations could negatively impact a business or investment by affecting the industry, sector, or market. Furthermore, alternative investments often engage in leveraging and other speculative investment practices that may increase the risk of investment loss, can be highly illiquid, are not required to provide periodic pricing or valuation information to investors, may involve complex tax structures and delays in distributing important tax information, are not subject to the same regulatory requirements as mutual funds, often charge high fees which may offset any trading profits, and in many cases, the underlying investments are not transparent and known only to the investment manager. Alternative investment performance can be volatile. An investor could lose all or a substantial amount of their investment. Investment Strategies Clients should know that short sales and margin transactions may carry greater risk, and investors may face a higher material risk of loss when using these strategies. Long-Term Trading This trading strategy captures market rates of both return and risk. By its nature, a long-term investment strategy can expose clients to risks that typically emerge over time as they hold the investments. These risks include, but are not limited to, inflation (purchasing power), interest rate, economic, market, and political and regulatory risks. Alternative investment funds and account managers often have full trading authority over their funds or accounts; consolidating these roles under a single adviser for similar trading programs may reduce diversification and, consequently, increase risk. There is often no secondary market for an investor’s interest in alternative investments, and the investor cannot expect one to develop. There may be restrictions on the transfer of interests in any alternative investment. Alternative investment products often execute a substantial portion of their trades on non-US exchanges. Investing in foreign markets may entail risks that differ from those associated with investments in US markets. Additionally, alternative investments often involve commodity Margin Transactions These transactions use the leverage from borrowing from a brokerage firm as collateral. When losses occur, the account’s margin value may fall below the brokerage firm’s threshold, Page 9 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  trading, which carries a substantial risk of loss. potential regulatory noncompliance. Annuities Annuities are retirement products for those who can pay a premium now and want to receive certain monthly payments or a return on investment later in the future. Annuities are contracts issued by a life insurance company to meet long-term needs or goals. An annuity is not a life insurance policy. Variable annuities are long-term investments to meet retirement and other long-range goals. Variable annuities are unsuitable for meeting short-term goals because substantial taxes and insurance company charges may apply if you withdraw your money early. Variable annuities also involve investment risks, just as mutual funds do. Fixed Income (Bonds) Fixed-income investments generally pay returns on a fixed schedule, though payment amounts can vary. This type of investment can include corporate and government debt securities, leveraged loans, high-yield and investment-grade debt, and structured products, such as mortgage and other asset-backed securities. However, investors consider individual bonds the best-known fixed-income security. The fixed-income market is generally volatile, and fixed-income securities carry interest rate risk. As interest rates rise, bond prices usually fall; conversely, as interest rates fall, bond prices typically increase. This effect is usually more pronounced for longer-term securities. Fixed-income securities also carry inflation, liquidity, call, credit, and default risks for issuers and counterparties. The risk of default on Treasury inflation-protected/inflation-linked bonds depends on a US Treasury default (extremely unlikely); however, there is a potential risk of share price loss, albeit relatively minimal. Investing in foreign fixed-income securities also entails the general risks of investing outside the US. Buffered Exchange-Traded Funds (“Buffered ETFs”) Buffered ETFs are structured investment vehicles that provide downside protection—up to a predetermined “buffer”—in exchange for limiting potential upside returns over a specified outcome period (typically 12 months). These funds involve unique risks, including issuer credit risk, tracking error, and structural complexity. Buffered ETFs may not prevent losses that exceed the stated buffer and may underperform traditional ETFs in rising markets due to their capped return potential. Additionally, investors must generally hold these securities for the full outcome period to achieve the intended exposure and risk/return characteristics. Initial Public Offerings (IPOs) An initial public offering (IPO) is a public offering in which company shares are sold to investors. These shares are typically underwritten by an investment bank which arranges their listing on public exchanges. The purchase of IPO shares may involve higher transaction costs, and such shares may carry greater risk than shares of publicly traded companies. Commodities Commodities are tangible assets used to manufacture and produce goods or services. Various risk factors, including disease, storage capacity, supply and demand, delivery constraints, and weather, influence their prices. Because of those risk factors, even a well-diversified commodity investment can be uncertain. Money Market Funds Money market funds invest in high-quality, short-term debt securities, pay dividends that generally reflect short-term interest rates, and seek to maintain a stable net asset value (NAV) per share (typically $1). Although a money market fund is managed to maintain a stable NAV of $1 per share, the fund’s value may fluctuate, and you could lose money. In addition, a money market fund investment is not insured by the Federal Deposit Insurance Corporation or any other government agency. Cryptocurrencies Cryptocurrencies, including Bitcoin and Ethereum, are currently unregulated, illiquid, and uninsured. They carry technological risks, require unique tax treatment, and are generally much more volatile than traditional currencies. Mutual funds and ETFs whose values are directly or indirectly linked to one or more cryptocurrencies carry many of these risks. Mutual Funds Mutual funds carry the risk of capital loss; thus, an investor may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be a bond of a “fixed income” nature (lower risk) or a stock of an “equity” nature. Equity (Stocks) Equity investing involves buying shares of stock in exchange for future dividends and capital gains if the stock’s value increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions, and the general economic environment. Non-US Securities Non-US securities present certain risks, including currency fluctuations, political and economic changes, social unrest, changes in government regulation, accounting differences, and a lower level of publicly available information. Precious Metal ETFs Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion- backed “electronic shares,” not physical metal) may be negatively impacted by several factors, among them: Exchange-Traded Funds (ETFs) An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock-holding bankruptcy). Areas of concern include limited product transparency, increasing complexity, conflicts of interest, and Page 10 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  • Large sales by the official sector, which owns a significant portion of gold and other precious metals, aggregate world holdings • A substantial increase in hedging activities by gold or other D. Other Risk Factors Cybersecurity Risk We conduct periodic cybersecurity assessments and testing of our systems and controls as part of our ongoing risk management program. precious metals producers • A significant change in the attitude of speculators and investors Real Estate Funds (REITs) We rely on digital technologies to conduct our business and to implement safeguards designed to protect our systems and data from disruptions, unauthorized access, and cyber incidents. Despite these measures, our systems, networks, and devices remain subject to potential breaches and operational disruptions. Cyber incidents may include unauthorized access to systems, data corruption, service interruptions, and denial-of-service attacks. Such events could result in financial loss, reputational damage, regulatory scrutiny, or an inability to conduct business, and may adversely affect both our firm and our clients. These funds (including REITs) face several inherent risks in the real estate sector, which has historically experienced significant performance fluctuations and cycles. Revenues and cash flows may be adversely affected by changes in local real estate market conditions due to changes in national or local economic conditions or changes in regional property market characteristics; competition from other properties offering the same or similar services; changes in interest rates, and the state of the debt and equity credit markets; the ongoing need for capital improvements; changes in real estate tax rates and other operating expenses; adverse changes in governmental rules and fiscal policies; adverse changes in zoning laws; the impact of present or future environmental legislation and compliance with environmental regulations. Hypothetical Projections When helping you determine a target investment asset allocation to meet your financial goals, we use the Monte Carlo method. This method uses repeated random-sampling simulations to estimate the probability of outcomes based on historical market performance, return sequences, and estimated cash flows. Our future goal projections are hypothetical, do not reflect actual investment results, and do not ensure future results. Our reporting provides further information regarding the methodology, limitations, and assumptions. The above risk factors are not a complete list or explanation of the risks involved in an investment. For more information on the risks associated with any investment, analysis method, or investment approach, please ask your investment adviser at Optima Capital Management LLC. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as the client, should be prepared to bear. Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. Stable Value Funds The objective of stable value funds is to provide the safety of principal and an investment return generally higher than a money market return while allowing retirement plan participants to withdraw their assets for ordinary transactions at book value rather than market value. Stable value funds are subject to the counterparty risk of the insurers that provide the fund’s book value liquidity. However, the ability to withdraw stable-value assets at book value is limited by the insurance contracts that wrap the underlying assets. Also, most stable value funds have a hold period before the retirement plan sponsor can withdraw assets from the fund at book value. The fund may also refuse to honor book-value withdrawals if it finds that communications from the plan sponsor or plan fiduciaries caused participants to withdraw their funds. Additionally, the plan is often restricted from offering investment alternatives or plans that are viewed as competitive with the stable value it offers. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-Regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Venture Capital Funds Investments in venture capital funds are typically highly illiquid, speculative, and involve a significant risk of loss. In addition, these funds may invest in early-stage companies with narrow product lines and small market shares, which tend to be more vulnerable to competitors’ actions and to business, economic, and market conditions than more mature companies. The percentage of venture capital-backed and early-stage companies that survive and prosper can be small. The success of such companies often depends on proprietary technology used in their products and services, which may expose them to intellectual property disputes. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker-Dealer or Broker-Dealer Representative Neither Optima Capital Management LLC nor our associates are registered as broker-dealers or broker-dealer representatives, nor do they have pending applications to become registered as such. Page 11 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  You may request our Code of Ethics without charge by contacting Jonathan Elliott at jonathan_elliott@optimacapitalmgt.com or 480-776-1770. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither Optima Capital Management LLC nor our representatives are registered as, or have pending applications to become, either a Futures Commission Merchant, Commodity Pool Operator, Commodity Trading Advisor, or an associated person of any of the foregoing. B. Recommendations Involving Material Financial Interests We do not recommend that clients buy or sell any security in which a related person to Optima Capital Management LLC or to us, as a firm, has a material financial interest. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests 1. Jonathan Elliott holds an insurance license from the State of Arizona. Although Mr. Elliott is not currently affiliated with an insurance company, he may, from time to time, advise clients residing in Arizona on insurance planning and fee- based insurance products. Mr. Elliott does not receive commissions for selling insurance or other investment products to the Firm’s clients. C. Investing Personal Money in the Same Securities as Clients Our associates may buy or sell securities for their own accounts that they also recommend to our clients from time to time. These transactions may allow associates to buy or sell the same securities before or after recommending the same securities to clients, resulting in associates profiting from the recommendations they provide to clients. Such transactions may create a conflict of interest. We will document any transactions that could pose a potential conflict of interest. We will not trade to the client’s disadvantage when similar securities are bought or sold. Item 12: Brokerage Practices A. How We Select Custodians and Broker-Dealers We will recommend custodians and other broker-dealers that will hold your assets and execute transactions. 2. Todd Bendell serves as a General Partner for Amphibian Capital. Mr. Bendell’s role is to manage the associates responsible for the Firm’s operations and secure funding for its growth. Mr. Bendell receives compensation for his role outside of the Firm. The fund is entirely separate from the advisory services provided by Optima Capital Management LLC. Clients of Optima Capital Management LLC are not solicited or permitted to invest in the fund. There is no sharing of client information between the Firm and the fund, and no conflicts are expected to arise from this affiliation. D. Selection of Other Advisors or Managers and How This Adviser is Compensated for Those Selections Optima Capital Management LLC does not receive compensation for recommending or selecting other investment advisers for clients. We have a duty to seek “best execution,” which is the obligation to seek execution of securities transactions for you on the most favorable terms under the circumstances. You will not necessarily pay the lowest commission or commission equivalent. Furthermore, we will not charge a premium or commission on transactions beyond the cost imposed by the custodian or broker-dealer. In addition, we consider the following factors when making a recommendation for a custodian or broker-dealer. • Availability of investment research, including but not limited to access to written research, oral communication with analysts, admittance to research conferences, and other tools provided that may assist us in making investment decisions Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics Our written Code of Ethics outlines the professional standards of conduct for our associates. Our goal is to protect your interests and demonstrate our commitment to our fiduciary duties of honesty, good faith, and fair dealing with you. All associates are expected to understand and strictly follow these guidelines in the following areas: • Breadth of available investment products such as stocks, bonds, mutual funds, and exchange-traded funds (ETFs) • Capability to execute, clear, and settle trades (buy and sell securities for your account) • Capability to facilitate transfers and payments to and from accounts with wire transfers, check requests, and bill payment • Combination of transaction execution services and asset custody services without a separate fee for custody • Competitiveness of the price of those services (commission rates, margin interest rates, and other fees) and willingness to negotiate the prices Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Impartial Conduct Standards for Individual Retirement Account (IRA) Rollovers, Prohibited Activities, Conflicts of Interest, Gifts, and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. • Prior service to our clients and us Page 12 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  • Quality of services • Reputation, financial strength, security, and stability • Services delivered or paid for by the custodian or broker- dealer will be reviewed periodically to ensure that this policy does not systematically disadvantage any accounts. Finally, we will determine the appropriate number of shares and select the custodian that provides brokerage services consistent with our duty to seek best execution, except for accounts with specific brokerage directions. We maintain relationships with multiple approved custodians and broker-dealers. We may utilize any of the following custodians based on client needs, although not all custodians and broker-dealers listed may currently hold client assets: ADP Broker-Dealer, Inc. (“ADP”) Ascensus Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews Jonathan Elliott, Managing Partner and Chief Compliance Officer, will review client portfolios at least annually and on an ongoing basis. We consider your respective investment policy and risk tolerance when performing these reviews. Jackson National StanCorp Investment Advisors (“Standard”) • • • Charles Schwab (“Schwab”) • Guideline • • Brokerage for Client Referrals We do not receive referrals from a custodian, broker-dealer, or third party in exchange for using that custodian, broker-dealer, or third party. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market activity, economic or political events, or changes in your financial situation (such as retirement, termination of employment, physical move, or inheritance). C. Content and Frequency of Regular Reports Provided to Clients Our clients will receive a monthly or quarterly report detailing your account or portfolio, including assets held, asset value, and calculation of fees. Your custodian will provide this written report. Clients Directing Which Custodian or Broker-Dealer to Use We require clients to maintain assets with custodians or broker- dealers with whom we have an established relationship and whom we have approved for use. As a result, clients may not direct brokerage to other custodians. As such, we may be unable to achieve the most favorable execution of your transactions, and you may pay higher brokerage commissions than you might otherwise pay through another broker-dealer that offers the same types of services. Not all advisers require their clients to utilize direct brokerage. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients We do not receive any economic benefit, directly or indirectly, from any third party for advice that we provide to our clients. Research and Other Soft-Dollar Benefits We do not participate in a formal soft-dollar program; however, we receive research, products, and services from custodians and broker-dealers that qualify under Section 28(e) of the Securities Exchange Act of 1934. These research products and services may include investment research, market data, and analytical tools that assist us in managing client accounts. We benefit from these arrangements because we do not have to produce or pay for these services ourselves. However, we receive benefits from support products and services provided when clients maintain their accounts with certain custodians we may recommend. Under these arrangements, you do not pay more for assets held with these custodians. We benefit from these arrangements because we would otherwise pay the cost of these services, which may result in a conflict of interest when you select a custodian. The following are the products and services provided by our custodians, how they benefit us, and potential conflicts of interest. These arrangements create a conflict of interest because they incentivize us to recommend custodians or broker-dealers that offer such benefits. There is no assurance that any client will benefit from the research or services received, even if the client’s transactions generated the benefits. ADP We do not currently participate in ADP’s institutional advisor program. Ascensus We do not currently participate in Ascensus’s institutional advisor program. Charles Schwab Schwab Advisor Services (“Schwab”) is a division of Charles B. Aggregating (Block) Trading for Multiple Client Accounts If we buy or sell the same securities on behalf of more than one client, we may (but are under no obligation to) aggregate such securities into a single transaction for multiple clients to obtain more favorable prices, lower brokerage commissions, or more efficient execution. In such a case, we would place an aggregate order with the custodian, which provides brokerage services on behalf of all such clients, to ensure fairness for all clients. Trades Page 13 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  of these services or pays all or part of a third party’s fees. Schwab & Co., Inc. Member FINRA/SIPC. Charles Schwab & Co., Inc. is an independent and unaffiliated SEC-registered broker- dealer. Schwab also provides us with other benefits, such as occasional business entertainment for our associates. If you did not maintain your assets with Schwab, we would be required to pay for these services using our own resources. Schwab’s support services are available to independent investment advisors on an unsolicited basis, at no charge, so long as an investment adviser maintains client assets at Schwab. We are independently owned and operated and not an affiliate of Charles Schwab. Guideline We do not currently participate in Guideline’s institutional advisor program. Schwab does not charge for custody services for client accounts, but account holders compensate Schwab through commissions or other transaction-related or asset-based fees for securities trades. These transactions are executed through Schwab or settled into a Schwab account. Jackson National We do not currently participate in Jackson’s institutional advisor program. Standard We do not currently participate in the Standard’s institutional advisor program. Schwab provides our clients and us with access to institutional brokerage services for the execution of securities transactions, custody, and research, including advice, analyses, reports, and access to mutual funds and other investments that are generally available only to institutional investors or would otherwise require a significantly higher minimum initial investment. However, certain retail investors may be able to get institutional brokerage services from Schwab without going through us. B. Compensation to Non-Advisory Personnel for Client Referrals OCM does not directly or indirectly compensate any person who is not a supervised person of the Firm for client referrals. Schwab also provides products and services that benefit us but may not directly benefit you or your account. These products and services assist us in managing and administering our clients’ accounts and operating our Firm. They include investment research from both Schwab and third parties. We use this research to service all or a substantial number of our client accounts, including accounts not maintained at Schwab. Item 15: Custody When we deduct advisory fees directly from your qualified custodian’s accounts, we will have limited custody solely for the purpose of deducting advisory fees. We must have your written authorization as the client to proceed. You will receive account statements from the custodian, and we recommend that you review those statements for accuracy. In addition, Schwab makes available software and other technology to help us with the following activities: • Assistance with back-office training and support functions • Facilitate payment of our fees from its clients’ accounts • Facilitate trade execution and, if applicable, allocation of aggregated trade orders for multiple client accounts Item 16: Investment Direction Portfolio Management We provide discretionary investment advisory services to our clients. The Investment Agreement established with each client outlines our discretionary authority for trading. • Provide investment research, pricing information, and other market data • Recordkeeping and client reporting • Software and other technology that allows access to client account data, such as trade confirmations and account statements Where you have granted us investment discretion, we generally manage the account and make investment decisions without your consultation as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought or sold, what securities to buy or sell, or the price per share. Schwab also offers the following services. In certain instances, conditions imposed by you as the client (in investment guidelines or objectives or your instructions otherwise provided) may limit our discretionary ability to make these determinations. • Educational conferences and events • Consulting on technology and business needs • Consulting on legal and related compliance needs • Publications and conferences on practice management • Access to employee benefits providers, human capital consultants, and insurance providers • Marketing consulting and support Retirement Plan Services When providing Retirement Plan Services as a 3(38) fiduciary, we exercise discretionary authority or control over the investments specified in the Agreement. This discretionary authority is granted explicitly to us by the Sponsor, as defined in the Retirement Plan Services Agreement. Furthermore, Schwab provides some of these services itself. In other cases, it will arrange for third-party vendors to provide the services to us. Schwab also discounts or waives its fees for some Page 14 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026  Item 17: Voting Client Securities We will not ask for or accept voting authority for client securities. Clients will receive proxies directly from the security issuer or the custodian. We ask that clients direct all proxy questions to the security issuer. Item 18: Financial Information A. Balance Sheet We neither require nor solicit prepayment of more than $1200 in fees per client six months or more in advance, and therefore, it is not necessary to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Registered investment advisers are required to provide specific financial information or disclosures about their firms. We have no financial obligations that would impair our ability to meet our contractual and fiduciary commitments to clients. C. Bankruptcy Petitions in Previous Ten Years We have not been the subject of a bankruptcy petition in the last ten years. Page 15 of 15 Optima Capital Management LLC - Firm Brochure as of 4/22/2026