Overview

Assets Under Management: $144 million
High-Net-Worth Clients: 5
Average Client Assets: $27.1 million

Frequently Asked Questions

PRIVATE LANE CAPITAL, LLC charges 2.00% on the first $0 million, 1.25% on the next $2 million, 1.00% on the next $5 million, 0.75% on all assets according to their SEC Form ADV filing. See complete fee breakdown ↓

Yes. As an SEC-registered investment advisor (CRD #124999), PRIVATE LANE CAPITAL, LLC is subject to fiduciary duty under federal law.

PRIVATE LANE CAPITAL, LLC serves 5 high-net-worth clients according to their SEC filing dated April 06, 2026. View client details ↓

According to their SEC Form ADV, PRIVATE LANE CAPITAL, LLC offers portfolio management for individuals. View all service details ↓

PRIVATE LANE CAPITAL, LLC manages $144 million in client assets according to their SEC filing dated April 06, 2026.

According to their SEC Form ADV, PRIVATE LANE CAPITAL, LLC serves high-net-worth individuals. View client details ↓

Services Offered

Services: Portfolio Management for Individuals

Fee Structure

Primary Fee Schedule (PRIVATE LANE CAPITAL, LLC - 2025 ADV PART 2 - BROCHURE.PDF (FILED MARCH 31, 2026))

MinMaxMarginal Fee Rate
$0 $500,000 2.00%
$500,001 $2,000,000 1.25%
$2,000,001 $5,000,000 1.00%
$5,000,001 and above 0.75%
Illustrative Fee Rates
Total AssetsAnnual FeesAverage Fee Rate
$1 million $16,250 1.62%
$5 million $58,750 1.18%
$10 million $96,250 0.96%
$50 million $396,250 0.79%
$100 million $771,250 0.77%

Clients

Number of High-Net-Worth Clients: 5
Percentage of Firm Assets Belonging to High-Net-Worth Clients: 94.21%
Average Client Assets: $27.1 million
Total Client Accounts: 12
Discretionary Accounts: 12
Minimum Account Size: $500,000
Note on Minimum Client Size: $500,000

Regulatory Filings

CRD Number: 124999
Filing ID: 2091773
Last Filing Date: 2026-04-06 09:24:19

Form ADV Documents

Additional Brochure: PRIVATE LANE CAPITAL, LLC - 2025 ADV PART 2 - BROCHURE.PDF (2026-04-01)

View Document Text
Private Lane Capital, LLC 251 Crandon Blvd * Unit 1204 Key Biscayne, Florida 33149 www.privatelanecapital.com Item 1. FORM ADV PART 2-BROCHURE March 31, 2026 “This brochure provides information about the qualifications and business practices of Private Lane Capital, LLC. If you have any questions about the contents of this brochure, please contact us at (703) 679-7394 and/or paul@privatelanecapital.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” Additional information about Private Lane Capital, LLC may also is available on SEC’s website at http://www.adviserinfo.sec.gov/ Private Lane Capital, LLC is an investment adviser registered with the United States Securities and Exchange Commission. Registration does not imply a certain level of skill or training. Contact: Paul Di Biasio paul@privatelanecapital.com (703) 679-7394 Item 2. MATERIAL CHANGES This brochure updates only material changes that have occurred since the last amended filing on April 25, 2025 Items changed, deleted or updated. 1. Change in principal office location Private Lane Capital, LLC has relocated its principal office from Annandale, Virginia to Key Biscayne, Florida. 2. Change in regulator In connection with the firm’s growth and assets under management exceeding $100 million, Private Lane Capital, LLC is now registered with the U.S. Securities and Exchange Commission rather than with a state securities authority. 3. Updated regulatory disclosures The firm has updated its disclosure brochure to reflect SEC registration and to remove references applicable only to state-registered investment advisers. 4. Part 2A – Item 4 “assets under management “ changed from $128.77 to $144.23 million dollars. Please Note: There have been no material changes to the firm’s investment strategies, fee schedule, disciplinary history, or ownership structure. Some text throughout this document has been updated for clarity. Item 3. TABLE OF CONTENTS ITEM 1. FORM ADV PART 2-BROCHURE.................................................................................................................1 ITEM 2. MATERIAL CHANGES.................................................................................................................................2 ITEM 3. TABLE OF CONTENTS.................................................................................................................................3 ITEM 4. ADVISORY BUSINESS.................................................................................................................................4 ITEM 5. FEES AND COMPENSATION.......................................................................................................................5 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT...............................................................7 ITEM 7. TYPES OF CLIENTS......................................................................................................................................7 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS.....................................................7 ITEM 9. DISCIPLINARY INFORMATION..................................................................................................................10 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS................................................................10 ITEM 11. CODE OF ETHICS....................................................................................................................................10 ITEM 12. BROKERAGE PRACTICES.........................................................................................................................12 ITEM 13. REVIEW OF ACCOUNTS..........................................................................................................................13 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION..................................................................................13 ITEM 15. CUSTODY...............................................................................................................................................13 ITEM 16. INVESTMENT DISCRETION.....................................................................................................................14 ITEM 17. VOTING CLIENT SECURITIES...................................................................................................................15 ITEM 18. FINANCIAL INFORMATION.....................................................................................................................15 Item 4. ADVISORY BUSINESS Private Lane Capital, LLC provides discretionary investment advisory services by making in- vestment decisions for separately-managed client portfolios. The Firm primarily invests in eq- uity securities of U.S. and international companies but may also invest in other types of securi- ties, including options, fixed income instruments, exchange-traded funds, and private placement securities where appropriate. Unless otherwise directed by a client, portfolios are generally man- aged on a long-only basis without the use of leverage. The Firm does not limit its investment advice to any specific type of security and may utilize a variety of investment types and strategies based on each client’s objectives and market condi- tions. Client assets are held by independent, third-party custodians selected by the client and unaffili- ated with the Firm. For appropriate accounts, we may use stock options as a means of generating income and manag- ing risk, including the use of covered calls, cash-secured puts, and option spreads. The use of options involves risks that are different from, and in some cases greater than, the risks associated with investing directly in equity securities. These risks include, among others, the risk of assign- ment, leverage risk, liquidity risk, and the potential for significant loss over a short period of time. Options strategies may not be suitable for all clients and are employed only when deemed appropriate in light of a client’s investment objectives and financial circumstances. The Firm’s objective for each portfolio is long-term capital appreciation. Portfolio selection is based primarily on technical analysis, including the evaluation of price trends, relative strength, money-flows and trading patterns; and may also incorporate fundamental valuation, market con- ditions, and company-specific considerations. Portfolio allocations may change over time, in- cluding adjustments based on market capitalization The Firm does not provide financial planning or commodity trading advice and does not participate in wrap fee programs. The Firm may customize portfolio strategies to include private placement securities, fixed in- come securities, and preferred or convertible securities where appropriate. Clients investing in private placement securities must meet applicable eligibility requirements, including being a qualified investor as defined under applicable securities laws. Investments in private placement securities are subject to an additional fee as described in Item 5. Valuations of private placement securities are based on information reasonably available to the Firm at the time, including purchase price, subsequent third-party transactions, and other events we deem material. Because such securities are illiquid and not publicly traded, valuations are in- herently subjective and may differ materially from the value that could be realized in an actual transaction. For clients whose investment objectives emphasize income and capital preservation, the Firm may focus on investments in mature companies with consistent dividend histories, including companies represented in indices such as the Standard and Poor’s 500 or Russell 1000. Clients may impose reasonable restrictions on the management of their accounts, including re- strictions on:  specific securities  types of transactions (e.g., short sales or options)  securities listed on non-U.S. exchanges All client-imposed restrictions must be provided in writing. Private Lane Capital, LLC was founded in 1999 and is 100% employee-owned. As of year end December 31, 2025, we managed portfolios for 12 clients on a discretionary ba- sis with regulatory assets under management of approximately $144.23 million. Management History Private Lane Capital, LLC; has been in business since 1999 but did not engage in investment advisory services between 2006 and 2012. The sole owner of the Firm is: Paul Di Biasio Ownership Percentage: 100 Education: Emory University – Goizueta Business School – BBA Accounting Item 5. FEES AND COMPENSATION Private Lane Capital, LLC’s sole source of compensation is investment advisory fees based on a percentage of assets under management, as described below: Account Size Annual Fee First $250,000 to $500,000 2.00% $500,001 to $2,000,000 1.25% $2,000,001 to $5,000,000 1.00% Over $5,000,000 0.75%  Fees are based on the market value of assets under management, including cash and cash equivalents, as of the date of calculation.  Accounts under $500,000 are generally charged a fee of 2.00%.  For clients with segregated custodial accounts invested solely in fixed income securities, a fee of 0.30% may be charged.  Private placement securities that are restricted as to resale are subject to an additional fee of 1.25%, based on the capital invested or the most recent valuation, whichever is lower.  When a client maintains multiple accounts with the Firm, those accounts may be aggre- gated for purposes of fee calculation.  There is no minimum account size for active duty or retired military personnel, and such clients may receive reduced or waived fees, including a 0% fee on the first $250,000 in assets.  Fees are negotiable at the Firm’s discretion based on factors such as account size, rela- tionship scope, and other relevant considerations. Billing Practices Advisory fees are generally billed quarterly in advance, based on the value of assets under management at the beginning of the billing period. In certain cases, such as institutional relation- ships, fees may be billed in arrears as agreed upon in writing. Clients are invoiced directly for advisory fees. The Firm does not deduct fees from client ac- counts. Either the Firm or the client may terminate the advisory relationship upon 30 days’ written no- tice. Upon termination, any prepaid fees will be refunded on a pro rata basis. Additional Fees and Expenses In addition to the Firm’s advisory fees, clients may incur other fees and expenses associated with their accounts, including but not limited to:  Custodial fees  Brokerage commissions or transaction charges  Exchange fees  Mutual fund or ETF expenses  Other fees associated with securities transactions These fees are not paid to the Firm. Clients should be aware that investments in mutual funds, exchange-traded funds, or other pooled investment vehicles involve additional advisory or management fees charged by the managers of those investments. As a result, clients may incur multiple layers of fees. Compensation Disclosure The Firm does not receive compensation for the sale of securities or other investment products and does not receive commissions, referral fees, or other third-party compensation in connection with its advisory services.We bill our investment advisory fees on a calendar quarterly basis. Clients must pay these fees in advance of services rendered, except that larger institutional ac- counts may pay in arrears for services rendered, depending on contractual agreement. Contract terminations can occur at the option of us or the client and are generally effective upon receipt of 30 days’ written notice. In the event of termination, prepaid fees are refundable on a pro rata ba- sis. Item 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance-based fees and therefore have no side-by-side management con- flict of interests. Item 7. TYPES OF CLIENTS Our current clients include high net-worth individuals, families and profit-sharing plans; but we will accept corporations or other business entities; charitable organizations; trusts and estates. We require a $500,000 minimum for opening and maintaining an account. We will accept smaller asset amounts where the sum of the related accounts exceeds our stated minimum. There is no minimum account balance for active duty and retired military personnel. Item 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS In building our portfolios, we screen securities based on both technical and fundamental charac- teristics including  Relative Strength  Basing patterns  Abnormal Volume and price spikes  Liquidity  Growth in top line sales  Comparative Price to cash flows  Financial sustainability. We do not rely on any specific factor in determining the present or future value of any security and the factors considered may vary from investment to investment. Our opinion with respect to a particular security may be contrary to the general market and as of- ten the case when buying “basing patterns”. We buy securities of large, medium, small and mi- cro-capitalization companies. While over the long-term horizon small-cap stocks have outper- formed larger-cap stocks, in the short-term small-cap investments may suffer greater price de- clines during times of turmoil. Smaller-cap stocks are on the whole more illiquid than larger-cap stocks, resulting in a longer time period over which they may be purchased and sold without in- fluencing the price of the stock. Since we seek above-average growth opportunities, we are more likely to invest in businesses of newer companies or turnaround situations. We attempt to man- age risk through diversification of investments in markets and securities and limit the size of any one position within the portfolio. Our emerging market equity strategy might be subject to greater volatility than our modified global equity strategy because of the inherent greater volatil- ity of the emerging market asset class. Irrespective of this, investing in securities may always in- volve risk of loss that each client should be prepared to bear. We do not generally sell securities at times when markets are declining. Rather, we are likely to be a buyer during such times in or- der to take advantage of relatively cheap prices of stocks if they have long-term appreciation po- tential. We attempt to implement our investment strategy on a long-term time basis with the goal of seeking long term capital gain tax treatment. We do not use trading or short-term strategies to achieve our investment goals. Any short-term trading is likely to result from a new investment that has either performed beyond our expectations or the original reason for investing no longer exists (i.e. news event or a fact that was inadvertently overlooked). When we invest in international companies, we will usually focus on ADRs (American Deposi- tory Receipts) or country specific ETF’s (Exchange traded funds) . When we find opportunities in smaller companies, we may need to execute transactions on local stock exchanges in a number of emerging market countries. Some of these local stock markets are not as robust or developed as those in the U.S., resulting in companies being less well known and less followed by the in- vesting community. Emerging markets are also subject to events that might impact local markets and about which we from afar might have less understanding. In order to dissuade short-term investors, emerging market governments might impose a tax or other transaction fee for an investment made for shorter than six months. We always pur- chase securities with the intention of holding them for the long term. When we invest in companies on foreign local stock exchanges, we are taking on two risks: (1) the security risk and (2) the currency risk. This raises the possibility that both the stock could decrease in value and that the local currency could weaken against the dollar. In some situations and for some clients we may be able to hedge against the currency risk. We do not generally hedge currency risk as we believe the lack of depth of the currency markets in most emerging market countries renders this expensive and inefficient. We do, however, care- fully consider currency trends as part of our fundamental analysis of each international security, serving in some cases as a potential risk and in some cases a benefit to the business. When clients authorize us to invest in private placement securities, each such investment is made on a deal-by-deal basis. We do not use a co-mingled fund. Risks attendant to private investments are:  Valuation. Private placement investments in privately-held companies cannot be priced on a daily basis. In valuing these investments, we begin with the price at which the secu- rity was purchased. Adjustments to this price are made only if there is a later independent third-party transaction at a different price or intervening event that we believe justifies an adjustment in the price. We have adopted policies and guidelines that we follow in mak- ing these determinations. Because of limitations on the information available to us, our  price adjustments may not reflect all events material to the private company and its secu- rities. Our price may not be the same price at which a third party may be willing to pur- chase or sell the same securities. Illiquidity. Private placement investments are restricted securities that do not have a read- ily available market. Clients holding private placement securities may not be able to dis- pose of these securities at any time of their choosing. Where a client’s investment in one or more private placement securities is to be liquidated at a time where no liquid public market exists for the securities, we may sometimes be able to identify eligible client or employee accounts which could purchase one or more of the securities. Such a sale and purchase could potentially involve a conflict of interest. When investments in private placement securities are liquidated for a client, to avoid any potential conflict of interest, we typically do not act as investment advisor with respect to the sale of the investments by the liquidating client, which must make its own investment decision. We will make available to such client any information we have with respect to the company of any such securities being liquidated.  Tax issue. Clients for whose accounts stock of certain small business companies are pur- chased may have the opportunity to benefit from certain favorable provisions of the fed- eral income tax laws. Our approach to investment decisions does not take into considera- tion these or other potential tax benefits to a particular individual. We may attempt to alert clients in our periodic reports when information we obtain may tend to support treat- ment of particular securities as qualified small business stock for federal income tax pur- poses. However, it is beyond the scope of our investment advisory services to determine whether the information available to us and/or relevant to any client’s tax treatment is complete or correct or applicable to any particular client’s situation. The timing of our re- ports may not enable a client to utilize any potential tax benefit with respect to a transac- tion in qualified small business stock. From time to time we may have the opportunity to obtain for you securities offered in an initial public offering [“IPO”]. In such cases we at- tempt to divide these opportunities in an equitable manner among clients. Because such opportunities typically arise under very short notice, we allocate the available amount of securities among accounts primarily based on (1) cash availability and (2) large enough position size. We monitor to whom IPOs are allocated in order to achieve an equitable distribution of these opportunities. So that clients always receive the benefit of these lim- ited opportunities, we prohibit employees from participating in IPOs. Investment Risks Disclosure - Investing in securities involves risk of loss that a client should be prepared to bear. An investor in any of the strategies managed by Private Lane Capital, LLC must understand and be willing to accept those risks, including the loss of a significant amount of any such investment in securities. Those risks include the risk of changes in economic and market conditions, the concentration of investments within a portfolio, and the volatility of secu- rities. Investing in securities involves risk of loss, including the possible loss of principal. There can be no assurance that any investment strategy will be successful or achieve its objec- tives. Item 9. DISCIPLINARY INFORMATION Private Lane Capital, LLC has never had a legal or disciplinary action filed against it. Item 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Private Lane Capital, LLC uses software and research developed by Di Biasio & Edgington, Inc (hereinafter “D&E”), an affiliated company, which Mr Di Biasio is founder and majority owner. Mr Edgington, a minority shareholder in D&E, is also a member of another investment business but this business is unaffiliated with Private Lane Capital, LLC. D&E provides investment research and analysis based on a proprietary software product. The product and services are sold to institutional money managers only. D&E does not manage any client portfolios. Mr Di Biasio’s operating of D&E Inc provides many benefits to Private Lane Capital, LLC in the form of software use, research, industry/client communication and investment idea flow. D&E does not take a significant amount of his time and attention for Mr. Di Biasio. There are no specific arrangements or agreement to rely upon D&E’s research and the applicant is free to, and does, rely upon other sources for investment strategies. All relationships between Private Lane Capital, LLC and others are done on an “arms-length” basis. If there are any conflicts that arise in the future, this document will be amended to reflect the conflict and each client will be notified and be given the opportunity to remove their assets under management. Clients are not required to utilize, purchase, or rely upon any products or services offered by Di Biasio & Edgington, Inc. The existence of this affiliation may present a potential conflict of interest; however, we seek to manage any such conflicts through disclosure and by acting in the best interests of our clients. Item 11. CODE OF ETHICS We have adopted a Code of Ethics that addresses securities-related conduct and focuses principally on the following: personal securities transactions insider trading gifts and political contributions confidentiality conflicts of interest      Participation in Client Transactions. An important part of our philosophy is that our employees, particularly our managers, invest alongside our clients. To this end, employees and our officers will regularly invest in the same securities that are purchased for client portfolios. There is no guarantee that the client portfolios will perform in line with any of the employees or officers portfolios. Transaction Priority Clients that designate a directed brokerage may suffer a performance penalty because of transaction priority and are not able to participate in more favorable aggregate pricing that results from combining several accounts into one transaction. Larger accounts and those able to participate in aggregate transactions will have priority over smaller directed accounts and at no time will two orders compete with one another in the marketplace. In the event that a transaction impacts the market price of the security, some client’s transactions may be delayed or cancelled. The effects of transaction priority is particularly relevant in thinly traded securities. The fact that any client receives a priority in a transactions does not guarantee a more favorable result or outcome. When you designate a particular broker to which your trades must be directed, you might not obtain the “best price” for that day. A manager or employee may purchase a given security before it is deemed suitable for purchase by clients solely based on each client’s investment profile. If a position is deemed suitable for a client, than purchases for that client will have priority over managers and employees. We may, in the ordinary course of business, buy or sell for clients publicly-traded securities in which one or more of us have an investment, such transactions will be made only on the merits of the underlying companies and without regard to our ownership. Occasionally an employee may invest in securities not owned by clients or other employees. Private Placements.  Eligible employees are allowed to participate in private placements alongside clients on the same terms and for the same price. Typically, at least one manager will invest along with client accounts in each purchase of private placement securities.    We attempt to allocate private placement investment opportunities in an equitable manner to client accounts that have authorized us to invest in private placements. The available securities are allocated among appropriate investment accounts generally on the basis of available cash. In some cases, at a subsequent date, additional or other securities of the same company may be made available to our clients and to eligible employees for the same or a different price and terms. When they are deemed appropriate investments, these securities are made available to the same and/or other clients and to eligible employees on the same ba- sis. Such “follow-on” investments may raise potential conflicts of interest among those investing in the first-offered securities and those investing in the subsequent follow-on in- vestments. We make decisions with respect to each investment without regard to the fact that other clients or eligible employees may have a different investment in the same or other securities of the same company. Irrespective of the above, we do not recommend investments in “follow-on” investments to client accounts subject to Employment Retirement Income Security Act of l974 [“ERISA”]. A copy of our Code of Ethics is available to clients and prospective clients upon request. Item 12. BROKERAGE PRACTICES Each client designates a broker and such designation depends upon the specific terms negotiated by the client with the broker. Use of a designated broker through which transactions are to be made, may result in commission rates are higher than what which might be obtainable if we had full discretion in the broker’s selection. In addition, we will not be able to include the clients who designate the broker in any aggregation of trades. For a client who designates a broker, we might not be able to ensure the most favorable execution of trades, resulting in higher transaction costs to the client. We do not use portfolio trading software that will facilitate a more equitable means of executing trades for our clients. The benefits of using portfolio trading software are only attainable when the manager can choose which broker gets used for a given trade and that all participating accounts can aggregate their orders to obtain more favorable pricing. Without employing this class of investment software, each decision to buy or sell must be manually executed using multiple brokerage interfaces. This manual process will create inequities in execution results and the aggregate of these inequities will not be tracked, monitored or reported. When we are asked by a prospective client to recommend a broker, we will recommend CHARLES SCHWAB & CO., INC. 3000 SCHWAB WAY WESTLAKE, TX 76262-8104 USA The use of Charles Schwab & Co, Inc (SCHW-NYSE) will allow us to use their online trading platform. SCHW does not currently charge commissions on equity transactions. There is no guarantee that SCHW will provide better execution of transactions. We are not affiliated with SCHW and we do not get compensated by SCHW for recommending them to our clients. Although we recommend SCHW, it is ultimately the prospective client’s choice on which brokerage firm to use. Although we recommend Charles Schwab & Co., Inc., clients are under no obligation to se- lect Schwab as their custodian and may choose another qualified broker or custodian. Research and Other Soft Dollar Benefits We pay for independent research with hard dollars and do not employ the use of “soft dollar ar- rangements” to pay for any services. Item 13. REVIEW OF ACCOUNTS Portfolio managers and other portfolio administration personnel generally work collaboratively on all portfolios. They review all portfolios as follows:  weekly for comparison of account performance with relevant benchmark[s]  periodically as a result of on-going responses to changes in prices and potential needs for rebalancing.  Flows of cash and security transactions are also monitored daily.  Written performance and accounting reports are generated for each client quarterly. These reports include, for the period indicated: o an asset summary report o an asset detail report o a capital gains and loss report o a transaction report including all purchases, sales, withdrawals, additions, and cor- porate actions o an income report including both interest and dividends  Every account is checked by internal staff against the account’s custodian statement for the same audit period to ensure the reconciliation of cash and holdings between our report and the custodian statement. Item 14. CLIENT REFERRALS AND OTHER COMPENSATION Private Lane Capital, LLC does not compensate or receive compensation from unaffiliated third- party solicitors or promoters for client referrals. The Firm may compensate certain supervised persons of the Firm, including investment adviser representatives, for business development activities, including introducing prospective clients to the Firm and assisting with client relationships. Such compensation is paid solely from the Firm’s advisory fees and does not result in any additional charge to clients. All such individuals are supervised persons of the Firm and are subject to the Firm’s compliance policies and procedures. The Firm does not receive any economic benefit from third parties for providing advisory ser- vices to clients. Item 15. CUSTODY We do not have custody of client assets. The brokerage firm or bank you appoint as custodian for will have custody of your assets. We do not have authority to withdraw funds or securities from client accounts, do not act as trustee or executor, and do not serve as power of attorney for client accounts. Your custodian will send, directly to you, monthly account statements, which we urge you to re- view carefully. We will send you quarterly account statements and we urge you to review your statement carefully and compare it with that from your custodian. In regard to private placement investments:  Our and your custodian statements might differ if your portfolio includes private place- ment securities, which some custodians do not price.  Our agents, such as our lawyers, may have possession of stock certificates pending con- summation of the closing and subsequent distribution of such certificates to your custo- dian or others. Item 16. INVESTMENT DISCRETION We have full discretion over the selection of securities and quantities to be bought and sold with- out obtaining prior client consent, except in the case of a non-discretionary client. In agreement with us, the client may limit our discretionary authority over your account[s]. These limitations generally relate to:    the exclusion of an asset class, such as private placement securities or fixed income; the minimum and/or maximum percentage amount of the account that may be committed to an asset class; and/or the maximum amount of the portfolio that may be invested at the time of purchase in any one security. The client may impose investment restrictions on your account by giving us written notice, and may change those restrictions by written notice, which notice is deemed effective upon our re- ceipt. Such investment restrictions could adversely affect the account’s performance. Because we invest in any given time period in a select group of holdings, purchase of a holding by an account will largely depend upon: the advisability of purchase at a particular time at a particular price, and the availability of cash in the portfolio at the same time.   Because of the variable factors of time, price, and availability of cash, each client will not neces- sarily own the same securities or the same securities in the same amount or same proportions as every other client. There are certain regulatory limitations on our discretion, particularly those dealing with the in- clusion of private placement securities and derivative securities in portfolios where the size of the portfolio and/or net worth of the client prohibit such investments. Clients give us investment discretion when they sign a client agreement with us. The first section of the client agreement explicitly gives us this investment discretion. The Agreement provides limitations on this discretion in Exhibit C of the Investment Advisory Agreement. [“Limitations on Discretionary Authority”]. The client gives us authority to invest in private placement secu- rities, by agreeing to an expanded investment discretion in the first section of the client agree- ment and by filling out the agreement’s Exhibit D [“Accredited Investor Representation”]. Item 17. VOTING CLIENT SECURITIES As specifically provided in our client agreements, we will not accept authority to vote proxies for individuals and individual-related accounts, except with respect to proxies of privately-held com- panies. Individual clients will receive proxies from publicly-held companies directly from their custodian brokerage or bank and may contact us with questions about a particular solicitation. Item 18. FINANCIAL INFORMATION Balance Sheet Disclosure Because we do not require prepayment of fees six months or more in advance, we are not re- quired in this brochure to include any financial statements for our most recent fiscal year. Financial Condition Disclosure We do not have, and do not know of, any financial condition of ours that is reasonably likely to impair our ability to meet our contractual commitments to you or other clients. Bankruptcy Disclosure We have not been the subject of a bankruptcy petition at any time during the past ten years. ADV Part 2B - Paul Di Biasio Item 1 – Cover Sheet Private Lane Capital, LLC Part 2B of Form ADV Brochure Supplement Paul Di Biasio 251 Crandon Blvd Unit 1204 Key Biscayne, Florida 33149 (703) 679-7394 March 31, 2026 This brochure supplement provides information about Paul Di Biasio that supplements the Private Lane Capital brochure. You should have received a copy of that brochure. Please contact Paul Di Biasio at (703) 679-7394 and/or paul@privatelanecapital.com if you did not re- ceive Private Lane Capital’s brochure or if you have any questions about the contents of this sup- plement. Additional information about Paul Di Biasio may also is available on the SEC’s Investment Advisor Public Disclosure website at http://www.adviserinfo.sec.gov/ ADV Part 2B - Paul Di Biasio Item 2 – Educational Background and Business Experience Mr. Di Biasio (year of birth 1959) graduated from the Emory University, Atlanta Georgia with a bachelor’s degree in business administration (BBA). Following his education, Mr. Di Biasio began his career as a public accountant with the firm Becker, Weinstein and Kaufmann, Washington DC. While employed as a public accountant, Mr. Di Biasio passed the Uniform Certified Public Accountant Exam and subsequently became a C.P.A. After several years as an accountant, Mr. Di Biasio became a registered representative for Johnston, Lemon & Co., Washington DC. This required Mr. Di Biasio to pass the Series 7 exam. In 1987, Mr. Di Biasio moved to Philadelphia PA and began working as an institutional salesman for Hopper Soliday & Co (at the time a NYSE Listed Company). This employment was to sell and support a software product that Mr. Di Biasio had authored while living in Virginia. In 1989, Mr. Di Biasio left Hopper Soliday and started his a new firm called Di Biasio & Edgington, Inc. D&E, Inc has continued to produce and market investment software to institutional money managers. ADV Part 2B - Paul Di Biasio Item 3 -Disciplinary Information Mr. Di Biasio does not have any disciplinary information to disclose. He has NOT been party to a) a criminal or civil action in a domestic, foreign or military court; b) an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency or any foreign financial regulatory authority; c) a self-regulatory proceeding; or d) any other proceeding in which a professional attainment, designation, or license was revoked. ADV Part 2B - Paul Di Biasio Item 4 – Other Business Activities Di Biasio & Edgington, Inc. Mr. Di Biasio is president, and owns a majority stake in the software company. Di Biasio & Eding- ton, Inc. Di Biasio & Edgington, Inc. sell a subscription service to institutional investors that pro- vides portfolio analysis using the firm proprietary technical analysis. From 1989 to 2008, the company authored and sold investment software. Although the product is no longer offered, existing client are still supported. The firm has 1 employee and has been in business since 1989. Mr. Di Biasio estimates that managing D&E, Inc. requires roughly 10% of his time. As a result of his efforts, Mr Di Biasio does not receive any commission or additional economic ben- efit from any outside parties and his compensation from D&E, Inc. is derived solely from the prof- itability of the company. Securities recommendations made by D&E, Inc. are not solely relied on by Private Lane Capital ,LLC. The clients of D&E, Inc. are notified that the firm or its principals or related entities may have positions in the companies that it references in company generated reports. ADV Part 2B - Paul Di Biasio Item 5 -Additional Compensation Mr. Di Biasio does not receive any additional economic benefit from third parties for providing advisory services. ADV Part 2B - Paul Di Biasio Item 6 – Supervision Since Mr. Di Biasio is the sole member/owner of Private Lane Capital, LLC, he does not have a direct supervisor. ADV Part 2B - Julio Lacayo Item 1 – Cover Sheet Private Lane Capital, LLC Part 2B of Form ADV Brochure Supplement Julio A. Lacayo 5075 Ute Lane Vail, Colorado 81657 March 31, 2026 This brochure supplement provides information about Julio Lacayo that supplements the Private Lane Capital brochure. You should have received a copy of that brochure. Please contact Paul Di Biasio at (703) 679-7394 and/or paul@privatelanecapital.com if you did not re- ceive Private Lane Capital’s brochure or if you have any questions about the contents of this sup- plement. Additional information about Julio Lacayo may also is available on the SEC’s Investment Advisor Public Disclosure website at http://www.adviserinfo.sec.gov/ Item 2 – Educational Background and Business Experience Mr. Lacayo (year of birth 1969) graduated from the Allegheny College with a BA in Economics and then in 2003 he earned a MBA at Georgetown University. Julio Lacayo passed the Series 65 (Uniform Investment Adviser Law Examination), which qualifies him to act as an investment adviser representative (IAR). CRD# 5981622 Business Background:  Private Lane Capital, LLC – Investment Adviser Representative (2026–Present) Fiduciary Trust International - Wealth Director (Nov 2021 – Fall 2024)   Truist Financial Corporation (formerly SunTrust Bank) - Wealth Advisor (Nov 2018 - Nov 2021)  Bank of America, N.A. - Sr WM Lending Officer – (Sept 2014 – Oct 2018)  Merrill Lynch ( division of Bank of America) – Private Client Advisor – (Sept 2014 – Oct 2018) Item 3 -Disciplinary Information Mr. Lacayo does not have any legal or disciplinary events to disclose. Item 4 – Other Business Activities Mr. Lacayo is not engaged in any other investment-related or non-investment-related business activities that would present a conflict of interest. He owns and manages a rental property held in Roseville, MN since 08/14. This endeavor takes approximately 1 hour a month, Item 5 -Additional Compensation Mr. Lacayo is compensated by Private Lane Capital, LLC for his services, which may include business development activities and assisting with client relationships. His compensation is derived from the Firm’s advisory fees. He does not receive any economic benefit from third parties for providing advisory services. Item 6 – Supervision Julio Lacayo is supervised by: Paul Di Biasio Managing Member Private Lane Capital, LLC (703) 679-7394 Private Lane Capital, LLC maintains supervisory procedures designed to monitor the activities of its investment adviser representatives and to ensure compliance with applicable securities laws and firm policies. Item 7 – Requirements for State-Registered Advisers Not applicable. Private Lane Capital, LLC is registered with the U.S. Securities and Exchange Commission.

Primary Brochure: PRIVATE LANE CAPITAL, LLC - 2025 ADV PART 2 - BROCHURE.PDF (FILED MARCH 31, 2026) (2026-04-01)

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Private Lane Capital, LLC 251 Crandon Blvd * Unit 1204 Key Biscayne, Florida 33149 www.privatelanecapital.com Item 1. FORM ADV PART 2-BROCHURE March 31, 2026 “This brochure provides information about the qualifications and business practices of Private Lane Capital, LLC. If you have any questions about the contents of this brochure, please contact us at (703) 679-7394 and/or paul@privatelanecapital.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” Additional information about Private Lane Capital, LLC may also is available on SEC’s website at http://www.adviserinfo.sec.gov/ Private Lane Capital, LLC is an investment adviser registered with the United States Securities and Exchange Commission. Registration does not imply a certain level of skill or training. Contact: Paul Di Biasio paul@privatelanecapital.com (703) 679-7394 Item 2. MATERIAL CHANGES This brochure updates only material changes that have occurred since the last amended filing on April 25, 2025 Items changed, deleted or updated. 1. Change in principal office location Private Lane Capital, LLC has relocated its principal office from Annandale, Virginia to Key Biscayne, Florida. 2. Change in regulator In connection with the firm’s growth and assets under management exceeding $100 million, Private Lane Capital, LLC is now registered with the U.S. Securities and Exchange Commission rather than with a state securities authority. 3. Updated regulatory disclosures The firm has updated its disclosure brochure to reflect SEC registration and to remove references applicable only to state-registered investment advisers. 4. Part 2A – Item 4 “assets under management “ changed from $128.77 to $144.23 million dollars. Please Note: There have been no material changes to the firm’s investment strategies, fee schedule, disciplinary history, or ownership structure. Some text throughout this document has been updated for clarity. Item 3. TABLE OF CONTENTS ITEM 1. FORM ADV PART 2-BROCHURE.................................................................................................................1 ITEM 2. MATERIAL CHANGES.................................................................................................................................2 ITEM 3. TABLE OF CONTENTS.................................................................................................................................3 ITEM 4. ADVISORY BUSINESS.................................................................................................................................4 ITEM 5. FEES AND COMPENSATION.......................................................................................................................5 ITEM 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT...............................................................7 ITEM 7. TYPES OF CLIENTS......................................................................................................................................7 ITEM 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS.....................................................7 ITEM 9. DISCIPLINARY INFORMATION..................................................................................................................10 ITEM 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS................................................................10 ITEM 11. CODE OF ETHICS....................................................................................................................................10 ITEM 12. BROKERAGE PRACTICES.........................................................................................................................12 ITEM 13. REVIEW OF ACCOUNTS..........................................................................................................................13 ITEM 14. CLIENT REFERRALS AND OTHER COMPENSATION..................................................................................13 ITEM 15. CUSTODY...............................................................................................................................................13 ITEM 16. INVESTMENT DISCRETION.....................................................................................................................14 ITEM 17. VOTING CLIENT SECURITIES...................................................................................................................15 ITEM 18. FINANCIAL INFORMATION.....................................................................................................................15 Item 4. ADVISORY BUSINESS Private Lane Capital, LLC provides discretionary investment advisory services by making in- vestment decisions for separately-managed client portfolios. The Firm primarily invests in eq- uity securities of U.S. and international companies but may also invest in other types of securi- ties, including options, fixed income instruments, exchange-traded funds, and private placement securities where appropriate. Unless otherwise directed by a client, portfolios are generally man- aged on a long-only basis without the use of leverage. The Firm does not limit its investment advice to any specific type of security and may utilize a variety of investment types and strategies based on each client’s objectives and market condi- tions. Client assets are held by independent, third-party custodians selected by the client and unaffili- ated with the Firm. For appropriate accounts, we may use stock options as a means of generating income and manag- ing risk, including the use of covered calls, cash-secured puts, and option spreads. The use of options involves risks that are different from, and in some cases greater than, the risks associated with investing directly in equity securities. These risks include, among others, the risk of assign- ment, leverage risk, liquidity risk, and the potential for significant loss over a short period of time. Options strategies may not be suitable for all clients and are employed only when deemed appropriate in light of a client’s investment objectives and financial circumstances. The Firm’s objective for each portfolio is long-term capital appreciation. Portfolio selection is based primarily on technical analysis, including the evaluation of price trends, relative strength, money-flows and trading patterns; and may also incorporate fundamental valuation, market con- ditions, and company-specific considerations. Portfolio allocations may change over time, in- cluding adjustments based on market capitalization The Firm does not provide financial planning or commodity trading advice and does not participate in wrap fee programs. The Firm may customize portfolio strategies to include private placement securities, fixed in- come securities, and preferred or convertible securities where appropriate. Clients investing in private placement securities must meet applicable eligibility requirements, including being a qualified investor as defined under applicable securities laws. Investments in private placement securities are subject to an additional fee as described in Item 5. Valuations of private placement securities are based on information reasonably available to the Firm at the time, including purchase price, subsequent third-party transactions, and other events we deem material. Because such securities are illiquid and not publicly traded, valuations are in- herently subjective and may differ materially from the value that could be realized in an actual transaction. For clients whose investment objectives emphasize income and capital preservation, the Firm may focus on investments in mature companies with consistent dividend histories, including companies represented in indices such as the Standard and Poor’s 500 or Russell 1000. Clients may impose reasonable restrictions on the management of their accounts, including re- strictions on:  specific securities  types of transactions (e.g., short sales or options)  securities listed on non-U.S. exchanges All client-imposed restrictions must be provided in writing. Private Lane Capital, LLC was founded in 1999 and is 100% employee-owned. As of year end December 31, 2025, we managed portfolios for 12 clients on a discretionary ba- sis with regulatory assets under management of approximately $144.23 million. Management History Private Lane Capital, LLC; has been in business since 1999 but did not engage in investment advisory services between 2006 and 2012. The sole owner of the Firm is: Paul Di Biasio Ownership Percentage: 100 Education: Emory University – Goizueta Business School – BBA Accounting Item 5. FEES AND COMPENSATION Private Lane Capital, LLC’s sole source of compensation is investment advisory fees based on a percentage of assets under management, as described below: Account Size Annual Fee First $250,000 to $500,000 2.00% $500,001 to $2,000,000 1.25% $2,000,001 to $5,000,000 1.00% Over $5,000,000 0.75%  Fees are based on the market value of assets under management, including cash and cash equivalents, as of the date of calculation.  Accounts under $500,000 are generally charged a fee of 2.00%.  For clients with segregated custodial accounts invested solely in fixed income securities, a fee of 0.30% may be charged.  Private placement securities that are restricted as to resale are subject to an additional fee of 1.25%, based on the capital invested or the most recent valuation, whichever is lower.  When a client maintains multiple accounts with the Firm, those accounts may be aggre- gated for purposes of fee calculation.  There is no minimum account size for active duty or retired military personnel, and such clients may receive reduced or waived fees, including a 0% fee on the first $250,000 in assets.  Fees are negotiable at the Firm’s discretion based on factors such as account size, rela- tionship scope, and other relevant considerations. Billing Practices Advisory fees are generally billed quarterly in advance, based on the value of assets under management at the beginning of the billing period. In certain cases, such as institutional relation- ships, fees may be billed in arrears as agreed upon in writing. Clients are invoiced directly for advisory fees. The Firm does not deduct fees from client ac- counts. Either the Firm or the client may terminate the advisory relationship upon 30 days’ written no- tice. Upon termination, any prepaid fees will be refunded on a pro rata basis. Additional Fees and Expenses In addition to the Firm’s advisory fees, clients may incur other fees and expenses associated with their accounts, including but not limited to:  Custodial fees  Brokerage commissions or transaction charges  Exchange fees  Mutual fund or ETF expenses  Other fees associated with securities transactions These fees are not paid to the Firm. Clients should be aware that investments in mutual funds, exchange-traded funds, or other pooled investment vehicles involve additional advisory or management fees charged by the managers of those investments. As a result, clients may incur multiple layers of fees. Compensation Disclosure The Firm does not receive compensation for the sale of securities or other investment products and does not receive commissions, referral fees, or other third-party compensation in connection with its advisory services.We bill our investment advisory fees on a calendar quarterly basis. Clients must pay these fees in advance of services rendered, except that larger institutional ac- counts may pay in arrears for services rendered, depending on contractual agreement. Contract terminations can occur at the option of us or the client and are generally effective upon receipt of 30 days’ written notice. In the event of termination, prepaid fees are refundable on a pro rata ba- sis. Item 6. PERFORMANCE-BASED FEES AND SIDE-BY-SIDE MANAGEMENT We do not charge performance-based fees and therefore have no side-by-side management con- flict of interests. Item 7. TYPES OF CLIENTS Our current clients include high net-worth individuals, families and profit-sharing plans; but we will accept corporations or other business entities; charitable organizations; trusts and estates. We require a $500,000 minimum for opening and maintaining an account. We will accept smaller asset amounts where the sum of the related accounts exceeds our stated minimum. There is no minimum account balance for active duty and retired military personnel. Item 8. METHODS OF ANALYSIS, INVESTMENT STRATEGIES AND RISK OF LOSS In building our portfolios, we screen securities based on both technical and fundamental charac- teristics including  Relative Strength  Basing patterns  Abnormal Volume and price spikes  Liquidity  Growth in top line sales  Comparative Price to cash flows  Financial sustainability. We do not rely on any specific factor in determining the present or future value of any security and the factors considered may vary from investment to investment. Our opinion with respect to a particular security may be contrary to the general market and as of- ten the case when buying “basing patterns”. We buy securities of large, medium, small and mi- cro-capitalization companies. While over the long-term horizon small-cap stocks have outper- formed larger-cap stocks, in the short-term small-cap investments may suffer greater price de- clines during times of turmoil. Smaller-cap stocks are on the whole more illiquid than larger-cap stocks, resulting in a longer time period over which they may be purchased and sold without in- fluencing the price of the stock. Since we seek above-average growth opportunities, we are more likely to invest in businesses of newer companies or turnaround situations. We attempt to man- age risk through diversification of investments in markets and securities and limit the size of any one position within the portfolio. Our emerging market equity strategy might be subject to greater volatility than our modified global equity strategy because of the inherent greater volatil- ity of the emerging market asset class. Irrespective of this, investing in securities may always in- volve risk of loss that each client should be prepared to bear. We do not generally sell securities at times when markets are declining. Rather, we are likely to be a buyer during such times in or- der to take advantage of relatively cheap prices of stocks if they have long-term appreciation po- tential. We attempt to implement our investment strategy on a long-term time basis with the goal of seeking long term capital gain tax treatment. We do not use trading or short-term strategies to achieve our investment goals. Any short-term trading is likely to result from a new investment that has either performed beyond our expectations or the original reason for investing no longer exists (i.e. news event or a fact that was inadvertently overlooked). When we invest in international companies, we will usually focus on ADRs (American Deposi- tory Receipts) or country specific ETF’s (Exchange traded funds) . When we find opportunities in smaller companies, we may need to execute transactions on local stock exchanges in a number of emerging market countries. Some of these local stock markets are not as robust or developed as those in the U.S., resulting in companies being less well known and less followed by the in- vesting community. Emerging markets are also subject to events that might impact local markets and about which we from afar might have less understanding. In order to dissuade short-term investors, emerging market governments might impose a tax or other transaction fee for an investment made for shorter than six months. We always pur- chase securities with the intention of holding them for the long term. When we invest in companies on foreign local stock exchanges, we are taking on two risks: (1) the security risk and (2) the currency risk. This raises the possibility that both the stock could decrease in value and that the local currency could weaken against the dollar. In some situations and for some clients we may be able to hedge against the currency risk. We do not generally hedge currency risk as we believe the lack of depth of the currency markets in most emerging market countries renders this expensive and inefficient. We do, however, care- fully consider currency trends as part of our fundamental analysis of each international security, serving in some cases as a potential risk and in some cases a benefit to the business. When clients authorize us to invest in private placement securities, each such investment is made on a deal-by-deal basis. We do not use a co-mingled fund. Risks attendant to private investments are:  Valuation. Private placement investments in privately-held companies cannot be priced on a daily basis. In valuing these investments, we begin with the price at which the secu- rity was purchased. Adjustments to this price are made only if there is a later independent third-party transaction at a different price or intervening event that we believe justifies an adjustment in the price. We have adopted policies and guidelines that we follow in mak- ing these determinations. Because of limitations on the information available to us, our  price adjustments may not reflect all events material to the private company and its secu- rities. Our price may not be the same price at which a third party may be willing to pur- chase or sell the same securities. Illiquidity. Private placement investments are restricted securities that do not have a read- ily available market. Clients holding private placement securities may not be able to dis- pose of these securities at any time of their choosing. Where a client’s investment in one or more private placement securities is to be liquidated at a time where no liquid public market exists for the securities, we may sometimes be able to identify eligible client or employee accounts which could purchase one or more of the securities. Such a sale and purchase could potentially involve a conflict of interest. When investments in private placement securities are liquidated for a client, to avoid any potential conflict of interest, we typically do not act as investment advisor with respect to the sale of the investments by the liquidating client, which must make its own investment decision. We will make available to such client any information we have with respect to the company of any such securities being liquidated.  Tax issue. Clients for whose accounts stock of certain small business companies are pur- chased may have the opportunity to benefit from certain favorable provisions of the fed- eral income tax laws. Our approach to investment decisions does not take into considera- tion these or other potential tax benefits to a particular individual. We may attempt to alert clients in our periodic reports when information we obtain may tend to support treat- ment of particular securities as qualified small business stock for federal income tax pur- poses. However, it is beyond the scope of our investment advisory services to determine whether the information available to us and/or relevant to any client’s tax treatment is complete or correct or applicable to any particular client’s situation. The timing of our re- ports may not enable a client to utilize any potential tax benefit with respect to a transac- tion in qualified small business stock. From time to time we may have the opportunity to obtain for you securities offered in an initial public offering [“IPO”]. In such cases we at- tempt to divide these opportunities in an equitable manner among clients. Because such opportunities typically arise under very short notice, we allocate the available amount of securities among accounts primarily based on (1) cash availability and (2) large enough position size. We monitor to whom IPOs are allocated in order to achieve an equitable distribution of these opportunities. So that clients always receive the benefit of these lim- ited opportunities, we prohibit employees from participating in IPOs. Investment Risks Disclosure - Investing in securities involves risk of loss that a client should be prepared to bear. An investor in any of the strategies managed by Private Lane Capital, LLC must understand and be willing to accept those risks, including the loss of a significant amount of any such investment in securities. Those risks include the risk of changes in economic and market conditions, the concentration of investments within a portfolio, and the volatility of secu- rities. Investing in securities involves risk of loss, including the possible loss of principal. There can be no assurance that any investment strategy will be successful or achieve its objec- tives. Item 9. DISCIPLINARY INFORMATION Private Lane Capital, LLC has never had a legal or disciplinary action filed against it. Item 10. OTHER FINANCIAL INDUSTRY ACTIVITIES AND AFFILIATIONS Private Lane Capital, LLC uses software and research developed by Di Biasio & Edgington, Inc (hereinafter “D&E”), an affiliated company, which Mr Di Biasio is founder and majority owner. Mr Edgington, a minority shareholder in D&E, is also a member of another investment business but this business is unaffiliated with Private Lane Capital, LLC. D&E provides investment research and analysis based on a proprietary software product. The product and services are sold to institutional money managers only. D&E does not manage any client portfolios. Mr Di Biasio’s operating of D&E Inc provides many benefits to Private Lane Capital, LLC in the form of software use, research, industry/client communication and investment idea flow. D&E does not take a significant amount of his time and attention for Mr. Di Biasio. There are no specific arrangements or agreement to rely upon D&E’s research and the applicant is free to, and does, rely upon other sources for investment strategies. All relationships between Private Lane Capital, LLC and others are done on an “arms-length” basis. If there are any conflicts that arise in the future, this document will be amended to reflect the conflict and each client will be notified and be given the opportunity to remove their assets under management. Clients are not required to utilize, purchase, or rely upon any products or services offered by Di Biasio & Edgington, Inc. The existence of this affiliation may present a potential conflict of interest; however, we seek to manage any such conflicts through disclosure and by acting in the best interests of our clients. Item 11. CODE OF ETHICS We have adopted a Code of Ethics that addresses securities-related conduct and focuses principally on the following: personal securities transactions insider trading gifts and political contributions confidentiality conflicts of interest      Participation in Client Transactions. An important part of our philosophy is that our employees, particularly our managers, invest alongside our clients. To this end, employees and our officers will regularly invest in the same securities that are purchased for client portfolios. There is no guarantee that the client portfolios will perform in line with any of the employees or officers portfolios. Transaction Priority Clients that designate a directed brokerage may suffer a performance penalty because of transaction priority and are not able to participate in more favorable aggregate pricing that results from combining several accounts into one transaction. Larger accounts and those able to participate in aggregate transactions will have priority over smaller directed accounts and at no time will two orders compete with one another in the marketplace. In the event that a transaction impacts the market price of the security, some client’s transactions may be delayed or cancelled. The effects of transaction priority is particularly relevant in thinly traded securities. The fact that any client receives a priority in a transactions does not guarantee a more favorable result or outcome. When you designate a particular broker to which your trades must be directed, you might not obtain the “best price” for that day. A manager or employee may purchase a given security before it is deemed suitable for purchase by clients solely based on each client’s investment profile. If a position is deemed suitable for a client, than purchases for that client will have priority over managers and employees. We may, in the ordinary course of business, buy or sell for clients publicly-traded securities in which one or more of us have an investment, such transactions will be made only on the merits of the underlying companies and without regard to our ownership. Occasionally an employee may invest in securities not owned by clients or other employees. Private Placements.  Eligible employees are allowed to participate in private placements alongside clients on the same terms and for the same price. Typically, at least one manager will invest along with client accounts in each purchase of private placement securities.    We attempt to allocate private placement investment opportunities in an equitable manner to client accounts that have authorized us to invest in private placements. The available securities are allocated among appropriate investment accounts generally on the basis of available cash. In some cases, at a subsequent date, additional or other securities of the same company may be made available to our clients and to eligible employees for the same or a different price and terms. When they are deemed appropriate investments, these securities are made available to the same and/or other clients and to eligible employees on the same ba- sis. Such “follow-on” investments may raise potential conflicts of interest among those investing in the first-offered securities and those investing in the subsequent follow-on in- vestments. We make decisions with respect to each investment without regard to the fact that other clients or eligible employees may have a different investment in the same or other securities of the same company. Irrespective of the above, we do not recommend investments in “follow-on” investments to client accounts subject to Employment Retirement Income Security Act of l974 [“ERISA”]. A copy of our Code of Ethics is available to clients and prospective clients upon request. Item 12. BROKERAGE PRACTICES Each client designates a broker and such designation depends upon the specific terms negotiated by the client with the broker. Use of a designated broker through which transactions are to be made, may result in commission rates are higher than what which might be obtainable if we had full discretion in the broker’s selection. In addition, we will not be able to include the clients who designate the broker in any aggregation of trades. For a client who designates a broker, we might not be able to ensure the most favorable execution of trades, resulting in higher transaction costs to the client. We do not use portfolio trading software that will facilitate a more equitable means of executing trades for our clients. The benefits of using portfolio trading software are only attainable when the manager can choose which broker gets used for a given trade and that all participating accounts can aggregate their orders to obtain more favorable pricing. Without employing this class of investment software, each decision to buy or sell must be manually executed using multiple brokerage interfaces. This manual process will create inequities in execution results and the aggregate of these inequities will not be tracked, monitored or reported. When we are asked by a prospective client to recommend a broker, we will recommend CHARLES SCHWAB & CO., INC. 3000 SCHWAB WAY WESTLAKE, TX 76262-8104 USA The use of Charles Schwab & Co, Inc (SCHW-NYSE) will allow us to use their online trading platform. SCHW does not currently charge commissions on equity transactions. There is no guarantee that SCHW will provide better execution of transactions. We are not affiliated with SCHW and we do not get compensated by SCHW for recommending them to our clients. Although we recommend SCHW, it is ultimately the prospective client’s choice on which brokerage firm to use. Although we recommend Charles Schwab & Co., Inc., clients are under no obligation to se- lect Schwab as their custodian and may choose another qualified broker or custodian. Research and Other Soft Dollar Benefits We pay for independent research with hard dollars and do not employ the use of “soft dollar ar- rangements” to pay for any services. Item 13. REVIEW OF ACCOUNTS Portfolio managers and other portfolio administration personnel generally work collaboratively on all portfolios. They review all portfolios as follows:  weekly for comparison of account performance with relevant benchmark[s]  periodically as a result of on-going responses to changes in prices and potential needs for rebalancing.  Flows of cash and security transactions are also monitored daily.  Written performance and accounting reports are generated for each client quarterly. These reports include, for the period indicated: o an asset summary report o an asset detail report o a capital gains and loss report o a transaction report including all purchases, sales, withdrawals, additions, and cor- porate actions o an income report including both interest and dividends  Every account is checked by internal staff against the account’s custodian statement for the same audit period to ensure the reconciliation of cash and holdings between our report and the custodian statement. Item 14. CLIENT REFERRALS AND OTHER COMPENSATION Private Lane Capital, LLC does not compensate or receive compensation from unaffiliated third- party solicitors or promoters for client referrals. The Firm may compensate certain supervised persons of the Firm, including investment adviser representatives, for business development activities, including introducing prospective clients to the Firm and assisting with client relationships. Such compensation is paid solely from the Firm’s advisory fees and does not result in any additional charge to clients. All such individuals are supervised persons of the Firm and are subject to the Firm’s compliance policies and procedures. The Firm does not receive any economic benefit from third parties for providing advisory ser- vices to clients. Item 15. CUSTODY We do not have custody of client assets. The brokerage firm or bank you appoint as custodian for will have custody of your assets. We do not have authority to withdraw funds or securities from client accounts, do not act as trustee or executor, and do not serve as power of attorney for client accounts. Your custodian will send, directly to you, monthly account statements, which we urge you to re- view carefully. We will send you quarterly account statements and we urge you to review your statement carefully and compare it with that from your custodian. In regard to private placement investments:  Our and your custodian statements might differ if your portfolio includes private place- ment securities, which some custodians do not price.  Our agents, such as our lawyers, may have possession of stock certificates pending con- summation of the closing and subsequent distribution of such certificates to your custo- dian or others. Item 16. INVESTMENT DISCRETION We have full discretion over the selection of securities and quantities to be bought and sold with- out obtaining prior client consent, except in the case of a non-discretionary client. In agreement with us, the client may limit our discretionary authority over your account[s]. These limitations generally relate to:    the exclusion of an asset class, such as private placement securities or fixed income; the minimum and/or maximum percentage amount of the account that may be committed to an asset class; and/or the maximum amount of the portfolio that may be invested at the time of purchase in any one security. The client may impose investment restrictions on your account by giving us written notice, and may change those restrictions by written notice, which notice is deemed effective upon our re- ceipt. Such investment restrictions could adversely affect the account’s performance. Because we invest in any given time period in a select group of holdings, purchase of a holding by an account will largely depend upon: the advisability of purchase at a particular time at a particular price, and the availability of cash in the portfolio at the same time.   Because of the variable factors of time, price, and availability of cash, each client will not neces- sarily own the same securities or the same securities in the same amount or same proportions as every other client. There are certain regulatory limitations on our discretion, particularly those dealing with the in- clusion of private placement securities and derivative securities in portfolios where the size of the portfolio and/or net worth of the client prohibit such investments. Clients give us investment discretion when they sign a client agreement with us. The first section of the client agreement explicitly gives us this investment discretion. The Agreement provides limitations on this discretion in Exhibit C of the Investment Advisory Agreement. [“Limitations on Discretionary Authority”]. The client gives us authority to invest in private placement secu- rities, by agreeing to an expanded investment discretion in the first section of the client agree- ment and by filling out the agreement’s Exhibit D [“Accredited Investor Representation”]. Item 17. VOTING CLIENT SECURITIES As specifically provided in our client agreements, we will not accept authority to vote proxies for individuals and individual-related accounts, except with respect to proxies of privately-held com- panies. Individual clients will receive proxies from publicly-held companies directly from their custodian brokerage or bank and may contact us with questions about a particular solicitation. Item 18. FINANCIAL INFORMATION Balance Sheet Disclosure Because we do not require prepayment of fees six months or more in advance, we are not re- quired in this brochure to include any financial statements for our most recent fiscal year. Financial Condition Disclosure We do not have, and do not know of, any financial condition of ours that is reasonably likely to impair our ability to meet our contractual commitments to you or other clients. Bankruptcy Disclosure We have not been the subject of a bankruptcy petition at any time during the past ten years. ADV Part 2B - Paul Di Biasio Item 1 – Cover Sheet Private Lane Capital, LLC Part 2B of Form ADV Brochure Supplement Paul Di Biasio 251 Crandon Blvd Unit 1204 Key Biscayne, Florida 33149 (703) 679-7394 March 31, 2026 This brochure supplement provides information about Paul Di Biasio that supplements the Private Lane Capital brochure. You should have received a copy of that brochure. Please contact Paul Di Biasio at (703) 679-7394 and/or paul@privatelanecapital.com if you did not re- ceive Private Lane Capital’s brochure or if you have any questions about the contents of this sup- plement. Additional information about Paul Di Biasio may also is available on the SEC’s Investment Advisor Public Disclosure website at http://www.adviserinfo.sec.gov/ ADV Part 2B - Paul Di Biasio Item 2 – Educational Background and Business Experience Mr. Di Biasio (year of birth 1959) graduated from the Emory University, Atlanta Georgia with a bachelor’s degree in business administration (BBA). Following his education, Mr. Di Biasio began his career as a public accountant with the firm Becker, Weinstein and Kaufmann, Washington DC. While employed as a public accountant, Mr. Di Biasio passed the Uniform Certified Public Accountant Exam and subsequently became a C.P.A. After several years as an accountant, Mr. Di Biasio became a registered representative for Johnston, Lemon & Co., Washington DC. This required Mr. Di Biasio to pass the Series 7 exam. In 1987, Mr. Di Biasio moved to Philadelphia PA and began working as an institutional salesman for Hopper Soliday & Co (at the time a NYSE Listed Company). This employment was to sell and support a software product that Mr. Di Biasio had authored while living in Virginia. In 1989, Mr. Di Biasio left Hopper Soliday and started his a new firm called Di Biasio & Edgington, Inc. D&E, Inc has continued to produce and market investment software to institutional money managers. ADV Part 2B - Paul Di Biasio Item 3 -Disciplinary Information Mr. Di Biasio does not have any disciplinary information to disclose. He has NOT been party to a) a criminal or civil action in a domestic, foreign or military court; b) an administrative proceeding before the SEC, any other federal regulatory agency, any state regulatory agency or any foreign financial regulatory authority; c) a self-regulatory proceeding; or d) any other proceeding in which a professional attainment, designation, or license was revoked. ADV Part 2B - Paul Di Biasio Item 4 – Other Business Activities Di Biasio & Edgington, Inc. Mr. Di Biasio is president, and owns a majority stake in the software company. Di Biasio & Eding- ton, Inc. Di Biasio & Edgington, Inc. sell a subscription service to institutional investors that pro- vides portfolio analysis using the firm proprietary technical analysis. From 1989 to 2008, the company authored and sold investment software. Although the product is no longer offered, existing client are still supported. The firm has 1 employee and has been in business since 1989. Mr. Di Biasio estimates that managing D&E, Inc. requires roughly 10% of his time. As a result of his efforts, Mr Di Biasio does not receive any commission or additional economic ben- efit from any outside parties and his compensation from D&E, Inc. is derived solely from the prof- itability of the company. Securities recommendations made by D&E, Inc. are not solely relied on by Private Lane Capital ,LLC. The clients of D&E, Inc. are notified that the firm or its principals or related entities may have positions in the companies that it references in company generated reports. ADV Part 2B - Paul Di Biasio Item 5 -Additional Compensation Mr. Di Biasio does not receive any additional economic benefit from third parties for providing advisory services. ADV Part 2B - Paul Di Biasio Item 6 – Supervision Since Mr. Di Biasio is the sole member/owner of Private Lane Capital, LLC, he does not have a direct supervisor. ADV Part 2B - Julio Lacayo Item 1 – Cover Sheet Private Lane Capital, LLC Part 2B of Form ADV Brochure Supplement Julio A. Lacayo 5075 Ute Lane Vail, Colorado 81657 March 31, 2026 This brochure supplement provides information about Julio Lacayo that supplements the Private Lane Capital brochure. You should have received a copy of that brochure. Please contact Paul Di Biasio at (703) 679-7394 and/or paul@privatelanecapital.com if you did not re- ceive Private Lane Capital’s brochure or if you have any questions about the contents of this sup- plement. Additional information about Julio Lacayo may also is available on the SEC’s Investment Advisor Public Disclosure website at http://www.adviserinfo.sec.gov/ Item 2 – Educational Background and Business Experience Mr. Lacayo (year of birth 1969) graduated from the Allegheny College with a BA in Economics and then in 2003 he earned a MBA at Georgetown University. Julio Lacayo passed the Series 65 (Uniform Investment Adviser Law Examination), which qualifies him to act as an investment adviser representative (IAR). CRD# 5981622 Business Background:  Private Lane Capital, LLC – Investment Adviser Representative (2026–Present) Fiduciary Trust International - Wealth Director (Nov 2021 – Fall 2024)   Truist Financial Corporation (formerly SunTrust Bank) - Wealth Advisor (Nov 2018 - Nov 2021)  Bank of America, N.A. - Sr WM Lending Officer – (Sept 2014 – Oct 2018)  Merrill Lynch ( division of Bank of America) – Private Client Advisor – (Sept 2014 – Oct 2018) Item 3 -Disciplinary Information Mr. Lacayo does not have any legal or disciplinary events to disclose. Item 4 – Other Business Activities Mr. Lacayo is not engaged in any other investment-related or non-investment-related business activities that would present a conflict of interest. He owns and manages a rental property held in Roseville, MN since 08/14. This endeavor takes approximately 1 hour a month, Item 5 -Additional Compensation Mr. Lacayo is compensated by Private Lane Capital, LLC for his services, which may include business development activities and assisting with client relationships. His compensation is derived from the Firm’s advisory fees. He does not receive any economic benefit from third parties for providing advisory services. Item 6 – Supervision Julio Lacayo is supervised by: Paul Di Biasio Managing Member Private Lane Capital, LLC (703) 679-7394 Private Lane Capital, LLC maintains supervisory procedures designed to monitor the activities of its investment adviser representatives and to ensure compliance with applicable securities laws and firm policies. Item 7 – Requirements for State-Registered Advisers Not applicable. Private Lane Capital, LLC is registered with the U.S. Securities and Exchange Commission.