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Form ADV Part 2A
Client Brochure
January 7, 2026
QuadCap Wealth Management, LLC
2600 Network Boulevard, Suite 300
Frisco, TX 75034
Office: (972) 818-2400
Fax: (972) 733-0798
www.quadcapwm.com
Item 1 - Cover Page
This brochure provides information about the qualifications and business practices of QuadCap Wealth
Management, LLC (“QuadCap”). If you have any questions about the contents of this brochure, please
contact us at (972) 818-2400. The information in this brochure has not been approved or verified by the
United States Securities and Exchange Commission (“SEC”) or by any state securities authority.
QuadCap is a Registered Investment Adviser under the Investment Advisers Act of 1940, as amended
(“Advisers Act”). Registration with the SEC or any state securities authority does not imply a certain level
of skill or training.
Additional information about QuadCap is also available on the SEC’s website at
www.adviserinfo.sec.gov. The searchable IARD/CRD number for QuadCap is 151490.
QuadCap Wealth Management, LLC
Item 2 - Material Changes
Since the last annual updating amendment on March 31, 2025, we have the following material changes to
report:
QuadCap can serve as trustee for clients upon request. QuadCap’s responsibilities as trustee will be those
set out in the trust documents. QuadCap will be paid fees for trustee services as specified in the trust
documents. The payment for trustee services is separate from any payment QuadCap receives for providing
advisory services. QuadCap has engaged an independent public accountant to perform an annual surprise
audit of those accounts of which QuadCap serves as trustee.
QuadCap is also deemed to have custody due to Standing Letters of Authorization. QuadCap does not have
to obtain a surprise audit examination for these accounts because QuadCap follows the seven (7) safe harbor
provisions.
Denise Brochu was named Outsourced Chief Compliance Officer.
We review and update this brochure at least annually to confirm that it remains current. If/when we
determine that an interim update is meaningful or required, we will notify clients promptly.
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Item 3 - Table of Contents
Item 1 - Cover Page .................................................................................................. cover
Item 2 - Material Changes .......................................................................................................................... 1
Item 3 - Table of Contents ............................................................................................... 2
Item 4 - Advisory Business................................................................................................................... 3
Item 5 - Fees and Compensation .......................................................................................................... 7
Item 6 - Performance-Based Fees and Side-By-Side Management .......................................................... 9
Item 7 - Types of Clients ............................................................................................................................ 9
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss ............................................... 9
Item 9 - Disciplinary Information .................................................................................. 13
Item 10 - Other Financial Industry Activities and Affiliations ............................................................... 13
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal
Trading ...................................................................................................................................................... 14
Item 12 - Brokerage Practices ............................................................................................................. 15
Item 13 - Review of Accounts ......................................................................................... 16
Item 14 - Client Referrals and Other Compensation ............................................................................... 16
Item 15 – Custody ........................................................................................................................................... 16
Item 16 - Investment Discretion ............................................................................................................... 16
Item 17 - Voting Client Securities ............................................................................................................ 17
Item 18 - Financial Information ...................................................................................................... 17
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Item 4 - Advisory Business
As used herein, the words “QuadCap,” “we,” “us,” and “our” refer to QuadCap Wealth Management, LLC.
The words “you,” “your,” and “client” refer to you, as a client or prospective client of QuadCap.
General Firm Description
QuadCap was established in 2009. QuadCap provides investment management, financial planning and third-party
adviser selection to high-net-worth individuals. The investment management aspect of its business includes
providing continuous investment advice and making investments for Quad Cap’s clients based on the client’s
individual needs. David Blair is the Chief Executive Officer and the majority owner of QuadCap.
Types of Advisory Services
Discretionary Account Management
QuadCap offers highly customized and individualized investment programs for its clients. QuadCap crafts a
specific asset allocation strategy and investment policy based on the specific client’s goals, investment objectives
and constraints, which also takes into account each client’s risk tolerance, need for liquidity, and all other relevant
considerations that are unique to the client. QuadCap will determine in its sole discretion whether a client can
impose reasonable restrictions on investing in certain securities and types of securities.
Non-Discretionary Account Management
QuadCap provides non-discretionary advisory services to a limited number of its clients. With respect to such
non-discretionary services, QuadCap has no investment discretion over the client’s assets. Each agreement
entered into with a client for non-discretionary services will detail the specific services to be provided and fees.
Financial Planning Services
QuadCap can also provide clients with financial planning services as a standalone product or as part of its other
advisory services to a client. QuadCap can charge separate or additional fees for any such financial planning
services or include such financial planning services as part of its other advisory services. QuadCap, in its sole
discretion, determines on a case-by-case basis whether financial planning services are offered as a standalone
product subject to a standalone fee separate from its advisory fee. QuadCap’s financial planning services include,
but are not limited to, organization and assessment, retirement planning, education planning, long-term care,
insurance planning, debt management, investments, tax planning, estate planning and life events. The scope and
specific type of services provided as well as any fee arrangement are detailed in the client’s individual agreement
for services.
Prior to engaging QuadCap to provide planning or consulting services, clients are generally required to enter into a
consulting agreement with QuadCap setting forth the terms and conditions of the engagement (including
termination), describing the scope of the services to be provided, and the portion of the fee that is due from the
client prior to QuadCap commencing services. If requested by the client, QuadCap can recommend the services
of other professionals for implementation purposes. The client is under no obligation to engage the services of
any such recommended professional. The client retains absolute discretion over all such implementation
decisions and is free to accept or reject any recommendation from QuadCap. If the client engages any
recommended unaffiliated professional, and a dispute arises thereafter relative to such engagement, the client
agrees to seek recourse exclusively from and against the engaged professional. At all times, the engaged licensed
professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not QuadCap, shall be responsible for the
quality and competency of the services provided. It remains the client’s responsibility to promptly notify
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QuadCap if there is ever any change in their financial situation or investment objectives for the purpose of
reviewing, evaluating or revising QuadCap’s previous recommendations and/or services.
Limitations of Financial Planning and Non-Investment Consulting/Implementation Service: To the extent
requested by the client, QuadCap will generally provide financial planning and related consulting services
regarding matters such as tax and estate planning, insurance, etc. QuadCap will generally provide such consulting
services inclusive of its advisory fee set forth at Item 5 below (exceptions could occur based upon assets under
management, extraordinary matters, special projects, stand-alone planning engagements, etc. for which Firm can
charge a separate or additional fee). Please Note: QuadCap believes that it is important for the client to address
financial planning issues on an ongoing basis. QuadCap’s advisory fee, as set forth in Item 5 below, will remain
the same regardless of whether or not the client determines to address financial planning issues with QuadCap.
Please Also Note: QuadCap does not serve as an attorney or accountant, and no portion of our services should be
construed as the same. Accordingly, QuadCap does not prepare legal documents. To the extent requested by a
client, we can recommend the services of other professionals for non-investment implementation purposes (i.e.,
attorneys, accountants, insurance, etc.) The client is not under any obligation to engage any such professional(s).
The client retains absolute discretion over all such implementation decisions and is free to accept or reject any
recommendation from QuadCap and/or its representatives. If the client engages any professional (i.e., attorney,
accountant, etc.), recommended or otherwise, and a dispute arises thereafter relative to such engagement, the
engaged professional shall remain exclusively responsible for resolving any such dispute with the client. At all
times, the engaged licensed professional(s) (i.e., attorney, accountant, insurance agent, etc.), and not QuadCap,
shall be responsible for the quality and competency of the services provided.
Retirement Planning
Nearly all clients include retirement as one of their financial goals. A lifetime cash-flow projection is created to
analyze when and under what other circumstances retirement can be achieved. This includes projections of
investment returns, taxes, types of retirement accounts, spending and income as well as values of assets and
paying down of liabilities.
Retirement Rollovers: A client or prospective client leaving an employer typically has four options regarding an
existing retirement plan and can engage in a combination of these options: (i) leave the money in the former
employer’s plan, if permitted, (ii) roll over the assets to the new employer’s plan, if one is available and rollovers
are permitted, (iii) roll over to an Individual Retirement Account (“IRA”), or (iv) cash out the account value
(which could, depending upon the client’s age, result in adverse tax consequences). If QuadCap recommends
that a client roll over their retirement plan assets into an account to be managed by QuadCap, such a
recommendation creates a conflict of interest if QuadCap will earn new (or increase its current) compensation
as a result of the rollover. If QuadCap provides a recommendation as to whether a client should engage in
a rollover or not, QuadCap is acting as a fiduciary within the meaning of Title I of the Employee
Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing
retirement accounts.
QuadCap has policies and procedures that are designed to manage this conflict to ensure we provide advice
that’s in your best interest. As a fiduciary, when QuadCap makes a rollover recommendation, no client is under
any obligation to roll over Retirement Account assets to an account advised or managed by QuadCap.
Tax Preparation Service
QuadCap offers full-service tax preparation and filing services. Our team acts seamlessly with your primary
advisory team to provide your desired services, including individual and business tax planning and individual
and business tax preparation services. This service complements our wealth management services. No client is under
any obligation to use QuadCap’s tax preparation services. You are free to use a tax professional of your choosing.
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Trustee Services
QuadCap can serve as trustee for clients upon request. QuadCap’s responsibilities as trustee will be those set out
in the trust documents. QuadCap does not draft trust documents; clients should ask their counsel to draft these
documents. QuadCap will be paid fees for trustee services as specified in the trust documents. QuadCap will
have an incentive to allocate trust assets to its own management in order to earn advisory fees; thus, providing
trustee services creates a conflict of interest. To mitigate this conflict of interest, QuadCap is making you aware
of the fact that QuadCap will receive payment for trustee services and advisory fees for the management of the
trust assets. You are under no obligation to select QuadCap to serve as your trustee.
Account Aggregation Platforms
MoneyGuidePro Advisor Platform
QuadCap will provide its clients with access to an online platform hosted by “MoneyGuidePro”
(“MoneyGuide”). The MoneyGuide platform allows a client to view their complete asset allocation, including
those assets that QuadCap does not manage (the “Excluded Assets”).
QuadCap does not provide investment management, monitoring, or implementation services for the Excluded
Assets. The MoneyGuide platform also provides access to other types of information and applications including
financial planning concepts, hypothetical projections and other functions, which should not, in any manner
whatsoever, be construed as services, advice, or recommendations provided by QuadCap.
Finally, QuadCap shall not be held responsible for any adverse results a client experiences if the client engages
in financial planning or other functions available on the MoneyGuide platform without QuadCap’s assistance or
oversight. QuadCap has a fiduciary duty to provide services consistent with the client’s best interest. As part of
its investment advisory services, QuadCap will review client portfolios on an ongoing basis to determine if any
changes are necessary based on portfolio activity.
e-Money Advisor Platform
QuadCap will also provide its clients with access to an online platform hosted by e-Money. The e-Money platform
allows a client to view their complete asset allocation, including those assets that QuadCap does not manage (the
“Excluded Assets”).
QuadCap does not provide investment management, monitoring, or implementation services for the Excluded
Assets. The e-Money platform also provides access to other types of information and applications including
financial planning concepts, hypothetical projections and other functions, which should not, in any manner
whatsoever, be construed as services, advice, or recommendations provided by QuadCap.
Finally, QuadCap shall not be held responsible for any adverse results a client experiences if the client engages in
financial planning or other functions available on the e-Money platform without QuadCap’s assistance or
oversight. QuadCap has a fiduciary duty to provide services consistent with the client’s best interest. As part of its
investment advisory services, QuadCap will review client portfolios on an ongoing basis to determine if any
changes are necessary based on portfolio activity.
Cash Sweep and Cash Positions
The account custodians generally require that cash proceeds from account transactions or cash deposits be swept
into and/or initially maintained in the custodian’s sweep account. This is also dictated by an understanding of the
clients' timing needs and the size of the client’s cash balance.
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The yield on the sweep account is generally lower than those available in money market accounts. To help
mitigate this issue, QuadCap will generally purchase a higher yielding money market fund or other cash-like
securities (e.g. U.S. Treasury securities, Certificates of Deposit (CDs).
QuadCap will generally treat cash as an asset class; and as such, unless determined to the contrary by QuadCap,
all cash positions (money markets, etc.) shall continue to be included as part of assets under management for
purposes of calculating QuadCap’s advisory fee. At any specific point in time, depending upon perceived or
anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will
occur), QuadCap maintains cash positions for defensive purposes. In addition, while assets are maintained in cash,
such amounts could miss market advances. Depending upon current yields, at any point in time, in spite of every
effort and vigilant action by QuadCap's investment team, QuadCap’s advisory fee could exceed the interest paid
by the client’s money market fund.
Selection of Outside Advisers
In accordance with the client’s investment objective, QuadCap can allocate (and/or recommend that the client
allocate) a portion of a client’s investment assets among unaffiliated independent third-party investment
managers (“Independent Manager”(s)). In such situations, the Independent Manager(s) will have day-to-day
responsibility for the active discretionary management with respect to a portion, or all, of a client’s assets. When
determining whether to engage an Independent Manager, QuadCap considers a range of factors including, but not
limited to, the client’s financial objectives, risk profile, Independent Manager’s fees, reputation, and track record.
Under these arrangements, QuadCap will be compensated via a fee share from the advisers to which it
recommends those clients. The fees shared will not exceed any limit imposed by any regulatory agency. The
investment management fees charged by the designated Independent Manager(s) are inclusive of, and in addition
to, QuadCap’s ongoing investment advisory fee, which will be disclosed to the client before entering into the
Independent Manager engagement and/or subject to the terms and conditions of a separate agreement between
the client and the Independent Manager(s).
Clients should carefully review any Independent Manager’s brochure and contract, as applicable, in addition to
QuadCap’s fees in order to determine the total amount of fees. Fees are generally paid quarterly in advance. Clients
can terminate the contract without penalty, for a full refund of the adviser’s fees, within five business days of
signing the contract. Thereafter, clients can terminate the contract within thirty (30) days written notice. In the
case of the latter, refunds are given on a prorated basis and are based on the number of days remaining in the
quarter.
Participant Account Management (Discretionary)
We use a third-party platform to facilitate management of held away assets such as defined contribution plan
participant accounts, with discretion. The platform allows us to avoid being considered to have custody of Client
funds since we do not have direct access to Client log-in credentials to affect trades. We are not affiliated with the
platform in any way and receive no compensation from them for using their platform. A link will be provided to
the Client allowing them to connect an account(s) to the platform. Once Client account(s) is connected to the
platform, Adviser will review the current account allocations. When deemed necessary, Adviser will rebalance the
account considering client investment goals and risk tolerance, and any change in allocations will consider current
economic and market trends. The goal is to improve account performance over time, minimize loss during difficult
markets, and manage internal fees that harm account performance. Client account(s) will be reviewed at least
quarterly and allocation changes will be made as deemed necessary.
Wrap Fee Programs
QuadCap does not participate in a wrap fee program.
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Assets Under Management
QuadCap manages client assets on a discretionary basis and on a non-discretionary basis. As of December 31,
2024, QuadCap’s assets under management totaled the following:
Discretionary Assets Under Management:
Discretionary Number of Client Accounts:
Non-Discretionary Assets Under Management:
Non-Discretionary Number of Client Accounts:
$1,132,531,872
1,763
$4,155,818
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Item 5 - Fees and Compensation
General Fee Information
As further described below, fees paid to QuadCap are exclusive of all custodial and transaction costs paid to the
client’s custodian, brokers, or other third-party consultants. Please see Item 12 - Brokerage Practices for additional
information. Fees paid to QuadCap are also separate and distinct from the fees and expenses charged by mutual
funds, ETFs (exchange-traded funds), or other investment pools to their shareholders (generally including a
management fee and fund expenses, as described in each fund’s prospectus or offering materials). The client should
review all fees charged by funds, brokers, Independent Manager(s), QuadCap and others to fully understand the total
amount of fees paid by the client for investment and financial-related services.
Asset-Based Fees
Clients are charged for QuadCap’s asset management services as a percentage of assets under management. The
fee is negotiable at the adviser’s discretion but usually are based on the nature and complexity of the engagement,
length of relationship, and asset amount or life cycle of the account up to a maximum of 1%. Fees are billed at the
start of each quarter and are based on the average daily balance of the account over the preceding quarter. Fees
usually are deducted from client accounts.
Our investment approach combines a diversified portfolio of equity and fixed income securities, tailored to meet
your financial goals and risk tolerance. Our advisory fee is capped at a maximum of 1% of your assets under
management (AUM), ensuring transparent and competitive pricing while maximizing your returns. Advisory fees
are based upon the value of assets managed by QuadCap rather than the level of activity in the account. For
purposes of advisory fee calculations, QuadCap relies on the account values provided by the client’s custodian..
QuadCap prefers to have its advisory fees deducted directly from the client’s account. In these cases, clients must
provide the custodian with written authorization to have fees deducted from the client’s account and paid to
QuadCap. Clients who engage QuadCap after the beginning of a quarter will be subject to a prorated advisory fee,
so that the client is charged for the time the advisory agreement with QuadCap is entered into until the end of
the quarter. Clients who terminate services will generally be subject to prorated fees.
A client shall cause its custodian to deliver quarterly or monthly account statements to each client. Among other
details, account statements shall list disbursements made from the account, including the amount of the advisory
fee payable to QuadCap when deducted directly from the client’s account. Advisory fees are negotiable and can
vary amongst QuadCap clients. Your fees will be dependent on several subjective and objective factors including
time spent with QuadCap, number of meetings, complexity of your situation, amount of research, services
requested and staff resources. As a result of these factors, clients being provided similar services can be subject to
differing fee arrangements.
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Financial Planning
Financial planning fees can be included as part of the client’s advisory fee or can be considered separate and
exclusive of QuadCap’s advisory fees, as determined by QuadCap on a case-by-case basis. Where financial
planning is considered a standalone service, QuadCap will charge a fixed, annual fee, which is determined based
on a number of factors, including the specific strategies and the complexity of the financial planning, but is
negotiable at QuadCap’s sole discretion. QuadCap’s flat annual fee for financial planning services ranges up to
$12,000 per year. One-half of the estimated fee is due thirty (30) days after the engagement letter is signed, and
the remaining balance is due six (6) months thereafter.
QuadCap can also choose, on a case-by-case basis, to accept fees for its financial planning services in the form of
direct payments. If a client is subject to this type of direct payment arrangement, payment is due upon the client’s
receipt of a billing statement from QuadCap. Direct billing statements, if applicable, are delivered to clients
every six (6) months. In the event you opt to discontinue the financial planning arrangement prior to its
completion, QuadCap will calculate the amount due based upon the agreement in force and amount of time
completed on the project, and will either issue a refund for your unused balance, or QuadCap will provide an
invoice for work that has been completed with any remaining balance due, taking into account payments made
in advance.
QuadCap reserves the right to raise fees for financial planning services at its discretion in an amount not to exceed
15% per annum. In these instances, QuadCap will provide you with written notice not less than thirty (30) days prior
to any increase in financial planning fees pursuant to this provision.
Trustee Services
Upon a client’s request, QuadCap will serve as trustee for trusts established by clients. QuadCap will receive
trustee fees as specified within the trust documents. These fees are separate from and in addition to advisory fees
and other fees disclosed in this Item 5.
Other Fees
There are expenses and fees that will be charged to client accounts exclusive of QuadCap’s advisory fees. For
instance, certain of QuadCap’s employees are licensed insurance agents and can offer clients insurance-
related advice or products, such as fixed annuities. While QuadCap does not receive/share in commissions for
these services, employees of the firm will receive commissions that are separate and in addition to QuadCap’s
advisory fees. Clients should be aware that these commission payments involve a possible conflict of interest,
as commissionable products create an incentive to recommend such products based on compensation received,
rather than your needs. Clients should be aware that insurance products or other investment products offered
by QuadCap can be purchased by clients through other brokers or agents not affiliated with QuadCap.
Other fees include, but are not limited to, brokerage commissions and/or transaction ticket fees, custodian fees
and taxes. QuadCap will not receive any portion of such brokerage commissions or fees from the custodian. In
addition, clients can incur certain charges imposed by third parties other than QuadCap in connection with
investments made through the account, including but not limited to, mutual fund sales loads, 12b-1 fees and
surrender charges, variable annuity fees and surrender charges, private placement fees, and IRA and qualified
retirement plan fees.
Third-Party Managers
In accordance with the client’s investment objective, QuadCap can allocate (and/or recommend that the client
allocate) a portion of a client’s investment assets among unaffiliated independent third-party investment
managers (“Independent Manager”(s)). Clients should review the third-party investment management agreement
to determine how the third-party manager’s advisory fee will be calculated and paid.
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Clients should be aware that certain conflicts can arise where third-party managers engaged by QuadCap retain
12b-1 fees. For instance, if a third-party manager was party to a fee sharing arrangement with QuadCap, and
such manager retained a portion of 12b-1 fees, it could present a conflict of interest, because QuadCap could
potentially receive some benefit in the form of a higher fee split.
Further, QuadCap uses a third-party platform to facilitate management of held away assets such as defined
contribution plan participant accounts, with discretion. The platform allows us to avoid being considered to have
custody of Client funds since we do not have direct access to Client log-in credentials to affect trades. We are not
affiliated with the platform in any way and receive no compensation from them for using their platform. A link
will be provided to the Client allowing them to connect an account(s) to the platform. Once Client account(s) is
connected to the platform, QuadCap will review the current account allocations. When deemed necessary,
QuadCap will rebalance the account considering client investment goals and risk tolerance, and any change in
allocations will consider current economic and market trends. The goal is to improve account performance over
time, minimize loss during difficult markets, and manage internal fees that harm account performance. Client
account(s) will be reviewed at least quarterly and allocation changes will be made as deemed necessary.
Fees charged by QuadCap are separate and distinct from the fees and expenses charged by investment company
securities that can be recommended to clients. A description of these fees and expenses is available in each
investment company security’s prospectus. For more information regarding brokerage fee commissions, please
see Item 12.
Generally, clients are billed in advance for any third-party management services mentioned above, as applicable.
Clients should review the prospectus for a description of how fees are calculated.
Item 6 - Performance-Based Fees and Side-By-Side Management
QuadCap does not charge performance-based fees and does not engage in side-by-side management.
Item 7 - Types of Clients
The types of clients, QuadCap, generally provides investment advice to include, but is not limited to,
individuals, high net worth individuals, trusts, estates, charitable organizations, corporations or businesses.
QuadCap does not have a minimum account size requirement although all accounts are accepted at
QuadCap’s sole discretion.
Item 8 - Methods of Analysis, Investment Strategies and Risk of Loss
Methods of Analysis
QuadCap will use some or all of the following methods of analysis in formulating investment advice or
management assets: Quantitative, Fundamental, Technical, or Cyclical in formulating its investment strategies
for giving investment advice or managing client assets. The research process also involves meeting with industry
contacts and carefully monitoring current and potential investments. We also diligently monitor stock
performance and stay apprised of critical issues that have effects on industries impacting our clients’ investments.
QuadCap considers the client’s particular circumstances when building portfolios, including the client’s need for
liquidity and risk tolerance. Portfolios will generally consist of securities and investments into equity securities,
corporate debt securities, certificates of deposit, municipal securities, mutual funds, United States government
securities, option contracts and real estate.
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Investment Strategy
QuadCap constructs portfolios for clients using a blend of equities and fixed income via instruments that include
individual securities, mutual funds, exchange traded funds (ETFs) and to a lesser degree closed-end fund (CEFs)
tailored to the needs of individuals near or in retirement. Equities provide growth potential, while fixed income,
including individual bonds, offers stability and income. Initially, a higher allocation to equities aims for capital
appreciation, gradually shifting towards fixed income as retirement approaches to mitigate risk. The allocation is
periodically rebalanced to maintain the desired risk-return profile and to meet evolving income needs. Individual
bonds are selected based on factors like credit quality, maturity, and yield, ensuring a diversified fixed income
portfolio. This strategy aims to provide a balance between growth and stability, aligning investments with the
changing financial requirements of those nearing or in retirement.
QuadCap’s Investment strategy is personalized to a client's goal(s), time horizon, risk capacity and
preferences, liquidity needs, if any, tax posture and current financial assets. It is important that you notify us
immediately with respect to any material changes to your financial circumstances, including for example, a change
in your current or expected income level, tax circumstances, or employment status.
QuadCap chooses investments based on its investment philosophy, which is grounded in investment research.
We draw our research from multiple third-party providers. This allows us to consolidate independent views and
ideas and distill an appropriate course of action. Multiple sources of information insulate the firm and our clients
from individual biases or potential conflicts of interest. In developing investment strategies for accounts invested
in the Firm’s models, both quantitative and qualitative reviews are conducted in an effort to identify the
appropriate investment strategies.
Within a client’s portfolio, QuadCap can employ one or more of the strategies detailed below as well as other
investment strategies. Within a strategy, QuadCap can choose to invest client accounts in individual securities
and/or utilize other managers through investment in funds.
Principal Investment Strategies for Client Accounts
The firm constructs portfolios for clients on an individualized basis consisting of equities (individual or through
separately managed accounts), bonds (individual or through separately managed accounts), ETFs, and mutual
funds. Accounts will contain one or more of the securities mentioned above to align with the client’s stated
goal(s), time horizon, and risk preferences which have been previously discussed with the Advisor and agreed
upon by the client.
Risk of Loss:
While QuadCap seeks to diversify clients’ investment portfolios across various asset classes consistent with their
investment plan in an effort to reduce loss Investing in securities, other financial instruments, and real estate
involves a risk of loss, including the potential loss of the entire investment, which clients should be prepared to
bear. All investment strategies carry some degree of investment, regulatory, market, and political risk, and no
method of analysis can eliminate this risk of value fluctuations or prevent losses. Clients and prospective clients
should carefully consider all risks before investing with QuadCap. Clients can lose money through any of
QuadCap’s strategies. Material risks are described below, but additional risks apply specifically to particular
investment strategies or investments in different types of securities and other financial instruments. QuadCap
urges clients and potential clients to thoroughly read all investment-specific risk disclosures, and to consider such
risks in light of the client’s investment objectives and financial circumstances.
Reinvestment Risk:
There is a risk that proceeds from investments that have been reinvested can have a lower rate of return and
incur trading costs and income taxes.
Business Risk:
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QuadCap’s operations or cost of operations can be impacted by a shift in QuadCap’s business or changes in
United States law/regulations. Any of these changes could adversely impact QuadCap’s clients.
Market Risk:
Investing involves the risk of fluctuation, outside of QuadCap’s control, in the value of the investments. Prices
can drop in response to external events and conditions, such as economic, political or social circumstances.
Other general market factors can result from changes to foreign or domestic laws, credit availability and
inflation rates.
Reliance on Underlying Managers:
Client accounts that are invested with third-party managers largely depend on the expertise and ability of the
underlying fund manager to accurately evaluate and assess price fluctuations in the market. QuadCap cannot
provide any assurances that such third-party managers will be able to accurately predict these price fluctuations.
Focused Investments Risk: Portfolios that are focused or lack diversification are considered riskier than
diversified portfolios. QuadCap can employ a concentrated or focused investment strategy with fewer types of
investments and therefore might be subject to greater risk of volatility than a diversified portfolio. A fluctuation
in the value of one stock could have a significant impact on the overall performance of one portfolio in these
focused investment strategies.
Margin Risk:
QuadCap does not use margin as an investment strategy. However, clients can elect to borrow funds against their
investment portfolio. When investments are purchased, they can be paid for in full or the client can borrow part
of the purchase price from the account custodian. If a client borrows part of the purchase price, the client is
engaging in margin transactions and there is risk involved with this. The assets held in a margin account are
collateral for the custodian that loaned the client money. If those assets decline in value, then the value of the
collateral supporting the client’s loan also declines. As a result, the brokerage firm is required to take action in
order to maintain the necessary level of equity in the client’s account. The brokerage firm can issue a margin call
and/or sell other assets in the client’s account to accomplish this. It is important that clients fully understand the
risks involved in trading on margin, including but not limited to: • It is possible to lose more funds than is
deposited into a margin account; • The account custodian can force the sale of assets in the account; • The
account custodian can sell assets in the account without contacting the client first; • The account holder is not
entitled to choose which assets in a margin account will be sold to meet a margin call; • The account custodian
can increase its “house” maintenance margin requirements at any time without advance written notice; and • The
accountholder is not entitled to an extension of time on a margin call.
Equity Investments Risk:
Fluctuations in the market or in an underlying portfolio company’s financial condition can result in
unpredictable and rapid changes in the prices of equity securities. Equity investments are ownership positions in
portfolio companies. The value of a client’s investments can decrease as a result of these fluctuations. Equity
securities can include preferred stock, common stock, warrants or trading stock. Declines in the stock market
and the financial condition of the issuers of these securities can lead to a decline in the value of an equity
investment.
Fixed Income Investments Risk:
Fixed income securities are structured to distribute interest payments to holders until the principal is returned.
Investments in fixed income instruments are subject to many risks that can be inherent in other types of
investments as well. Some of these risks include, but are not limited to, credit risks that an issuer can default on
its obligation to pay principal or interest, liquidity risks and the risk of changes in interest rates that can impact
the value of fixed instruments.
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ETF Risks:
QuadCap can invest in ETFs as part of its strategy, which presents illiquidity risks and be more volatile than
other types of investments. ETFs generally present the same risks of the underlying securities of the ETF,
therefore disruptions to the market for the underlying securities can lead to disruptions in the ETFs. ETFs are
traded like stock at a certain market price. Such price can be above or below the net asset value of the ETF’s
underlying securities. ETFs can also present a greater cost to clients as opposed to holding an interest in the
underlying securities directly due to the separate ETF management fee of the ETF.
Tax Risk:
QuadCap can invest in companies that generate unrelated business income tax or that create other tax
implications for its clients or subject client accounts to complex tax rules. Clients are advised that they should
consult with an independent tax advisor regarding potential tax implications of investments made through
QuadCap.
Liquidity Risk:
It can be the case that a client’s portfolio contains illiquid investments. Clients can be subject to losses and
unable to quickly realize gains where the need to liquidate arises, but due to lock up periods or other limitations,
liquidity is not possible.
Interest Rate Risk:
Client investments can be subject to interest rate risks, meaning that changes in prevailing market interest
rates could negatively affect the value of such investments. Factors that can affect market interest rates include,
without limitation, inflation, slow or stagnant economic growth or recession, unemployment, money supply,
governmental monetary policies, international disorders and instability in U.S. and non-U.S. financial markets.
In a changing interest rate environment, the performance of these investments could be adversely affected.
Valuation Risks:
Values of stocks and securities can fluctuate after the close of markets on which they are traded, which can lead
to differences from QuadCap’s valuation of the investment. These differences can be significant, especially with
respect to markets that typically experience extreme volatility. QuadCap’s valuation process can also be
adversely impacted by any technological issues and/or oversights by other third-party providers QuadCap can
rely on for information.
Foreign Investment Risks:
QuadCap can invest in foreign securities for client portfolios. Foreign companies are those which have a physical
headquarters located outside of the United States. A company with a headquarters located outside of the United
States can be considered domestic if its primary trading activity occurs within the United States.
Foreign investments can be more volatile than domestic investments. Foreign markets can be less regulated and
less stable than domestic markets with respect to custody, accounting, reporting and various disclosure standards.
They also tend to implicate higher costs as a result of higher commission rates, custodial costs or transfer taxes.
Portfolios can also be subject to non-U.S. taxes as a result of foreign investment, even retroactively, with respect
to capital gains, transactions and repatriation of proceeds. Other factors, such as exchange rates, can positively or
negatively impact the value of QuadCap’s foreign investments.
Other investments in emerging markets present a greater risk than other markets. An emerging market can include
a country with less regulated or developed legal, political and investment regimes. Emerging market economies
tend to be more volatile than others and are more dependent on concentrated industries, which makes these
markets highly susceptible to fluctuation. Changes in market conditions and changes in government are more
likely in emerging markets. Emerging markets tend to be less regulated with respect to custody, accounting,
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reporting and various disclosure standards. There can also be significant limitations to the rights and remedies
available to investors against issuers.
Acts of God and Geopolitical Risks:
The performance of a client’s account could be impacted by Acts of God or other unforeseen and/or
uncontrollable events (collectively, “disruptions”), including, but not limited to, natural disasters, public health
emergencies (including any outbreak or threat of COVID-19, SARS, H1N1/09 flu, avian flu, other coronavirus,
Ebola, or other existing or new pandemic or epidemic diseases), terrorism, social and political discord, geopolitical
events national and international political circumstances, and other unforeseen and/or uncontrollable events with
widespread impact. These disruptions can affect the level and volatility of security prices and liquidity of any
investments. There is risk that unexpected volatility or lack of liquidity will impair an investment’s profitability
or result in it suffering losses. Economies and financial markets throughout the world are becoming increasingly
interconnected, which increases the likelihood that events or conditions in one country or region will adversely
impact markets or securities industry participants in other countries or regions. The extent of the impact of any
such disruption on QuadCap, its clients, and any portfolio investment’s operational and financial performance
will depend on many factors, including the duration and scope of such disruption, the extent of any related travel
advisories and restrictions implemented, the impact of such disruption on overall supply and demand, goods and
services, investor liquidity, consumer confidence and levels of economic activity and the extent of its disruption
to important global, regional and local supply chains and economic markets, all of which are highly uncertain
and cannot be predicted.
Cybersecurity Risks:
With the increased use of technologies such as the Internet and the dependence on computer systems to
perform necessary business functions, QuadCap, its service providers and the companies in which clients invest
can be susceptible to operational and information security risks resulting from cyber-attacks. Moreover,
QuadCap’s service providers rely on other third-party service providers that are susceptible to such cyber-attack
risks. In general, cyber-attacks are deliberate, but unintentional events can have similar effects. Cyber-attacks
include, among others, stealing, corrupting or encrypting data maintained online or digitally, preventing legitimate
users from accessing information or services on a website, releasing confidential information without
authorization, gaining unauthorized access to digital systems for purposes of misappropriating assets and causing
operational disruption. Cyber-attacks can also be carried out in a manner that does not require gaining
unauthorized access, such as causing denial of service. Successful cyber-attacks against, or security breakdowns
of, QuadCap or its service providers can adversely affect QuadCap or its strategies. Technology failures or cyber
security breaches, whether deliberate or unintentional, including those arising from use of third-party service
providers, could delay or disrupt QuadCap's ability to do business and service clients.
General Risk of Loss:
Investing in securities involves the risk of loss. Clients should be prepared to bear such loss.
Item 9 - Disciplinary Information
QuadCap nor any of its employees have been involved in legal or disciplinary events that would be material to a
client or a prospective client’s evaluation of QuadCap’s advisory business or the integrity of QuadCap’s
management.
Item 10 - Other Financial Industry Activities and Affiliations
Neither QuadCap nor its associated persons are registered, nor do they have an application pending to register,
as a futures commission merchant, commodity pool operator, commodity trading adviser, broker-dealer or
registered representative of a broker-dealer, or an associated person of the foregoing entities, at this time.
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Potential Conflicts of Interest
Conflicts of interest are inherent in investment adviser/client relationships. Notwithstanding potential conflicts
of interest, as a fiduciary, QuadCap will always act in the best interests of the client. QuadCap maintains policies
and procedures designed to avoid conflicts of interest where possible and provides full and fair disclosure of any
material conflicts, many of which are detailed in this brochure.
Conflicts of interest can arise when QuadCap directs clients to third-party money managers. QuadCap will be
compensated via a fee share from the advisers to which it directs those clients. This creates a conflict of interest in
the fact that QuadCap has an incentive to direct clients to certain third-party money managers that provide
QuadCap with a larger fee split. In order to mitigate such conflicts, QuadCap will disclose such arrangements in
writing, as applicable. The fees shared will not exceed any limit imposed by any regulatory agency. QuadCap
will ensure that all recommended advisers or managers are licensed or have filed a notice in the states in which
QuadCap recommends them to clients.
Conflicts can also arise with respect to additional fees QuadCap collects from financial planning services
QuadCap provides its clients, which can be exclusive of advisory services, such as tax preparation. Some of these
non-advisory services could result in a potential conflict of interest where QuadCap is compensated at differing
rates. Further, conflicts can also arise where certain non-advisory activities demand significant time and attention
from QuadCap, which can limit time and attention spent on advisory client accounts.
Commission payments to certain of QuadCap’s staff members can also present a conflict of interest. For instance,
several QuadCap employees are licensed insurance agents, and can offer clients insurance-related advice or
products. Clients should be aware that these services pay a commission and involve a possible conflict of interest,
as commissionable products can conflict with the fiduciary duties of a registered investment adviser. As a
fiduciary, QuadCap must always act in the best interest of the client, including in the sale of commissionable
products to advisory clients. Clients are in no way required to implement the plan through any representative of
QuadCap in their capacity as a licensed insurance agent.
Item 11 - Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
QuadCap’s Code of Ethics
QuadCap and its associated persons are subject to QuadCap’s Code of Ethics, adopted pursuant to Rule
204A-1 under the Advisers Act, which imposes certain procedures, disclosures, and/or restrictions designed to
avoid and manage conflicts of interest between QuadCap and its clients. A copy of QuadCap’s Code of Ethics
will be promptly provided to a client or a potential client upon written request.
An investment adviser is considered a fiduciary according to the Advisers Act. As a fiduciary, it is an investment
adviser’s responsibility to provide fair and full disclosure of all material facts and to act solely in the best interest
of each of our clients at all times. QuadCap has a fiduciary duty to all clients. This fiduciary duty is considered the
core underlying principle for QuadCap’s Code of Ethics which also covers its Insider Trading and Personal
Securities Transactions Policies and Procedures. QuadCap requires all of its supervised persons to act in
accordance with its Code of Ethics, to conduct business with the highest level of ethical standards and to comply
with all federal and state securities laws. QuadCap has the responsibility to ensure that the interests of all clients
are placed ahead of QuadCap’s or its supervised person’s own investment interest. Full disclosure of all material
facts and potential conflicts of interest will be provided to clients prior to any services being conducted. QuadCap
and its supervised persons must conduct business in an honest, ethical and fair manner and avoid all circumstances
that might negatively affect or appear to affect our duty of complete loyalty to all clients.
QuadCap does not participate in principal transactions or agency cross transactions. However, QuadCap and its
personnel can invest for their own accounts or have a financial interest in the same securities or other investments
that the firm recommends or acquires for the accounts of its clients and can engage in transactions that are the
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same as or different than transactions recommended to or made for client accounts. Personal trading creates
conflicts of interest, including the possibility of “front-running” (trading ahead of clients to obtain better prices).
QuadCap has adopted written policies in accordance with Rule 204A-1 of the Advisers Act in order to mitigate
conflicts of interests this can present. Among other requirements, (i) QuadCap employees are required to pre-
clear participation in Initial Public Offerings and private or limited offerings; and (ii) supervised persons are
required to provide quarterly transaction reports with respect to reportable securities, which the Compliance
Officer will review for any potential violations (i.e. patterns of the supervised person’s investments in the same
securities as his or her client outperforming the client), as required under the Code of Ethics.
General Offer
Clients and prospective clients can contact QuadCap to request a copy of its Code of Ethics.
Item 12 - Brokerage Practices
Broker-Dealer Selection
QuadCap generally does not permit clients to direct brokerage to any broker-dealer of the client’s choice and
instead requests that clients direct brokerage to The Charles Schwab Corporation (“Schwab”).
However, where a client has previously engaged a different broker-dealer/custodian, QuadCap can choose to
manage the relevant accounts without requiring the client to move those assets to an account with Schwab. In
such instances, QuadCap could be unable to achieve most favorable execution of client transactions. As a
result, QuadCap does not charge fees on these assets.
In requiring clients to direct brokerage to Schwab, QuadCap ultimately seeks to obtain the best price and
execution for its clients when effecting trades. QuadCap has also performed an analysis of the following factors
in its determination that Schwab is its recommended broker-dealer: commissions, trading fees, the rate of trade
error, trade allocation and aggregation, restrictions, quality of trade services, reputation, expertise, experience,
levels of responsiveness to QuadCap and other factors that QuadCap determines are relevant in its sole discretion
even if such factor does not necessarily provide a specific benefit to its clients.
Although QuadCap’s policy and procedures in place are aimed at achieving the best execution and pricing for its
clients, there can be no assurances that best execution or the best price possible will be achieved in client
transactions.
Software and Support Provided by Financial Institutions:
The Firm does not currently have any formal soft dollar arrangements. The Firm is not required to allocate either
a stated dollar or stated percentage of its brokerage business to any broker for any minimum time period;
however, from time-to-time QuadCap can receive other products and services from Schwab without cost to
QuadCap. For instance, Schwab currently provides QuadCap with ETF screener reports, performance reports
and access to certain software programs (e.g. including third-party research reports, supplemental performance
reports, research information or software and computer programs). The software and system tools allow QuadCap
to better monitor client accounts.
QuadCap can receive software and related support without cost because QuadCap renders investment
management services to clients that maintain assets at Schwab. The software and related systems support can
benefit QuadCap, but not all of its clients directly. In fulfilling its duties to its clients, QuadCap endeavors at all
times to put the interests of its clients first. Clients should be aware, however, that QuadCap’s receipt of economic
benefits from a broker-dealer creates a conflict of interest since these benefits can influence QuadCap’s choice
of one broker-dealer over another broker-dealer that does not furnish similar software, systems support, or
services.
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Brokerage for Client Referrals
QuadCap does not currently, nor does it anticipate selecting a broker in exchange for client referrals.
Aggregation
When feasible, QuadCap can aggregate the purchase or sale of securities for various client accounts. Although
QuadCap can utilize aggregation when it believes aggregation benefits its clients overall, in any specific instance
a client may have achieved more favorable results had a purchase or sale not been aggregated.
Item 13 - Review of Accounts
Account Reviews
Account reviews are conducted by QuadCap’s advisers in connection with asset management accounts. For
discretionary clients, a QuadCap representative will contact clients at least annually for the purpose of
reviewing their account and to determine if there have been changes in their financial situation or investment
objectives. More frequent reviews can be triggered by changes to the client’s circumstances, by client request,
or major changes within the market. The underlying investment performance of client accounts are reviewed on
a more frequent basis. Portfolios are usually reviewed as frequently as weekly, and not less than monthly.
Triggering factors that can prompt more frequent review of underlying investments includes the relative valuation
changes between asset classes, valuation of the individual security, or economic or political changes that change
the perceived risk/reward ratio of a sector or sub-sector of the global or national economy.
Reports
Clients will receive account statements directly from the custodians, Schwab and Interactive Brokers. Statements
will be delivered no less than quarterly but as frequently as monthly. In addition, QuadCap can provide quarterly
newsletters covering general financial and investment topics, explaining current views of the global economies
and factors driving investment decisions.
Item 14 - Client Referrals and Other Compensation
QuadCap does not directly or indirectly receive compensation or any economic benefit from any person who is
not a client for providing its services to clients. QuadCap does not directly or indirectly provide compensation
to persons who are not supervised persons for client referrals.
Several QuadCap employees provide investment advice on behalf of our firm as licensed insurance agents. For
information on the conflicts of interest, and how QuadCap addresses these conflicts, refer to the Other Financial
Industry Activities and Affiliations section.
Item 15 - Custody
QuadCap does not maintain physical custody of any client fund or securities. Under the rules of the Investment
Advisers Act of 1940, QuadCap is deemed to have custody of client’s assets despite not having physical custody
in certain instances. For example, if a client authorizes QuadCap to instruct the custodian to deduct QuadCap’s
advisory fees directly from the client’s account, or if client establishes certain first party and/or any third-party
Standing Letters of Authorization (SLOAs) to move money from client’s account with QuadCap to a different
account, QuadCap is deemed to have custody.
Clients will receive account statements from the qualified custodian(s) holding the clients’ funds and securities
at least quarterly. The accounts statements from the custodian will indicate the amount of QuadCap’s advisory
fees deducted from the client’s account each billing period. Each client should carefully review account
statements for accuracy.
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Standing Letter of Authorization
QuadCap, or Advisory Representatives, can effect move money transfers from client accounts to one or more
third parties designated, in writing, by the client without obtaining written client consent for each separate,
individual transaction, as long as the client has provided QuadCap with written authorization to do so. Such
written authorization is known as a Standing Letter of Authorization. An adviser with authority to conduct such
third party move money transfers has access to the client’s assets and therefore has custody of the client’s assets
in any related accounts.
However, QuadCap does not have to obtain a surprise annual audit, as QuadCap otherwise would be required to
by reason of having custody, as long as the following criteria are met:
1. Client provides a written, signed instruction to the qualified custodian that includes the third party’s name
and address or account number at a custodian.
2. Client authorizes QuadCap in writing to direct transfers to the third party either on a specified schedule or
from time to time.
3. Cleint’s qualified custodian verifies client’s authorization (e.g., signature review) and provides a transfer of
funds notice to you promptly after each transfer.
4. Client can terminate or change the instruction.
5. QuadCap has no authority or ability to designate or change the identity of the third party, the address, or
any other information about the third party.
6. QuadCap maintains records showing that the third party is not a related party to us nor located at the same
address as us; and
7. Client’s qualified custodian sends the client, in writing, an initial notice confirming the instruction and an
annual notice reconfirming the instruction.
QuadCap complies with the conditions of the safe harbor provisions and is therefore exempt from the annual
surprise exam requirement for these standing letters of authorization.
Trustee Services
QuadCap is deemed to have custody over some accounts that QuadCap manages as certain related parties serve
as trustee over client accounts.
Considering this determination, QuadCap has engaged an independent public accountant to perform an annual
surprise audit of those accounts of which QuadCap is deemed to have custody.
Custody of separately managed account client assets will be maintained with the independent custodian selected
by the client. QuadCap will not have custody of any assets in the client’s account except as permitted for payment
of advisory fees. Clients will receive at least quarterly statements showing all transactions occurring in the client’s
account during the period covered by the account statement, and the funds, securities and other property in the
client’s account at the end of the period. This will come directly from the custodian. Clients are urged to compare
the account statement provided by the custodian with any statements provided by QuadCap.
We urge clients who receive any reports or account statements from QuadCap to carefully review these
statements along with the statements received from its custodian. Clients who identify any discrepancies or have
not timely received a statement from their custodian should contact QuadCap immediately.
Item 16 - Investment Discretion
Upon receiving written authorization from the client, QuadCap provides discretionary investment advisory
services for client accounts. QuadCap’s discretionary authority will be granted by the client in the client
agreement. When discretionary authority is granted, it is limited in that QuadCap will only be given discretionary
trading authority. This authority will allow QuadCap to determine the type of securities and the number of securities
that can be bought or sold for the client portfolio without obtaining the client’s consent for each transaction. In its
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sole discretion, QuadCap can agree to allow a client to restrict the types of investments QuadCap will participate
in on behalf of the client’s account.
Item 17 - Voting Client Securities
QuadCap does not perform proxy-voting services on a client’s behalf. Clients are instructed to read through the
information provided with the proxy-voting documents and to make a determination based on the information
provided. Upon request from the client, QuadCap can provide limited clarifications of the issues presented in the
proxy voting materials based on QuadCap’s understanding of issues presented in the proxy-voting materials.
However, the client will have the ultimate responsibility for making all proxy-voting decisions.
Item 18 - Financial Information
QuadCap does not require or solicit prepayment of fees by any client six months or more in advance. As
described in Item 5, fees for financial planning services are calculated for a six-month period and paid in
advance, but less than six months in advance. As discussed in Item 4 – Advisory Business, above, QuadCap
can direct clients to third-party money managers with respect to a portion, or all of, a client’s assets. Under these
arrangements, QuadCap will be compensated via a fee share from the advisers to which it directs those clients.
The fees shared will not exceed any limit imposed by any regulatory agency but can be paid to QuadCap in
advance.
QuadCap does not foresee any financial condition that is reasonably likely to impair its ability to meet
contractual commitments to its clients.
QuadCap has not been the subject of a bankruptcy petition at any time during the past ten (10) years.
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