View Document Text
Disclosure Brochure April 28, 2025
a Registered Investment Adviser
4001 Maple Avenue, Suite 290
Dallas, TX 75219
(469) 373-3399
www.requisitecm.com
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Requisite Capital Management, LLC (“Requisite Capital” or the “Advisor”). If you have any
questions about the content of this Disclosure Brochure, please contact the Advisor at (469) 373-3399.
Requisite Capital is a registered investment advisor with the U.S. Securities and Exchange Commission
(“SEC”). The information in this Disclosure Brochure has not been approved or verified by the SEC or by any
state securities authority. Registration of an investment advisor does not imply any specific level of skill or
training. This Disclosure Brochure provides information about Requisite Capital to assist you in determining
whether to retain the Advisor.
Additional information about Requisite Capital and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 283107.
Disclosure Brochure Requisite Capital Management, LLC
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the
Advisory Persons of Requisite Capital. For convenience, the Advisor has combined these documents into a
single disclosure document.
Requisite Capital believes that communication and transparency are the foundation of its relationship with
clients and will continually strive to provide you with complete and accurate information at all times.
Requisite Capital encourages all current and prospective clients to read this Disclosure Brochure and
discuss any questions you may have with the Advisor.
Material Changes
There following material changes have been made to this Disclosure Brochure since the last annual
amendment filing on March 27, 2024.:
• The Advisor has appointed Thomas Yates as Chief Compliance Officer.
• The Advisor has updated its phone number to (469) 373-3399.
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 283107.
You may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (469) 373-
3399.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 2
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Item 3 – Table of Contents
Item 1 – Cover Page
Item 2 – Material Changes
Item 3 – Table of Contents
Item 4 – Advisory Services
A. Firm Information
B. Advisory Services Offered
C. Client Account Management
D. Wrap Fee Programs
E. Assets Under Management
Item 5 – Fees and Compensation
A. Fees for Advisory Services
B. Fee Billing
C. Other Fees and Expenses
D. Advance Payment of Fees and Termination
E. Compensation for Sales of Securities
Item 6 – Performance-Based Fees and Side-By-Side Management
Item 7 – Types of Clients
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
B. Risk of Loss
Item 9 – Disciplinary Information
Item 10 – Other Financial Industry Activities and Affiliations
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
B. Personal Trading with Material Interest
C. Personal Trading in Same Securities as Clients
D. Personal Trading at Same Time as Client
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
B. Aggregating and Allocating Trades
Item 13 – Review of Accounts
A. Frequency of Reviews
B. Causes for Reviews
C. Review Reports
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Requisite Capital
B. Compensation for Client Referrals
Item 15 – Custody
Item 16 – Investment Discretion
Item 17 – Voting Client Securities
Item 18 – Financial Information
Form ADV 2B – Brochure Supplements
Privacy Policy
1
1
2
4
4
4
7
7
7
7
7
8
9
9
9
10
10
10
10
11
12
13
13
13
13
13
14
14
14
15
15
15
15
16
16
16
17
17
17
18
18
19
35
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 3
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Item 4 – Advisory Services
A. Firm Information
Requisite Capital Management, LLC (“Requisite Capital” or the “Advisor”) is a registered investment advisor
with the U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company
(“LLC”) under the laws of the State of Delaware and is located in the State of Texas. Requisite Capital was
founded in June 2017 and is owned by Douglas G. John (Managing Partner), Bryn T. Talkington (Managing
Partner) and CWC Ranger Investor LLC (Member), an entity controlled by Constellation Wealth Capital. The
Advisor is operated by both Mr. John and Ms. Talkington. This Disclosure Brochure provides information
regarding the qualifications, business practices, and the advisory services provided by Requisite Capital. For
information regarding this Disclosure Brochure, please contact Bryn Talkington at (469) 373-3399 or by email
at bryn.talkington@requisitecm.com.
B. Advisory Services Offered
Requisite Capital offers investment advisory services to individuals, high net worth individuals, trusts,
estates, and charitable organizations (each referred to as a “Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a
fiduciary, the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to
mitigate potential conflicts of interest. Requisite Capital’s fiduciary commitment is further described in the
Advisor’s Code of Ethics. For more information regarding the Code of Ethics, please see Item 11 – Code of
Ethics, Participation or Interest in Client Transactions and Personal Trading.
Wealth Management Services
Requisite Capital provides Clients with wealth management services, which generally includes a broad
range of comprehensive financial planning, consulting services, asset allocation and financial reporting in
connection with discretionary management of investment portfolios. These services are described below.
Investment Management Services – Requisite Capital provides customized investment advisory solutions for
its Clients. This is achieved through continuous personal Client contact and interaction while providing
discretionary and non-discretionary investment management and related advisory services. Requisite
Capital works closely with each Client to identify their investment goals and objectives as well as risk
tolerance and financial situation in order to create a portfolio strategy. Requisite Capital will then construct
an investment portfolio, which can consist of, but not limited to:
International Securities
● Exchange-traded funds (“ETFs”)
● Private Equity Funds
● Private Credit Funds
● Direct Investments
● Option Contracts
● Equities
● Preferred Securities
●
● Fixed Income
● Master Limited Partnerships
● Margin transactions
● Mutual Funds
The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with the
overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 4
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Client.. Requisite Capital’s investment approach is primarily long-term focused, but the Advisor may buy, sell
or re-allocate positions that have been held less than one year to meet the objectives of the Client or due to
market conditions. Requisite Capital will construct, implement and monitor the portfolio to ensure it meets
the goals, objectives, circumstances, and risk tolerance agreed to by the Client. Each Client will have the
opportunity to place reasonable restrictions on the types of investments to be held in their respective
portfolio, subject to acceptance by the Advisor.
Requisite Capital evaluates and selects investments for inclusion in Client portfolios only after applying its
internal due diligence process. Requisite Capital may recommend specific positions to increase sector or
asset class weightings. The Advisor may recommend employing cash positions as a possible hedge against
market movement. Requisite Capital may recommend selling positions for reasons that include, but are not
limited to, harvesting capital gains or losses, business or sector risk exposure to a specific security or class of
securities, overvaluation or overweighting of the position[s] in the portfolio, change in risk tolerance of Client,
generating cash to meet Client needs, or any risk deemed unacceptable for the Client’s risk tolerance.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of
the Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as
applicable, which are laws governing retirement accounts. When deemed to be in the Client’s best interest,
the Advisor will provide investment advice to a Client regarding a distribution from an ERISA retirement
account or to roll over the assets to an IRA, or recommend a similar transaction including rollovers from one
ERISA sponsored Plan to another, one IRA to another IRA, or from one type of account to another account
(e.g., commission-based account to fee-based account). Such a recommendation creates a conflict of
interest if the Advisor will earn a new (or increase its current) advisory fee as a result of the transaction. No
client is under any obligation to roll over a retirement account to an account managed by the Advisor.
Use of Independent Managers – Requisite Capital, depending on the Client’s needs and objectives,
recommend that a Client utilize one or more unaffiliated investment managers or investment platforms
(collectively “Independent Managers”) for all or a portion of a Client’s investment portfolio. In such instances,
the Client may be required to authorize and enter into an advisory agreement with the Independent
Manager[s] that defines the terms in which the Independent Manager[s] will provide investment
management and related services. The Advisor assists in the development of the initial policy
recommendations and managing the ongoing Client relationship. The Advisor will perform initial and
ongoing oversight and due diligence over the selected Independent Manager[s] to ensure the Independent
Managers’ strategies and target allocations remain aligned with its clients’ investment objectives and overall
best interests. The Client, prior to entering into an agreement with unaffiliated investment manager[s] or
investment platform[s], will be provided with the Independent Manager's Form ADV 2A (or a brochure that
makes the appropriate disclosures).
Under certain circumstances, Requisite Capital may accept or maintain custody of Client’s funds or
securities. Please see Item 15 – Custody for more information.
Private Fund Investments - The Advisor provides investment advice regarding unaffiliated private investment
funds. The Advisor’s role relative to the private investment funds shall be limited to its initial and ongoing due
diligence and investment monitoring services. If a Client invests in a private fund, the amount of assets
invested in the fund[s] shall be included as part of “assets under management” for purposes of the Advisor
calculating its investment advisory fee. The Advisor’s Clients are under no obligation to consider or make an
investment in a private investment fund[s]. The Advisor may receive a portion of an incentive fee for certain
investments into the Private Funds. In addition, the Advisor may also be entitled to receive revenues for certain
private funds where Client assets are invested. If the Advisor receives any additional fees from private
investment funds, the Advisor will not charge an advisory fee on those assets.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 5
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
The Advisor may introduce Clients to a private investment fund for which Requisite Capital or affiliated person
serves as the Investment Advisor (herein the “Fund”). The Advisor’s Clients are under no obligation to consider
or make an investment in the Fund. For additional information, please see Item 10 – Other Financial Industry
Activities and Affiliations below.
Financial Planning Services – Requisite Capital will typically provide a variety of financial planning and
consulting services to Clients. Services are offered in several areas of a Client’s financial situation, depending
on their goals and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement
planning, personal savings, education savings and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or
alter retirement savings, establish education savings and/or charitable giving programs.
Requisite Capital may also refer Clients to an accountant, attorney or other specialists, as appropriate for
their unique situation. For certain financial planning engagements, the Advisor will provide a written
summary of the Client’s financial situation, observations, and recommendations. For consulting or ad-hoc
engagements, the Advisor may not provide a written summary. Plans or consultations are typically
completed within six (6) months of contract date, assuming all information and documents requested are
provided promptly.
Financial planning and consulting recommendations pose a conflict between the interests of the Advisor
and the interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage
the Advisor for investment management services or to increase the level of investment assets with the
Advisor, as it would increase the amount of advisory fees paid to the Advisor. Clients are not obligated to
implement any recommendations made by the Advisor or maintain an ongoing relationship with the Advisor.
If the Client elects to act on any of the recommendations made by the Advisor, the Client is under no
obligation to implement the transaction through the Advisor.
Reporting Services – Requisite Capital may provide Clients with periodic evaluation reports of accounts and
each portion managed by the Advisor or an Independent Manager. The report details the performance and
asset allocation of the account[s] managed by the respective managers. Requisite receives its information
from account custodians, Independent Managers and other third parties. To the extent that erroneous
information is provided due to inaccurate data from a third-party, the Advisor is not responsible for any
inaccuracies which are contained in the report. At the Client’s request, Requisite Capital will consider the
asset classes of investments that are not managed by the Advisor for asset allocation purposes and may
report the performance of those investments relative to an appropriate benchmark but will not otherwise
provide due diligence or monitoring services on such assets. Including outside investments in performance
reports does not constitute investment advice or a recommendation or endorsement by Requisite Capital.
Private Fund Investments
The Advisor provides investment advice or private investment funds. The Advisor and/or its Principal is the
General Partner and/or Investment Advisor to private funds issued (the Affiliated Fund[s]). If a Client
determines to invest in an Affiliated Fund, the amount of assets invested in the Affiliated Fund shall be
included as part of “assets under management” for purposes of the Advisor calculating its investment advisory
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 6
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
fee per Item 5 below. The Advisor’s Clients are under no obligation to consider or make an investment in an
Affiliated Fund.
The Advisor does not receive a separate advisory fee or other forms of compensation for its investment
advisory services to any Affiliated Funds. Rather, the Advisor’s only compensation is the advisory fee that it
receives from any value included as a part of assets under management.
C. Client Account Management
Prior to engaging Requisite Capital to provide investment advisory services, each Client is required to enter
into one or more agreements with the Advisor that define the terms, conditions, authority and
responsibilities of the Advisor and the Client. These services may include:
● Establishing an Investment Strategy – Requisite Capital, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals objectives.
● Asset Allocation – Requisite Capital will develop a strategic asset allocation that is targeted to meet
the investment objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – Requisite Capital will develop a portfolio for the Client that is intended to
●
meet the stated goals and objectives of the Client.
Investment Management and Supervision – Requisite Capital will provide investment management
and ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Requisite Capital does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by Requisite Capital.
E. Assets Under Management
As of December 31, 2024, Requisite oversees $2,794,620,109 in assets including: (i) regulatory assets under
management of $1,987,793,761 ($870,587,004 Discretionary / $1,117,206,757 Non-Discretionary) and (ii)
assets under advisement (“AUA”) of $806,826,348.00
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by
the Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into
one or more written agreements with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
For Clients engaged for comprehensive wealth management services, the Client will be charged a single
combined fee for investment management and financial planning services based on the market value of
assets under management.
Investment advisory fees are prorated and paid quarterly, in advance of each calendar quarter, pursuant to
the terms of the agreement. Investment advisory fees are based on the market value of assets under
management at the end of the prior calendar quarter. Investment advisory fees are prorated for any
deposits and withdrawals throughout the quarter and reflected in the next quarter’s fee. Investment advisory
fees generally range from 0.35% to 1.00%, or an agreed upon fixed fee, annually based on several factors,
including: the complexity of the services to be provided, wealth planning services, reporting needs, the level
of assets to be managed, and the overall relationship with the Advisor. Relationships with multiple
objectives, specific reporting requirements, portfolio restrictions and other complexities may be charged a
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 7
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
higher fee. Clients that elect to be charged a fixed annual fee for the Advisor’s wealth management services;
fees will not exceed the above disclosed rate.
The investment advisory fee in the first quarter of service is prorated from the inception date of the
account[s] to the end of the first quarter. Fees are negotiable at the sole discretion of the Advisor. The
Client’s fees will take into consideration the aggregate assets under management with the Advisor. All
securities held in accounts managed by Requisite Capital will be independently valued by the Custodian.
Requisite Capital will conduct periodic reviews of the Custodian’s valuations. The Advisor will conduct
periodic reviews of the Custodian’s valuation to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees,
and other related costs and expenses described in Item 5.C below, which will be incurred by the Client.
However, the Advisor shall not receive any portion of these commissions, fees, and costs.
Use of Independent Managers
For Clients referred by the Advisor to an Independent Manager, the Client’s fee may be separately billed or
deducted from the Client’s account[s] by the Independent Manager.
Financial Planning Services
Requisite Capital offers financial planning services for a fixed fee ranging from $2,500 to $25,000. Fees may
be negotiable based on the nature and complexity of the services to be provided and the overall
relationship with the Advisor. An estimate for total costs will be determined prior to establishing the advisory
relationship.
B. Fee Billing
Wealth Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s
account[s] at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the
fees to be deducted from the Client’s account[s] at the beginning of the respective quarter. The amount due
is calculated by applying the quarterly rate (# of days in the quarter divided by 365) to the total assets under
management with Requisite Capital at the end of the prior quarter. Requisite will then calculate the average
daily balance during the respective billing period, taking into account assets that are deposited into or
withdrawn from an account[s]. The investment advisory fee is then adjusted at the end of the quarter to
reflect the actual average daily balance during the billing period. Clients will be provided with a statement,
at least quarterly, from the Custodian reflecting deduction of the investment advisory fee. It is the
responsibility of the Client to verify the accuracy of these fees as listed on the Custodian’s brokerage
statement as the Custodian does not assume this responsibility. Clients provide written authorization
permitting advisory fees to be deducted by Requisite Capital directly from their account[s] held by the
Custodian as part of the investment advisory agreement and separate account forms provided by the
Custodian.
Use of Independent Managers
For Clients referred by the Advisor to an Independent Manager, the Client’s fee may be separately billed or
deducted from the Client’s account[s] with the respective manager and a portion of the investment advisory
fee may be provided to Requisite Capital.
Financial Planning Services
Financial planning fees may be invoiced up to twenty-five percent (25%) of the expected total fee upon
execution of the financial planning agreement. The balance shall be invoiced upon completion of the
agreed upon deliverable[s].
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 8
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
C. Other Fees and Expenses
Clients will incur certain fees or charges imposed by third parties in connection with investments made on
behalf of the Client’s account[s]. The Client is responsible for all securities execution and custody fees
charged by the Custodian, if applicable. Certain custodians recommended by the Advisor do not charge
securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets
the terms and conditions of the custodian's brokerage requirements. However, the Custodian typically
charges for mutual funds and other types of investments. The fees charged by the Advisor are separate and
distinct from these custody and execution fees.
Investment advisory fees are separate and distinct from the expenses charged by mutual funds and ETFs to
their shareholders, if applicable. These fees and expenses are described in each fund’s prospectus. These
fees and expenses will generally be used to pay management fees for the funds, other fund expenses,
account administration (e.g., custody, brokerage and account reporting), and a possible distribution fee. A
Client may be able to invest in these products directly, without the services of Requisite Capital, but would
not receive the services provided by Requisite Capital which are designed, among other things, to assist the
Client in determining which products or services are most appropriate for each Client’s financial situation
and objectives. Clients will not be responsible for any wire fees or other related wire costs, as the Advisor
has negotiated to pay the Custodian an agreed upon fixed fee to have these costs waived. Accordingly, the
Client should review both the fees charged by the fund[s] and the fees charged by Requisite Capital to fully
understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices for additional information.
D. Advance Payment of Fees and Termination
Wealth Management Services
Requisite Capital is compensated for its services in advance of the quarter in which investment advisory
services are rendered. Either party may terminate the investment advisory agreement, at any time, by
providing advance notice to the other party. At termination, the Client will incur charges for bona fide
advisory services rendered to the point of termination and such fees will be due and payable by the Client.
The Advisor will refund any unearned, prepaid investment advisory fees from the effective date of
termination to the end of the quarter. The Client’s investment advisory agreement with the Advisor is non-
transferable without the Client’s prior consent.
Use of Independent Managers
In the event that a Client should wish to terminate their relationship with the Independent Manager, the
terms for termination will be set forth in the respective agreements between the Client and that
Independent Manager. Requisite Capital will assist the Client with the termination and transition as
appropriate.
Financial Planning Services
Requisite Capital requires an advance deposit as described above. Either party may terminate the financial
planning agreement by providing advance written notice to the other party. The Client may also terminate
the financial planning agreement within five (5) business days of signing the Advisor’s agreement at no cost
to the Client. After the five-day period, the Client will incur charges for bona fide advisory services rendered
to the point of termination and such fees will be due and payable by the Client. Upon termination, the Client
shall be billed for the percentage of the engagement scope completed by the Advisor. The Advisor will
refund any unearned, prepaid financial planning fees from the effective date of termination. The Client’s
financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 9
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Requisite Capital does not buy or sell securities and does not receive any compensation for securities
transactions in any Client account, other than the investment advisory fees noted above.
Item 6 – Performance-Based Fees and Side-By-Side Management
The Advisor may receive a performance-based fee upon specific gains obtained in the accounts of
“Qualified Clients” pursuant to the terms of the investment advisory agreement. Only Qualified Clients with
either $1,000,000 under management with the Advisor or a net worth of $2,100,000 will be charged a
performance-based fee.
Qualified Clients will be charged the investment advisory fee described in Item 5 – Fees and Compensation
billed quarterly in advance.
Who is a “Qualified Client”?
The Investment Advisers Act of 1940 (the “Advisers Act”), Rule 205-3(d)(1) defines a “Qualified Client” who is
financially sophisticated and meets one or more of the following conditions:
● Client is a natural person who, or a company that, immediately after entering into the contract has at
least $1,000,000 under the management of the Advisor;
● Client is a natural person who, or a company that, immediately prior to entering into the contract has
a net worth (together, in the case of a natural person, with assets held jointly with a spouse) of more
than $2,100,000 at the time the contract is entered into.
The receipt of a performance-based fee by certain Clients results in a potential conflict of interest, where
Requisite Capital has the potential for higher compensation from a Client. Requisite Capital will not charge
an investment advisory fee to Clients that are charged a performance fee.
Item 7 – Types of Clients
Requisite Capital offers investment advisory services to individuals, high net worth individuals, trusts,
estates, pooled investment vehicles and charitable organizations. The amount of each type of Client is
available on Requisite Capital’s Form ADV Part 1A. These amounts may change over time and are updated at
least annually by the Advisor. Typically, Requisite Capital requires either a minimum relationship size of
$5,000,000 or a minimum investment advisory fee of $35,000. The minimum relationship size or fee may be
waived at the sole discretion of the Advisor.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Requisite Capital primarily employs fundamental and technical analysis methods in developing investment
strategies for its Clients. Research and analysis from Requisite Capital is derived from numerous sources,
including third-party research materials, Internet sources, and review of company activities, including annual
reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the
entity being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a
strong investment with a value discounted by the market. While this type of analysis helps the Advisor in
evaluating a potential investment, it does not guarantee that the investment will increase in value. Assets
meeting the investment criteria utilized in the fundamental analysis may lose value and may have negative
investment performance. The Advisor monitors these economic indicators to determine if adjustments to
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 10
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
strategic allocations are appropriate. More details on the Advisor’s review process are included below in
Item 13 – Review of Accounts.
Technical analysis involves the analysis of past market data rather than specific company data in
determining the recommendations made to clients. Technical analysis may involve the use of charts to
identify market patterns and trends, which may be based on investor sentiment rather than the
fundamentals of the company. The primary risk in using technical analysis is that spotting historical trends
may not help to predict such trends in the future. Even if the trend will eventually reoccur, there is no
guarantee that Requisite Capital will be able to accurately predict such a reoccurrence.
As noted above, Requisite Capital generally employs a long-term investment strategy for its Clients, as
consistent with their financial goals. Requisite Capital will typically hold all or a portion of a security for more
than a year but may hold for shorter periods for the purpose of rebalancing a portfolio or meeting the cash
needs of Clients. At times, Requisite Capital may also buy and sell positions that are more short-term in
nature, depending on the goals of the Client and/or the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value.
Clients should be prepared to bear the potential risk of loss. Requisite Capital will assist Clients in
determining an appropriate strategy based on their tolerance for risk and other factors noted above.
However, there is no guarantee that a Client will meet their investment goals.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee
that the investment will increase in value. Assets meeting the investment criteria utilized in these methods of
analysis may lose value and may have negative investment performance. The Advisor monitors these
economic indicators to determine if adjustments to strategic allocations are appropriate. More details on the
Advisor’s review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account.
Client participation in this process, including full and accurate disclosure of requested information, is
essential for the analysis of a Client's account[s]. The Advisor shall rely on the financial and other information
provided by the Client or their designees without the duty or obligation to validate the accuracy and
completeness of the provided information. It is the responsibility of the Client to inform the Advisor of any
changes in financial condition, goals or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process.
Following are some of the risks associated with the Advisor’s investment approach:
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as
well as economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of
the overall financial markets.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the
ETFs will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have
a trading risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 11
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
ETFs have a large bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the
market movements and may dissociate from the index being tracked by the ETF or the price of the
underlying investments. An ETF purchased or sold at one point in the day may have a different price than
the same ETF purchased or sold a short time later.
Mutual Fund Risks
The performance of mutual funds are subject to market risk, including the possible loss of principal. The
price of the mutual funds will fluctuate with the value of the underlying securities that make up the funds.
The price of a mutual fund is typically set daily therefore a mutual fund purchased at one point in the day
will typically have the same price as a mutual fund purchased later that same day.
Options Contracts
Investments in options contracts have the risk of losing value in a relatively short period of time. Option
contracts are leveraged instruments that allow the holder of a single contract to control many shares of an
underlying stock. This leverage can compound gains or losses.
Margin Borrowings
The use of short-term margin borrowings may result in certain additional risks to a Client. For example, if
securities pledged to brokers to secure a Client's margin accounts decline in value, the Client could be
subject to a "margin call", pursuant to which it must either deposit additional funds with the broker or be the
subject of mandatory liquidation of the pledged securities to compensate for the decline in value.
Short Sales
A short sale involves the sale of a security that the Client does not own in the hope of purchasing the same
security at a later date at a lower price. To make delivery to the buyer, the Client must borrow the security
and is obligated to return the security to the lender, which is accomplished by a later purchase of the
security. The Client realizes a profit or a loss as a result of a short sale if the price of the security decreases
or increases respectively between the date of the short sale and the date on which the Client covers its
short position, i.e., purchases the security to replace the borrowed security. A short sale involves the
theoretically unlimited risk of an increase in the market price of the security that would result in a
theoretically unlimited loss.
Alternative Investments (Limited Partnerships)
The performance of alternative investments (limited partnerships) is typically shown quarterly and may have
limited liquidity. An investor could lose all or a portion of their investment. Such investments often have
concentrated positions and investments that may carry higher risks. Clients should only have a portion of
their assets in these investments.
International Investments
Investing in, or having exposure to, foreign domiciled investments may involve risk of capital loss from
unfavorable fluctuation in currency values, withholding taxes, from differences in generally accepted
accounting principles or from economic or political instability in other nations.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
Requisite Capital values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the
requisite due diligence on any advisor or service provider that the Client engages. The backgrounds of the
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 12
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Advisor and its Advisory Persons are available on the Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching by the Advisor’s firm name or CRD# 283107.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliations
Advisory Persons of Requisite Capital serve as licensed insurance professionals. Implementations of
insurance recommendations are separate and apart from an Advisory Person’s role with Requisite Capital.
As insurance professionals, Advisory Persons will receive customary commissions and other related
revenues from the various insurance companies whose products are sold. Commissions generated by
insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending insurance products. Clients are under no obligation to implement any recommendations
made by the Advisor or its Advisory Persons.
Private Fund
As noted in Item 4 – Advisory Services, there is an affiliation due to common ownership between Requisite
Capital and RCM GP, LLC (“RCM GP”). Douglas John serves as the manager to the Marble Capital Fund III-
Credit Facility, LLC and Marble Capital Fund IV Credit Facility, LLC (the “Marble Credit Fund”). Advisory
Persons may make such vehicles available for investment by Qualified Purchasers. This causes a conflict of
interest as the Advisor has an incentive to recommend investments in the Marble Fund due to the common
ownership. The Advisor nor any affiliated person receives any additional compensation from the Marble
Credit Fund.
Committee / Advisory Board
Certain Advisory Persons may serve on a committee and/or advisory board for certain private funds and/or
companies associated with the private fund, where the Advisor recommended such investments. To remove
any conflict, no Advisory Person will receive additional compensation related to serving on the committee
and/or advisory board.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Requisite Capital has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary
commitment to each Client. This Code applies to all persons associated with Requisite Capital (“Supervised
Persons”). The Code was developed to provide general ethical guidelines and specific instructions regarding
the Advisor’s duties to the Client. Requisite Capital and its Supervised Persons owe a duty of loyalty, fairness
and good faith towards each Client. It is the obligation of Requisite Capital’s Supervised Persons to adhere
not only to the specific provisions of the Code, but also to the general principles that guide the Code. The
Code covers a range of topics that address employee ethics and conflicts of interest. To request a copy of
the Code, please contact the Advisor at (469) 373-3399.
B. Personal Trading with Material Interest
Requisite Capital allows Supervised Persons to purchase or sell the same securities that are recommended
to and purchased on behalf of Clients. Requisite Capital does not act as principal in any transactions. In
addition, the Advisor does not act as the general partner of a fund or advise an investment company.
Requisite Capital does not have a material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Requisite Capital allows Supervised Persons to purchase or sell the same securities that are recommended
to and purchased on behalf of Clients. Owning the same securities that are recommended (purchase or sell)
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 13
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
to Clients presents a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated
through policies and procedures. The Advisor has adopted the Code to address insider trading (material
non-public information controls); gifts and entertainment; outside business activities and personal securities
reporting. When trading for personal accounts, Supervised Persons have a conflict of interest if trading in the
same securities. The fiduciary duty to act in the best interest of its Clients can be violated if personal trades
are made with more advantageous terms than Client trades, or by trading based on material non-public
information. This risk is mitigated by Requisite Capital requiring reporting of personal securities trades by its
Supervised Persons for review by the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also
adopted written policies and procedures to detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Requisite Capital allows Supervised Persons to purchase or sell the same securities that are
recommended to and purchased on behalf of Clients, such trades are typically aggregated with Client
orders or traded afterward. At no time will Requisite Capital, or any Supervised Person of Requisite
Capital, transact in any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Requisite Capital does not have discretionary authority to select the broker-dealer/custodian for custody
and execution services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to
safeguard Client assets and authorize Requisite Capital to direct trades to the Custodian as agreed upon in
the investment advisory agreement. Further, Requisite Capital does not have the discretionary authority to
negotiate commissions on behalf of Clients on a trade-by-trade basis.
Where Requisite Capital does not exercise discretion over the selection of the Custodian, recommends the
Custodian[s] to Clients for custody and execution services. Clients are not obligated to use the Custodian
recommended by Requisite Capital and will not incur any extra fee or cost from the Advisor associated with
using a custodian not recommended by Requisite . However, the Advisor may be limited in the services it
can provide if the recommended Custodian is not engaged. Typically, Requisite Capital will recommend that
Clients establish their account[s] with either Interactive Brokers LLC (“Interactive Brokers”), Fidelity Clearing
& Custody Solutions, and related entities of Fidelity Investments, Inc. (collectively “Fidelity”) or Charles
Schwab & Co., Inc. (“Schwab” ), Interactive Brokers, Fidelity and Schwab (collectively the “Custodians”) serve
as a “qualified custodian” for Client accounts. The Advisor maintains institutional relationships with
Interactive Brokers and Fidelity. Please see Item 14 below.
Factors which the Advisor considers in recommending Interactive Brokers, Fidelity or Schwab to Clients
include their respective financial strength, reputation, execution, pricing, and research service. The
commissions and/or transaction fees charged by Interactive Brokers and Fidelity may be higher or lower
than those charged by other financial institutions. The Advisor maintains an institutional relationship with
Interactive Brokers and Fidelity, whereby the Advisor receives certain benefits. Please see Item 14 below.
Following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an
advisor enters into an agreement to place security trades with a broker-dealer/custodian in exchange for
research and other services. Requisite Capital does not participate in soft dollar programs sponsored or
offered by any broker-dealer/custodian. However, the Advisor receives certain economic benefits from
the Custodian. Please see Item 14 below.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 14
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
2. Brokerage Referrals - Requisite Capital does not receive any compensation from any third party in
connection with the recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Requisite Capital will
place trades within the established account[s] at the Custodian designated by the Client. Further, all Client
accounts are traded within their respective account[s]. The Advisor will not engage in any principal
transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with other
Client accounts (i.e., purchase of a security into one Client account from another Client’s account[s]).
Requisite Capital will not be obligated to select competitive bids on securities transactions and does not
have an obligation to seek the lowest available transaction costs. These costs are determined by the
Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to
obtain the most favorable net results taking into account such factors as 1) price, 2) size of the order, 3)
difficulty of execution, 4) confidentiality and 5) skill required of the Custodian. Requisite Capital will execute
its transactions through the Custodian as authorized by the Client.
Requisite Capital may aggregate orders in a block trade or trades when securities are purchased or sold
through the Custodian for multiple (discretionary) accounts in the same trading day. If a block trade cannot
be executed in full at the same price or time, the securities actually purchased or sold by the close of each
business day must be allocated in a manner that is consistent with the initial pre-allocation or other written
statement. This must be done in a way that does not consistently advantage or disadvantage any particular
Clients’ accounts. The following circumstances include, but are not limited to when Requisite Capital would
not include Client account[s] in an aggregate or block trade;
• Client account[s] are comingled or part of a customized strategy, where trades are completed
manually
• Client account is a part of the Dollar Cost Averaging strategy, multiple portfolios of varying size and
circumstances are traded throughout the day. The timing of entry and size of trades could cause
trade errors if aggregated or blocked at the end of day, so manual trade execution is required.
• Ad hoc purchases of the same security are unrelated and made at different times of the day, these
trades are unable to be aggregated or blocked.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Bryn Talkington, Managing
Partner of Requisite Capital. Formal reviews are generally conducted at least annually or more frequently
depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as
a result of major changes in economic conditions, known changes in the Client’s financial situation, and/or
large deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Requisite Capital if
changes occur in the Client’s personal financial situation that might adversely affect the Client’s investment
plan. Additional reviews may be triggered by material market, economic or political events.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 15
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic
access to the Custodian’s website so that the Client may view these reports and their account activity. Client
brokerage statements will include all positions, transactions and fees relating to the Client’s account[s]. The
Advisor may also provide Clients with periodic reports regarding their holdings, allocations, and
performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Requisite Capital
Participation in Institutional Advisor Platform
Requisite Capital has established an institutional relationship with the Custodians to assist the Advisor in
managing Client account[s]. The Advisor receives access to software and related support as part of its
relationship with the Custodians. The software and related systems support may benefit the Advisor, but not
its Clients directly. In fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of
its Clients first. Clients should be aware, however, that the receipt of economic benefits from a Custodian
creates a potential conflict of interest since these benefits may influence the Advisor's recommendation of
the Custodian over one that does not furnish similar software, systems support, or services.
Additionally, the Advisor receives the following benefits from the Custodians: reimbursement to Clients for
transfer costs to the platform/custodian; financing services, receipt of duplicate Client confirmations and
bundled duplicate statements; access to a trading desk that exclusively services its institutional participants;
access to block trading which provides the ability to aggregate securities transactions and then allocate the
appropriate shares to Client accounts; and access to an electronic communication network for Client order
entry and account information.
Participation in Institutional Advisor Platform
Requisite Capital has established an institutional relationship with Schwab through its “Schwab Advisor
Services” unit, a division of Schwab dedicated to serving independent advisory firms like Requisite Capital.
As a registered investment advisor participating on the Schwab Advisor Services platform, Requisite Capital
receives access to software and related support without cost because the Advisor renders investment
management services to Clients that maintain assets at Schwab. Services provided by Schwab Advisor
Services benefit the Advisor and many, but not all services provided by Schwab will benefit Clients. In
fulfilling its duties to its Clients, the Advisor endeavors at all times to put the interests of its Clients first.
Clients should be aware, however, that the receipt of economic benefits from a custodian creates a
potential conflict of interest since these benefits may influence the Advisor's recommendation of this
custodian over one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities.
Through Schwab, the Advisor may be able to access certain investments and asset classes that the Client
would not be able to obtain directly or through other sources. Further, the Advisor may be able to invest in
certain mutual funds and other investments without having to adhere to investment minimums that might
be required if the Client were to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate statements
for Client accounts, the ability to deduct advisory fees, trading tools, and back-office support services as
part of its relationship with Schwab. These services are intended to assist the Advisor in effectively
managing accounts for its Clients but may not directly benefit all Clients.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 16
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to
Requisite Capital that may not benefit the Client, including: educational conferences and events, financial
start-up support, consulting services and discounts for various service providers. Access to these services
creates a financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of
interest. Requisite Capital believes, however, that the selection of Schwab as Custodian is in the best
interests of its Clients.
Requisite Capital is incented to remain affiliated with Schwab and to recommend that Clients establish
accounts with Schwab due to financial support received from Schwab. Through the relationship with
Schwab, Requisite Capital will receive support payment for technology, marketing and compliance
consulting related expenses based on a specific amount of Client assets to be custodied with Schwab. The
receipt of any such compensation creates a financial incentive for Requisite Capital to recommend Schwab
the Custodian for the assets in your account. This conflict is mitigated through disclosure and that Clients
are not obligated to utilize Requisite Capital’s recommended Custodian. Additionally, as mentioned above,
the Client may directly or indirectly receive other benefits through the engagement with Schwab. Requisite
encourages you to discuss any such conflicts of interest with us before making a decision to custody your
assets at Schwab.
Unaffiliated Private Funds
Requisite may recommend that Clients invest in certain unaffiliated private funds, where the Advisor may
receive additional fees or revenue. In such arrangements, Requisite has a conflict of interest in that Requisite
will receive separate compensation from the unaffiliated private funds in the form of either incentive fee or
revenue share. The conflict is mitigated by an internal policy mandating that the Advisor will not charge a
separate investment advisory fee for the management of the assets placed in these unaffiliated private
funds. Clients are under no obligation to invest in any private fund recommended by the Advisor.
B. Compensation for Client Referrals
Requisite Capital does not compensate, either directly or indirectly, any persons who are not supervised
persons, for Client referrals.
Item 15 – Custody
All Clients must place their assets with a “qualified custodian”. Clients are required to engage the Custodian
to retain their funds and securities and direct Requisite Capital to utilize the Custodian for the Client’s
security transactions. Clients are urged to compare statements provided by the Custodian to any reports
provided by Requisite Capital to ensure accuracy, as the custodian does not perform this review. For more
information about custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor
may have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and
the Advisor have adopted safeguards to ensure that the money movements are completed in accordance
with the Client’s instructions.
Item 16 – Investment Discretion
Requisite Capital generally has discretion over the selection and amount of securities to be bought or sold in
Client accounts without obtaining prior consent or approval from the Client. However, these purchases or
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 17
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
sales may be subject to specified investment objectives, guidelines, or limitations previously set forth by the
Client and agreed to by Requisite Capital. Discretionary authority will only be authorized upon full disclosure
to the Client. The granting of such authority will be evidenced by the Client's execution of an investment
advisory agreement containing all applicable limitations to such authority. All discretionary trades made by
Requisite Capital will be in accordance with each Client's investment objectives and goals.
For certain engagements, Requisite Capital does not have discretion over the selection and amount of
securities to be bought or sold in Client accounts without obtaining prior approval from the Client. For these
non-discretionary engagements, the Advisor will contact the Client and obtain approval prior to executing
trades or allocating investment assets.
Item 17 – Voting Client Securities
Requisite Capital generally does not accept proxy voting responsibilities. Clients will receive proxy
statements directly from the Custodian. The Advisor will assist in answering questions relating to proxies,
however, the Client retains the sole responsibility for proxy decisions and voting.
In very limited circumstances, the Advisor will accept proxy-voting responsibilities, depending on the needs
of the Client relationship, pursuant to a written agreement. In these instances, the Advisor has adopted
proxy-voting guidelines to vote alongside with the management of the companies, seeking to ensure votes
are made in the best interest of the Advisor's Clients. Furthermore, it is understood that any material
conflicts between the Advisor’s interests and Clients with regard to proxy voting must be resolved before
proxies are voted. Clients of the Advisor may obtain upon request a copy of the Advisor’s Proxy Voting
Policies and Procedures and a record of how the Advisor voted a Client’s securities by contacting the
Advisor at (469) 373-3399.
Item 18 – Financial Information
Neither Requisite Capital, nor its management, have any adverse financial situations that would reasonably
impair the ability of Requisite Capital to meet all obligations to its Clients. Neither Requisite Capital, nor any
of its Advisory Persons, has been subject to a bankruptcy or financial compromise. Requisite Capital is not
required to deliver a balance sheet along with this Disclosure Brochure as the Advisor does not collect
advance fees of $1,200 or more for services to be performed six months or more in the future.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 18
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Form ADV Part 2B – Brochure Supplement
for
Douglas G. John, CFP®, CIMA®
Founder, Managing Partner
Effective: April 28, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Douglas G. John, CFP®, CIMA®, (CRD# 2813648) in addition to the information contained in the Requisite
Capital Management, LLC (“Requisite Capital” or the “Advisor”, CRD# 283107) Disclosure Brochure. If you
have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the
Requisite Capital Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (469) 373-
3399.
Additional information about Mr. John is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2813648.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 19
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Item 2 – Educational Background and Business Experience
Douglas G. John, CFP®, CIMA®, born in 1971, is dedicated to advising Clients of Requisite Capital as the
Founder, Managing Partner. Mr. John earned a M.B.A., in Finance from SMU Cox School of Business in 2002.
Additional information regarding Mr. John’s employment history is included below.
Employment History:
Founder, Managing Partner, Requisite Capital Management, LLC
06/2017 to Present
06/2017 to 12/2018
11/2002 to 06/2017
Registered Representative, FallLine Securities LLC
Financial Advisor and Registered Representative, UBS Financial
Services Inc.
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP® and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by Certified
Financial Planner Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries for
its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and
(3) ethical requirements that govern professional engagements with clients. Currently, more than
71,000 individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP® Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services, and attain a Bachelor’s Degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP®
Board’s financial planning subject areas include insurance planning and risk management, employee
benefits planning, investment planning, income tax planning, retirement planning, and estate
planning.
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes
case studies and client scenarios designed to test one’s ability to correctly diagnose financial
planning issues and apply one’s knowledge of financial planning to real world circumstances.
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP® Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
in order to maintain the right to continue to use the CFP ® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including
two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 20
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
standard of care. This means CFP® professionals must provide financial planning services in the best
interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP®
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP ®
certification.
Certified Investment Management AnalystSM (CIMA®)
The CIMA certification signifies that an individual has met initial and ongoing experience, ethical, education,
and examination requirements for investment management consulting, including advanced investment
management theory and application. To earn CIMA certification, candidates must: submit an application,
pass a background check and have an acceptable regulatory history; pass an online Qualification
Examination; complete an in-person or online executive education program at an AACSB accredited
university business school; pass an online Certification Examination; and have an acceptable regulatory
history as evidenced by FINRA Form U-4 or other regulatory requirements and have three years of financial
services experience at the time of certification.
CIMA certificants must adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and
Rules and Guidelines for Use of the Marks. CIMA designees must report 40 hours of continuing education
credits, including two ethics hours, every two years to maintain the certification. The designation is
administered through Investment Management Consultants Association (IMCA).
Item 3 – Disciplinary Information
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices.
The Advisor encourages you to independently view the background of Mr. John on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
2813648.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. John is a licensed insurance professional. Implementations of insurance recommendations are separate
and apart from Mr. John’s role with Requisite Capital. As an insurance professional, Mr. John will receive
customary commissions and other related revenues from the various insurance companies whose products
are sold. Mr. John is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest
in recommending certain products of the insurance companies. Clients are under no obligation to
implement any recommendations made by Mr. John or the Advisor.
Item 5 – Additional Compensation
Mr. John has additional business activities that are detailed in Item 4 above.
Item 6 – Supervision
Mr. John serves as the Founder, Managing Partner of Requisite Capital and is supervised by Bryn Talkington,
Managing Partner. Ms. Talkington can be reached at (469) 373-3399.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 21
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Requisite Capital has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Requisite Capital. Further, Requisite
Capital is subject to regulatory oversight by various agencies. These agencies require registration by
Requisite Capital and its Supervised Persons. As a registered entity, Requisite Capital is subject to
examinations by regulators, which may be announced or unannounced. Requisite Capital is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 22
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Form ADV Part 2B – Brochure Supplement
for
Bryn B. Talkington
Managing Partner
Effective:April 28, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Bryn B. Talkington (CRD# 2466264) in addition to the information contained in the Requisite Capital
Management, LLC (“Requisite Capital” or the “Advisor”, CRD# 283107) Disclosure Brochure. If you have not
received a copy of the Disclosure Brochure or if you have any questions about the contents of the Requisite
Capital Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (469) 373-3399.
Additional information about Ms. Talkington is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 2466264.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 23
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Item 2 – Educational Background and Business Experience
Bryn B. Talkington, born in 1971, is dedicated to advising Clients of Requisite Capital as a Managing Partner.
Ms. Talkington earned a B.A., in Management and Spanish from Texas Tech University in 1993. Additional
information regarding Ms. Talkington’s employment history is included below.
Employment History:
06/2017 to Present
06/2017 to 12/2018
12/2003 to 06/2017
Managing Partner, Requisite Capital Management, LLC
Registered Representative, FallLine Securities LLC
Investment Adviser Representative, Registered Representative, UBS Asset
Management, Inc.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Talkington. Ms. Talkington has
never been involved in any regulatory, civil or criminal action. There have been no client complaints,
lawsuits, arbitration claims or administrative proceedings against Ms. Talkington.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted,
there are no legal, civil or disciplinary events to disclose regarding Ms. Talkington.
However, the Advisor does encourage you to independently view the background of Ms. Talkington on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or
her Individual CRD# 2466264.
Item 4 – Other Business Activities
Ms. Talkington is dedicated to the investment advisory activities of Requisite Capital’s Clients. Ms. Talkington
does not have any other business activities.
Item 5 – Additional Compensation
Ms. Talkington is dedicated to the investment advisory activities of Requisite Capital’s Clients. Ms. Talkington
does not receive any additional forms of compensation.
Item 6 – Supervision
Ms. Talkington is supervised by Thomas Yates, Chief Compliance Officer. Mr. Yates can be reached at (617)
795-3037.
Requisite Capital has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Requisite Capital. Further, Requisite
Capital is subject to regulatory oversight by various agencies. These agencies require registration by
Requisite Capital and its Supervised Persons. As a registered entity, Requisite Capital is subject to
examinations by regulators, which may be announced or unannounced. Requisite Capital is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 24
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Form ADV Part 2B – Brochure Supplement
for
Ryan C. Dilworth, CFA®, CAIA
Managing Director
Effective:April 28, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Ryan C. Dilworth, CFA®, CAIA, (CRD# 5127997) in addition to the information contained in the Requisite
Capital Management, LLC (“Requisite Capital” or the “Advisor”, CRD# 283107) Disclosure Brochure. If you
have not received a copy of the Disclosure Brochure or if you have any questions about the contents of the
Requisite Capital Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (469) 373-
3399.
Additional information about Mr. Dilworth is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5127997.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 25
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Item 2 – Educational Background and Business Experience
Ryan C. Dilworth, CFA®, CAIA, born in 1984, is dedicated to advising Clients of Requisite Capital as an
Executive Director. Mr. Dilworth earned a B.B.A., in Finance from Texas State University in 2006. Additional
information regarding Mr. Dilworth’s employment history is included below.
Employment History:
Executive Director, Requisite Capital Management, LLC
Registered Representative, FallLine Securities LLC
Associate Director, UBS Financial Services Inc
06/2017 to Present
06/2017 to 12/2018
08/2011 to 06/2017
Chartered Financial Analyst (“CFA®”)
The Chartered Financial Analyst (“CFA”) charter is a professional designation established in 1962 and
awarded by CFA Institute. To earn the CFA charter, candidates must pass three sequential, six-hour
examinations over two to four years. The three levels of the CFA Program test a wide range of investment
topics, including ethical and professional standards, fixed-income analysis, alternative and derivative
investments, and portfolio management and wealth planning. In addition, CFA charterholders must have at
least four years of acceptable professional experience in the investment decision-making process and must
commit to abide by, and annually reaffirm, their adherence to the CFA Institute Code of Ethics and
Standards of Professional Conduct. CFA® is a trademark owned by CFA Institute.
Chartered Alternative Investment Analyst (CAIA)
The CAIA designation, recognized globally, is administered by the Chartered Alternative Investment Analyst
Association and requires a comprehensive understanding of core and advanced concepts regarding
alternative investments, structures, and ethical obligations. To qualify for the CAIA designation, finance
professionals must complete a self-directed, comprehensive course of study on risk-return attributes of
institutional quality alternative assets; pass both the Level I and Level II CAIA examinations at global,
proctored testing centers; attest annually to the terms of the Member Agreement; and hold a US bachelor's
degree (or equivalent) plus have at least one year of professional experience or have four years of
professional experience. Professional experience includes full-time employment in a professional capacity
within the regulatory, banking, financial, or related fields. Once a qualified candidate completes the CAIA
program, he or she may apply for CAIA membership and the right to use the CAIA designation, providing an
opportunity to access ongoing educational opportunities.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Dilworth. Mr. Dilworth has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mr. Dilworth.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted,
there are no legal, civil or disciplinary events to disclose regarding Mr. Dilworth.
However, the Advisor does encourage you to independently view the background of Mr. Dilworth on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or
his Individual CRD# 5127997.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 26
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Item 4 – Other Business Activities
Mr. Dilworth is dedicated to the investment advisory activities of Requisite Capital’s Clients. Mr. Dilworth
does not have any other business activities.
Item 5 – Additional Compensation
Mr. Dilworth is dedicated to the investment advisory activities of Requisite Capital’s Clients. Mr. Dilworth
does not receive any additional forms of compensation.
Item 6 – Supervision
Mr. Dilworth serves as an Executive Director of Requisite Capital and is supervised by Bryn Talkington,
Managing Partner. Ms. Talkington can be reached at (469) 373-3399.
Requisite Capital has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Requisite Capital. Further, Requisite
Capital is subject to regulatory oversight by various agencies. These agencies require registration by
Requisite Capital and its Supervised Persons. As a registered entity, Requisite Capital is subject to
examinations by regulators, which may be announced or unannounced. Requisite Capital is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 27
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Form ADV Part 2B – Brochure Supplement
for
Angelica Parra
Executive Director
Effective:April 28, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Angelica Parra (CRD# 3166392) in addition to the information contained in the Requisite Capital
Management, LLC (“Requisite Capital” or the “Advisor”, CRD# 283107) Disclosure Brochure. If you have not
received a copy of the Disclosure Brochure or if you have any questions about the contents of the Requisite
Capital Disclosure Brochure or this Brochure Supplement, please contact the Advisor at (469) 373-3399.
Additional information about Ms. Parra is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 3166392.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 28
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Item 2 – Educational Background and Business Experience
Angelica Parra, born in 1973, is dedicated to advising Clients of Requisite Capital as an Executive Director.
Ms. Parra earned a B.B.A., in Organizational Behavior and Business Policy, B.A., Spanish and in Latin American
Studies from Southern Methodist University in 1995. Additional information regarding Ms. Parra’s
employment history is included below.
Employment History:
Executive Director, Requisite Capital Management, LLC
Registered Representative, FallLine Securities LLC
CSA, UBS Financial Services Inc.
06/2017 to Present
06/2017 to 12/2018
07/2009 to 06/2017
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Ms. Parra. Ms. Parra has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Ms. Parra.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted,
there are no legal, civil or disciplinary events to disclose regarding Ms. Parra.
However, the Advisor does encourage you to independently view the background of Ms. Parra on the
Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or
her Individual CRD# 3166392.
Item 4 – Other Business Activities
Ms. Parra is dedicated to the investment advisory activities of Requisite Capital’s Clients. Ms. Parra does not
have any other business activities
Item 5 – Additional Compensation
Ms. Parra is dedicated to the investment advisory activities of Requisite Capital’s Clients. Ms. Parra does not
receive any additional forms of compensation.
Item 6 – Supervision
Ms. Parra serves as an Executive Director of Requisite Capital and is supervised by Bryn Talkington,
Managing Partner. Ms. Talkington can be reached at (469) 373-3399.
Requisite Capital has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Requisite Capital. Further, Requisite
Capital is subject to regulatory oversight by various agencies. These agencies require registration by
Requisite Capital and its Supervised Persons. As a registered entity, Requisite Capital is subject to
examinations by regulators, which may be announced or unannounced. Requisite Capital is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 29
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Form ADV Part 2B – Brochure Supplement
for
Rachel M. Niemuth
Executive Director
Effective:April 28, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Rachel M. Niemuth (CRD# 2763773) in addition to the information contained in the Requisite Capital
Management, LLC (“Requisite Capital” or the “Advisor,” CRD# 283107) Disclosure Brochure. If you have not
received a copy of the Disclosure Brochure or if you have any questions about the contents of the Requisite
Capital Disclosure Brochure or this Brochure Supplement, please contact us at (469) 373-3399.
Additional information about Mrs. Niemuth is available on the SEC’s Investment Adviser Public Disclosure
website at www.adviserinfo.sec.gov by searching with her full name or her Individual CRD# 2763773.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 30
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Item 2 – Educational Background and Business Experience
Rachel M. Niemuth, born in 1975, is dedicated to advising Clients of Requisite Capital as an Executive
Director. Mrs. Niemuth earned a Business Administration degree from the University of Texas at Arlington in
1998. Additional information regarding Mrs. Niemuth’s employment history is included below.
Employment History:
Executive Director, Requisite Capital Management, LLC
Client Service Advisor, Halcyon Wealth Advisors
Contract Employee, Randstad
Authorized Officer, UBS
10/2019 to Present
05/2019 to 10/2019
01/2019 to 04/2019
11/2002 to 08/2018
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mrs. Niemuth. Mrs. Niemuth has never
been involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits,
arbitration claims or administrative proceedings against Mrs. Niemuth.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted,
there are no legal, civil or disciplinary events to disclose regarding Mrs. Niemuth.
However, we do encourage you to independently view the background of Mrs. Niemuth on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with her full name or her
Individual CRD# 2763773.
Item 4 – Other Business Activities
Mrs. Niemuth is dedicated to the investment advisory activities of Requisite Capital’s Clients. Mrs. Niemuth
does not have any other business activities.
Item 5 – Additional Compensation
Mrs. Niemuth is dedicated to the investment advisory activities of Requisite Capital’s Clients. Mrs. Niemuth
does not receive any additional forms of compensation.
Item 6 – Supervision
Mrs. Niemuth serves as an Executive Director of Requisite Capital and is supervised by Bryn Talkington,
Managing Partner. Ms. Talkington can be reached at (469) 373-3399.
Requisite Capital has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Requisite Capital. Further, Requisite
Capital is subject to regulatory oversight by various agencies. These agencies require registration by
Requisite Capital and its Supervised Persons. As a registered entity, Requisite Capital is subject to
examinations by regulators, which may be announced or unannounced. Requisite Capital is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 31
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Form ADV Part 2B – Brochure Supplement
for
Samuel M. Ellis, CFP®
Director
Effective:April 28, 2025
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Samuel M. Ellis, CFP® (CRD# 6793632) in addition to the information contained in the Requisite Capital
Management, LLC (“Requisite Capital” or the “Advisor”, CRD# 283107) Disclosure Brochure. If you have not
received a copy of the Disclosure Brochure or if you have any questions about the contents of the Requisite
Capital Disclosure Brochure or this Brochure Supplement, please contact us at (469) 373-3399.
Additional information about Mr. Ellis is available on the SEC’s Investment Adviser Public Disclosure website
at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 6793632.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 32
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Item 2 – Educational Background and Business Experience
Samuel M. Ellis, CFP® born in 1995, is dedicated to advising Clients of Requisite Capital as an Associate
Director. Mr. Ellis earned a B.B.A. in Finance from Southern Methodist University in 2018. Additional
information regarding Mr. Ellis’s employment history is included below.
Employment History:
Associate Director, Requisite Capital Management, LLC
Sports & Experiential Marketing Intern, Publicis Hawkeye
Private Wealth Management Intern, UBS Financial Services
New Car Sales Associate, Mike Castrucci Chevrolet
06/2018 to Present
09/2017 to 12/2017
05/2017 to 08/2017
05/2016 to 08/2016
CERTIFIED FINANCIAL PLANNER™ (“CFP®”)
The CERTIFIED FINANCIAL PLANNER™, CFP®, and federally registered CFP® (with flame design) marks
(collectively, the “CFP® marks”) are professional certification marks granted in the United States by
CERTIFIED FINANCIAL PLANNER™ Board of Standards, Inc. (“CFP® Board”).
The CFP® certification is a voluntary certification; no federal or state law or regulation requires financial
planners to hold CFP® certification. It is recognized in the United States and a number of other countries for
its (1) high standard of professional education; (2) stringent code of conduct and standards of practice; and
(3) ethical requirements that govern professional engagements with clients. Currently, more than
87,000 individuals have obtained CFP® certification in the United States.
To attain the right to use the CFP® marks, an individual must satisfactorily fulfill the following requirements:
● Education – Complete an advanced college-level course of study addressing the financial planning
subject areas that CFP Board’s studies have determined as necessary for the competent and
professional delivery of financial planning services and attain a bachelor’s degree from a regionally
accredited United States college or university (or its equivalent from a foreign university). CFP
Board’s financial planning subject areas include insurance planning and risk management, employee
benefits planning, investment planning, income tax planning, retirement planning, and estate
planning.
● Examination – Pass the comprehensive CFP® Certification Examination. The examination includes
case studies and client scenarios designed to test one’s ability to correctly diagnose financial
planning issues and apply one’s knowledge of financial planning to real-world circumstances.
● Experience – Complete at least three years of full-time financial planning-related experience (or the
equivalent, measured as 2,000 hours per year); and
● Ethics – Agree to be bound by CFP Board’s Standards of Professional Conduct, a set of documents
outlining the ethical and practice standards for CFP® professionals.
Individuals who become certified must complete the following ongoing education and ethics requirements
in order to maintain the right to continue to use the CFP ® marks:
● Continuing Education – Complete 30 hours of continuing education hours every two years, including
two hours on the Code of Ethics and other parts of the Standards of Professional Conduct, to maintain
competence and keep up with developments in the financial planning field; and
● Ethics – Renew an agreement to be bound by the Standards of Professional Conduct. The Standards
prominently require that CFP® professionals provide financial planning services at a fiduciary
standard of care. This means CFP® professionals must provide financial planning services in the best
interests of their clients.
CFP® professionals who fail to comply with the above standards and requirements may be subject to CFP
Board’s enforcement process, which could result in suspension or permanent revocation of their CFP ®.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 33
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Ellis. Mr. Ellis has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Ellis.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have
been found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other
statutes; fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery,
forgery, counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted,
there are no legal, civil or disciplinary events to disclose regarding Mr. Ellis.
However, we do encourage you to independently view the background of Mr. Ellis on the Investment
Adviser Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his
Individual CRD# 6793632.
Item 4 – Other Business Activities
Mr. Ellis is dedicated to the investment advisory activities of Requisite Capital’s Clients. Mr. Ellis does not
have any other business activities.
Item 5 – Additional Compensation
Mr. Ellis is dedicated to the investment advisory activities of Requisite Capital’s Clients. Mr. Ellis does not
receive any additional forms of compensation.
Item 6 – Supervision
Mr. Ellis serves as an Associate Director of Requisite Capital and is supervised by Bryn Talkington, Managing
Partner. Ms. Talkington can be reached at (469) 373-3399.
Requisite Capital has implemented a Code of Ethics, an internal compliance document that guides each
Supervised Person in meeting their fiduciary obligations to Clients of Requisite Capital. Further, Requisite
Capital is subject to regulatory oversight by various agencies. These agencies require registration by
Requisite Capital and its Supervised Persons. As a registered entity, Requisite Capital is subject to
examinations by regulators, which may be announced or unannounced. Requisite Capital is required to
periodically update the information provided to these agencies and to provide various reports regarding the
business activities and assets of the Advisor.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 34
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
Privacy Policy
Effective:April 28, 2025
Our Commitment to You
Requisite Capital Management, LLC (“Requisite Capital” or the “Advisor”) is committed to safeguarding the
use of personal information of our Clients (also referred to as “you” and “your”) that we obtain as your
Investment Advisor, as described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. Requisite Capital (also referred
to as "we", "our" and "us”) protects the security and confidentiality of the personal information we have and
implements controls to ensure that such information is used for proper business purposes in connection
with the management or servicing of our relationship with you.
Requisite Capital does not sell your non-public personal information to anyone. Nor do we provide such
information to others except for discrete and reasonable business purposes in connection with the servicing
and management of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are
set forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of
servicing your account. Federal and State laws give you the right to limit some of this sharing and require
RIAs to disclose how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Assets and liabilities
Social security or taxpayer identification
number
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Investment experience and goals
Account information (including other
institutions)
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Account applications and forms
Other advisory agreements and legal
documents
Transactional information with us or others
Investment questionnaires and suitability
documents
Other information needed to service account
SMS Messaging
The Advisor’s SMS messaging provides the Client with timely and relevant communications directly from
the Advisor. Client’s can expect to receive periodic messages. Messages are related to day to day services,
which include but are not limited to, meeting confirmations, service commentary, market updates or
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 35
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
addressing your specific needs and/or requests. Message frequency will vary based on your needs and/or
action our action items. You can cancel SMS service at any time. Just reply STOP. Once you reply STOP to
us, we will send a message to confirm that you have been unsubscribed. After this, you will no longer
receive SMS messages from us. If you want to join again, just notify us via email or text and we will start
sending SMS messages to you again. If you are experiencing issues with the messaging program you can
reply with the word HELP for more assistance, or you can get help directly at info@requisitecm.com Carriers
are not liable for delayed or undelivered messages. As always, message and data rates may apply for any
messages exchanged with this number. If you have any questions about your text or data plan, contact your
phone provider.
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural
and electronic security measures. These include such safeguards as secure passwords, encrypted file
storage and a secure office environment. Our technology vendors provide security and access control over
personal information and have policies over the transmission of data. Our associates are trained on their
responsibilities to protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list
some reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you
limit?
Yes
No
Servicing our Clients
We may share non-public personal information with non-affiliated
third parties (such as administrators, brokers, custodians, regulators,
credit agencies, other financial institutions) as necessary for us to
provide agreed upon services to you, consistent with applicable law,
including but not limited to: processing transactions; general account
maintenance; responding to regulators or legal investigations; and
credit reporting.
No
Not Shared
Marketing Purposes
Requisite Capital does not disclose, and does not intend to disclose,
personal information with non-affiliated third parties to offer you
services. Certain laws may give us the right to share your personal
information with financial institutions where you are a customer and
where Requisite Capital or the client has a formal agreement with the
financial institution. We will only share information for purposes of
servicing your accounts, not for marketing purposes.
Yes
Yes
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 36
www.requisitecm.com
Disclosure Brochure Requisite Capital Management, LLC
No
Not Shared
Information About Former Clients
Requisite Capital does not disclose and does not intend to disclose,
non-public personal information to non-affiliated third parties with
respect to persons who are no longer our Clients.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised policy if the changes materially
alter the previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of
non-public personal information other than as described in this notice unless we first notify you and provide
you with an opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting us at (469) 373-3399.
Requisite Capital Management, LLC
4001 Maple Avenue, Suite 290, Dallas, TX 75219
Phone: (469) 373-3399 * Fax: (214) 295-8253
Page 37
www.requisitecm.com