REVOLUTION CAPITAL, LLC

Revolution Capital, LLC Firm Brochure - Form ADV Part 2A This brochure provides information about the qualifications and business practices of Revolution Capital, LLC. If you have any questions about the contents of this brochure, please contact us at (402) 933-3371 or by email at: ryan@revgroupllc.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Revolution Capital, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Revolution Capital, LLC’s CRD number is: 300496. 17838 Burke Street # 103 Omaha, NE 68118 (402) 933-3371 ryan@revgroupllc.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 04/06/2026 i  Item 2: Material Changes Any material changes in this brochure from the last updating amendment of Revolution Capital, LLC on 02/19/2025 are described below. Material changes relate to Revolution Capital, LLC’s policies, practices or conflicts of interests. • None ii  Item 3: Table of Contents Item 1: Cover Page ..................................................................................................................................................................................................... i Item 2: Material Changes ........................................................................................................................................................................................... ii Item 3: Table of Contents........................................................................................................................................................................................... iii Item 4: Advisory Business .......................................................................................................................................................................................... 2 Item 5: Fees and Compensation ................................................................................................................................................................................. 5 Item 6: Performance-Based Fees and Side-By-Side Management ......................................................................................................................... 9 Item 7: Types of Clients .............................................................................................................................................................................................. 9 Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss .................................................................................................................... 9 Item 9: Disciplinary Information ............................................................................................................................................................................. 13 Item 10: Other Financial Industry Activities and Affiliations .............................................................................................................................. 14 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ..................................................................... 16 Item 12: Brokerage Practices .................................................................................................................................................................................... 17 Item 13: Review of Accounts ................................................................................................................................................................................... 18 Item 14: Client Referrals and Other Compensation .............................................................................................................................................. 19 Item 15: Custody ....................................................................................................................................................................................................... 20 Item 16: Investment Discretion ................................................................................................................................................................................ 20 Item 17: Voting Client Securities (Proxy Voting)................................................................................................................................................... 21 Item 18: Financial Information ................................................................................................................................................................................. 21 iii  Item 4: Advisory Business A. Description of the Advisory Firm Revolution Capital, LLC (hereinafter “RevCap”) is a Limited Liability Company organized in the State of Nebraska. The firm was formed in January 2019, and the principal owner is Revolution Group, LLC. B. Types of Advisory Services Portfolio Management Services RevCap offers ongoing portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. RevCap creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels) and then constructs a plan to aid in the selection of a portfolio that matches each client's specific situation. Portfolio management services include, but are not limited to, the following: Investment strategy • • Asset allocation • Risk tolerance Personal investment policy Asset selection Regular portfolio monitoring • • • RevCap evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. RevCap will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. For certain alternative investments, discretionary trading is not possible. In these cases, the client will be consulted prior to the execution of the investment recommendation. RevCap seeks to provide investment decisions that are made in accordance with the fiduciary duties owed to its clients and without consideration of RevCap’s economic, investment or other financial interests. To meet its fiduciary obligations, RevCap attempts to avoid, among other things, investment or trading practices that systematically advantage or disadvantage certain client portfolios, and accordingly, RevCap’s policy is to seek fair and equitable allocation of investment opportunities/transactions among its clients to avoid favoring one client over another over time. It is RevCap’s policy to allocate investment opportunities and transactions it identifies as being appropriate and prudent, including initial public offerings ("IPOs") and other investment opportunities that might have a limited supply, among its clients on a fair and equitable basis over time. 2  Pension Consulting Services RevCap offers consulting services to pension or other employee benefit plans (including but not limited to 401(k) plans). Pension consulting may include, but is not limited to: • • • • • identifying investment objectives and restrictions providing guidance on various asset classes and investment options recommending money managers to manage plan assets in ways designed to achieve objectives. monitoring performance of money managers and investment options and making recommendations for changes recommending other service providers, such as custodians, administrators and broker-dealers creating a written pension consulting plan • These services are based on the goals, objectives, demographics, time horizon, and/or risk tolerance of the plan and its participants. Financial Planning Financial plans and financial planning may include but are not limited to: investment planning; life insurance; tax concerns; retirement planning; college planning; and debt/credit planning. Accounting & Tax Services In addition to its investment advisory services, Revolution Capital, LLC is affiliated with Revolution Tax LLC, a sister company under Revolution Group LLC, which provides accounting, tax preparation, and tax planning services. These services are performed by a Certified Public Accountant (CPA) who is an employee of Revolution Group LLC. The services include, but are not limited to, general bookkeeping, preparation of federal and state tax returns, and personalized tax planning strategies designed to optimize clients’ financial outcomes. Advisory clients are in no way required to utilize the accounting, tax preparation, and/or tax planning services available through Revolution Tax LLC and may choose to engage external providers of their preference. Attest Services In addition to the services above, Revolution Advanced Tax, LLC has been created to provide attest services. Attest services involve a CPA offering independent, objective examinations or reviews of financial information, systems, processes, or controls. These services provide assurance to third parties – such as investors, creditors, or regulators – regarding the reliability and accuracy of that information. This entity is owned 51% by the CPA that will run the day-to-day affairs of the entity and 49% by Ryan Fleischer. 3  Outsourced Chief Investment Officer (OCIO) RevCap provides Outsourced Chief Investment Officer (OCIO) services to foundations, endowments, and family offices seeking a fully delegated portfolio management and governance solution. Under this service, RevCap acts as a discretionary investment adviser, taking on fiduciary responsibility for managing client portfolios and overseeing investment governance in accordance with each client’s investment policy statement (IPS), risk tolerance, and long-term objectives. This offering is designed for clients who prefer to outsource day-to-day investment decision-making and governance responsibilities, allowing them to focus on their mission-driven goals or core priorities. In its OCIO role, RevCap constructs, manages, and monitors client portfolios, which may include a combination of traditional investments (e.g., equities, fixed income) and alternative strategies (e.g., private equity, real estate, hedge funds), consistent with the client’s established guidelines. Additionally, RevCap provides governance support, including developing or refining investment policies, ensuring compliance with fiduciary standards, and facilitating coordination with the client’s board or investment committee. Services encompass asset allocation, manager selection, portfolio rebalancing, performance reporting, and governance oversight, all executed under RevCap’s discretionary authority. These services may be provided on an interim or ongoing basis, tailored to the unique needs of each client. Written Acknowledgement of Fiduciary Status When we provide investment advice to you regarding your retirement plan account or individual retirement account, we are fiduciaries within the meaning of Title I of the Employee Retirement Income Security Act and/or the Internal Revenue Code, as applicable, which are laws governing retirement accounts. The way we make money creates some conflicts with your interests, so we operate under a special rule that requires us to act in your best interest and not put our interest ahead of yours. Under this special rule’s provisions, we must: • Meet a professional standard of care when making investment recommendations (give prudent advice); • Never put our financial interests ahead of yours when making recommendations (give loyal advice); • Avoid misleading statements about conflicts of interest, fees, and investments; • Follow policies and procedures designed to ensure that we give advice that is in your best interest; • Charge no more than is reasonable for our services; and • Give you basic information about conflicts of interest. Services Limited to Specific Types of Investments RevCap generally limits its investment advice to mutual funds, fixed income securities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, 4  venture capital funds and private placements. RevCap may use other securities as well to help diversify a portfolio when applicable. C. Client Tailored Services and Client Imposed Restrictions RevCap will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by RevCap on behalf of the client. RevCap may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients may impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. However, if the restrictions prevent RevCap from properly servicing the client account, or if the restrictions would require RevCap to deviate from its standard suite of services, RevCap reserves the right to end the relationship. D. Wrap Fee Programs RevCap acts as portfolio manager and sponsor for a wrap fee program, which is an investment program where the client pays one stated fee that includes management fees, transaction costs, and certain other administrative fees. However, this brochure describes RevCap’s non-wrap fee advisory services; clients utilizing RevCap’s wrap fee portfolio management should see RevCap’s separate Wrap Fee Program Brochure. RevCap manages the investments in the wrap fee program. RevCap receives the advisory fee set forth in Item 5 below as a management fee under the wrap fee program. Please also see Item 5 and Item 12 of this brochure. E. Assets Under Management RevCap has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $241,915,426 $0 December 2025 Item 5: Fees and Compensation A. Fee Schedule Portfolio Management Fees RevCap uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Some alternative 5  investments are not billed using the average of the daily balance in the client’s account, for those investments RevCap. For investments where average daily balance billing is not allowed or applicable to the investment, RevCap will use the amount of the original investment and make adjustments according to the value using fund statements and/or audited financials provided by the fund operator and/or sponsor. Investment advisory fees are based on the market value of managed assets with a potential minimum annual fee not to exceed 2% annually. Billing Formula: Billed Value X Annual Fee Rate % X Days in Period / Days in Year Days in cycle refers to how many days the account is billed during the billing period. Actual Number of Days – The fee calculation for partial quarters is based on the exact number of days that occurred during that quarter divided by 365 or 366 (leap years) Prorate by Days in Cycle – The fee calculation for the management fee notification is based on the same number of days no matter which quarter is billed. The days in cycle for every quarter is 90/360. This calculation is used to determine the total annual fee amount divided by the four quarters. Fees may be negotiable at the sole discretion of the Advisor. Client fees will take into consideration several factors, including aggregate assets under management, the complexity of the services to be provided, and the overall relationship with the Advisor. The final fee schedule is attached as Exhibit II of the Investment Advisory Contract. Client will be charged a $25 per account, per quarter technology fee to recoup client facing technology and administrative costs. Can be reduced or waived at RevCap's sole discretion. These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of RevCap's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. Pension Consulting Services Fees Asset-Based Fees for Pension Consulting Total Assets Under Management Annual Fee All Assets Up to 2.50% RevCap uses an average of the daily balance in the client's account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. 6  These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Clients may terminate the agreement without penalty for a full refund of RevCap's fees within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the pension consulting agreement immediately upon written notice. RevCap uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Fixed Fees The rate for creating client pension consulting plans is between $1,000 and $10,000. The final fee schedule will be memorialized in the client’s advisory agreement. This service may be canceled immediately upon written notice. Hourly Fees The hourly fee for these services is between $150 and $350. The final fee schedule will be memorialized in the client’s advisory agreement. Financial Planning Fees Fixed Fees The negotiated fixed rate for creating client financial plans is between $300 and $10,000. Hourly Fees The negotiated hourly fee for these services is between $150 and $350. Clients may terminate the agreement without penalty, for full refund of RevCap’s fees, within five business days of signing the Financial Planning Agreement. Thereafter, clients may terminate the Financial Planning Agreement generally upon written notice. Accounting & Tax Service Fees Fees for accounting, tax preparation, and tax planning services are separate from investment advisory fees and are project-based, depending on the scope of work. Clients will receive a fee quote prior to engagement. Payment for these services is due upon completion and is remitted to Revolution Tax LLC. Advisory clients are not obligated to use these services. Fees may vary between advisory clients and non-clients depending on the scope of services and existing advisory relationships. B. Payment of Fees 7  Payment of Portfolio Management Fees Asset-based portfolio management fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in arrears. Payment of Pension Consulting Fees Asset-based pension consulting fees are withdrawn directly from the client's accounts with client's written authorization on a quarterly basis or may be invoiced and billed directly to the client on a quarterly basis. Clients may select the method in which they are billed. Fees are paid in arrears. Fixed pension consulting fees are paid via check. These fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Hourly pension consulting fees are paid 25% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Payment of Financial Planning Fees Financial planning fees are paid via check and wire. Fixed financial planning fees are paid 50% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Hourly financial planning fees are paid 25% in advance, but never more than six months in advance, with the remainder due upon presentation of the plan. Payment for Accounting & Tax Service Fees Accounting, tax preparation, and tax planning services are all handled by Revolution Tax LLC, a sister firm to Revolution Capital, LLC and a subsidiary of Revolution Group LLC. These services are performed by a CPA who is an employee of Revolution Group LLC. Fees for these services can be paid by check and made payable to Revolution Tax LLC. Payment for Attest Services Attest services are handled by Revolution Advanced Tax, LLC, an entity 51% owned by the CPA that serves those seeking this service, and 49% by Ryan Fleischer. Payment for these services can be paid by check made payable to Revolution Advanced Tax, LLC. 8  C. Client Responsibility for Third Party Fees Clients are responsible for the payment of all third party fees (i.e. custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.). Those fees are separate and distinct from the fees and expenses charged by RevCap. Please see Item 12 of this brochure regarding broker- dealer/custodian. D. Prepayment of Fees RevCap collects certain fees in advance and certain fees in arrears, as indicated above. Refunds for fees paid in advance but not yet earned will be refunded on a prorated basis and returned within fourteen days to the client via check or return deposit back into the client’s account. Fixed fees that are collected in advance will be refunded based on the prorated amount of work completed at the point of termination. For hourly fees that are collected in advance, the fee refunded will be the balance of the fees collected in advance minus the hourly rate times the number of hours of work that has been completed up to and including the day of termination. E. Outside Compensation for the Sale of Securities to Clients Neither RevCap nor its supervised persons accept any compensation for the sale of investment products, including asset-based sales charges or service fees from the sale of mutual funds. Item 6: Performance-Based Fees and Side-By-Side Management RevCap does not accept performance-based fees or other fees based on a share of capital gains or capital appreciation of the assets of a client. Item 7: Types of Clients RevCap generally provides advisory services to the following types of clients: Individuals High-Net-Worth Individuals Family Offices Pension funds Corporations or Business Entities ❖ ❖ ❖ ❖ ❖ RevCap has a minimum account size of $1,000,000 but we reserve the right to accept and maintain clients with less than that amount to manage. 9  Item 8: Methods of Analysis, Investment Strategies, & Risk of Loss A. Methods of Analysis and Investment Strategies Methods of Analysis RevCap’s methods of analysis include Charting analysis, Cyclical analysis, Fundamental analysis, Modern portfolio theory, Quantitative analysis and Technical analysis. Charting analysis involves the use of patterns in performance charts. RevCap uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various asset. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Technical analysis involves the analysis of past market data; primarily price and volume. Investment Strategies RevCap uses long term trading, margin transactions and options trading (including covered options, uncovered options, or spreading strategies). Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. B. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is 10  that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Quantitative analysis Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Investment Strategies RevCap's use of margin transactions and options trading generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term trading is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. 11  Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets in a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. C. Risks of Specific Securities Utilized RevCap's use of margin transactions and options trading generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% 12  loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Hedge funds often engage in leveraging and other speculative investment practices that may increase the risk of loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and the liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. 13  Item 9: Disciplinary Information A. Criminal or Civil Actions There are no criminal or civil actions to report. B. Administrative Proceedings There are no administrative proceedings to report. C. Self-regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Item 10: Other Financial Industry Activities and Affiliations A. Registration as a Broker/Dealer or Broker/Dealer Representative Neither RevCap nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. B. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither RevCap nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. C. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Ryan Fleischer and Chad McKown are licensed insurance agents and operate under Revolution Group, LLC. Revolution Group, LLC is a licensed insurance agency and from time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. RevCap always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of RevCap in connection with such individual's activities outside of RevCap. 14  RevGroup, along with its affiliates, offers Outsourced Chief Investment Officer (OCIO) services to foundations, endowments, and family offices that require investment sourcing, due diligence, and governance support without delegating full portfolio management. In this non-discretionary capacity, RevGroup conducts due diligence and sources investment opportunities, asset allocation options, and third-party managers that conform to the client’s existing investment mandate, policy, risk profile, and objectives. These services are intended for clients who retain full decision-making authority over their portfolios and engage RevGroup to locate and evaluate investments within their established framework. RevGroup and its affiliates do not exercise discretionary authority or take custody of client assets under this service. Instead, we work with the client’s investment committee, board, or designated fiduciaries to source and perform due diligence on investment opportunities (such as private equity deals, real assets, or other alternative investments) that fit the institution’s or family’s given investment policy, and to provide governance support. Governance services may include reviewing or drafting investment policy statements, assisting with fiduciary best practices, and supporting committee reporting or oversight processes. This OCIO sourcing, due diligence, and governance support may be provided on a project-specific, interim, or ongoing basis, depending on the client’s needs. Revolution Capital, LLC (RevCap) is a subsidiary of Revolution Group, LLC and a sister company to Revolution Tax LLC, which provides accounting, tax preparation, and tax planning services. These services are performed by a CPA who is an employee of Revolution Group, LLC. Fees for these services are paid to Revolution Tax, LLC. This affiliated structure may present a conflict of interest, as Revolution Capital, LLC and Revolution Tax, LLC, through their common ownership under Revolution Group LLC, could benefit financially from referrals of advisory clients to Revolution Tax LLC. To address this, the IA discloses that clients are under no obligation to use these services and are free to select any qualified provider. Referrals to Revolution Tax, LLC are made only when deemed appropriate for the client’s needs, and the IA maintains policies to ensure that such recommendations prioritize the client’s best interests over the financial interests of Revolution Group, LLC or its subsidiaries. Revolution Advanced Tax, LLC is an affiliated firm offering attest services. The firm is owned 51% by the CPA that performs these services and 49% by Ryan Fleischer. Attest services consist of CPAs offering independent, objective examinations or reviews of financial information, systems, processes, or controls. These services provide assurance to third parties – such as investors, creditors, or regulators – regarding the reliability and accuracy of that information. This firm creates a conflict of interest since Ryan Fleischer (Revolution Capital, LLC’s Chief Compliance Officer) owns 49% of this firm and business sent to this entity would provide indirect compensation. To address this, the IA discloses that clients are under no obligation to use the attest services offered by this firm and are free to select any other qualified provider. Should a referral be made to Revolution Advanced Tax, LLC, it would only be in a case deemed appropriate for the client’s needs, and RevCap maintains policies to ensure that such recommendations prioritize the clients’ best interests over the financial interests of Revolution Group, LLC or its subsidiaries. Ryan Mathew Fleischer is a Founder/President at Revolution Group, LLC. 15  D. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections RevCap does not utilize nor select third-party investment advisers. Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading A. Code of Ethics RevCap has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. RevCap's Code of Ethics is available free upon request to any client or prospective client. B. Recommendations Involving Material Financial Interests RevCap does not recommend that clients buy or sell any security in which a related person to RevCap or RevCap has a material financial interest. C. Investing Personal Money in the Same Securities as Clients From time to time, representatives of RevCap may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of RevCap to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. RevCap will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. D. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of RevCap may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of RevCap to buy or sell securities before or after recommending securities to clients resulting 16  in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, RevCap will never engage in trading that operates to the client’s disadvantage if representatives of RevCap buy or sell securities at or around the same time as clients. Item 12: Brokerage Practices A. Factors Used to Select Custodians and/or Broker/Dealers the market expertise and research access provided by Custodians/broker-dealers will be recommended based on RevCap’s duty to seek “best execution,” which is the obligation to seek execution of securities transactions for a client on the most favorable terms for the client under the circumstances. Clients will not necessarily pay the lowest commission or commission equivalent, and RevCap may also consider the broker- dealer/custodian, including but not limited to access to written research, oral communication with analysts, admittance to research conferences and other resources provided by the brokers that may aid in RevCap's research efforts. RevCap will never charge a premium or commission on transactions, beyond the actual cost imposed by the broker-dealer/custodian. RevCap will require clients to use Charles Schwab & Co., Inc. Advisor Services. NuView Trust is the custodian for clients’ self-directed IRA accounts. RevCap recommends CNB Custody and AET. 1. Research and Other Soft-Dollar Benefits While RevCap has no formal soft dollars program in which soft dollars are used to pay for third party services, RevCap may receive research, products, or other services from custodians and broker-dealers in connection with client securities transactions (“soft dollar benefits”). RevCap may enter into soft-dollar arrangements consistent with (and not outside of) the safe harbor contained in Section 28(e) of the Securities Exchange Act of 1934, as amended. There can be no assurance that any particular client will benefit from soft dollar research, whether or not the client’s transactions paid for it, and RevCap does not seek to allocate benefits to client accounts proportionate to any soft dollar credits generated by the accounts. RevCap benefits by not having to produce or pay for the research, products or services, and RevCap will have an incentive to recommend a broker-dealer based on receiving research or services. Clients should be aware that RevCap’s acceptance of soft dollar benefits may result in higher commissions charged to the client. 2. Brokerage for Client Referrals RevCap receives no referrals from a broker-dealer or third party in exchange for using that broker-dealer or third party. 17  3. Clients Directing Which Broker/Dealer/Custodian to Use RevCap will require clients to use a specific broker-dealer to execute transactions. Not all advisers require clients to use a particular broker-dealer. B. Aggregating (Block) Trading for Multiple Client Accounts If RevCap buys or sells the same securities on behalf of more than one client, then it may (but would be under no obligation to) aggregate or bunch such securities in a single transaction for multiple clients in order to seek more favorable prices, lower brokerage commissions, or more efficient execution. In such case, RevCap would place an aggregate order with the broker on behalf of all such clients in order to ensure fairness for all clients; provided, however, that trades would be reviewed periodically to ensure that accounts are not systematically disadvantaged by this policy. RevCap would determine the appropriate number of shares and select the appropriate brokers consistent with its duty to seek best execution, except for those accounts with specific brokerage direction (if any). Item 13: Review of Accounts A. Frequency and Nature of Periodic Reviews and Who Makes Those Reviews All client accounts for RevCap's advisory services provided on an ongoing basis are reviewed at least Annually by Ryan M Fleischer, CEO, with regard to clients’ respective investment policies and risk tolerance levels. All accounts at RevCap are assigned to this reviewer. All financial planning accounts are reviewed upon financial plan creation and plan delivery by Ryan M Fleischer, CEO. Financial planning clients are provided a one-time financial plan concerning their financial situation. After the presentation of the plan, there are no further reports. Clients may request additional plans or reports for a fee. B. Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). With respect to financial plans, RevCap’s services will generally conclude upon delivery of the financial plan. 18  C. Content and Frequency of Regular Reports Provided to Clients Each client of RevCap's advisory services provided on an ongoing basis will receive a quarterly report detailing the client’s account, including assets held, asset value, and calculation of fees. This written report will come from the custodian. RevCap will also provide a quarterly performance report to the client. Each financial planning client will receive the financial plan upon completion. Item 14: Client Referrals and Other Compensation A. Economic Benefits Provided by Third Parties for Advice Rendered to Clients (Includes Sales Awards or Other Prizes) From time to time, we or our affiliates may receive compensation from product sponsors and service providers in the form of sponsorship fees for educational seminars or events. Our receipt of these sponsorship fees is for the purpose of defraying costs associated with coordinating and hosting the sponsored event. These sponsorship fees do not entitle the sponsor to any preferential treatment. Accordingly, a conflict of interest may exist where we receive compensation from sponsors and service providers willing to contribute sponsorship fees more frequently or in greater amounts than other product sponsors and service providers. However, consideration of product sponsors and service providers for sponsorship fee compensation by us is based on the quality of the product sponsor or service provider and is not solely based on the anticipated sponsorship fees our Firm will receive. Clients or potential investors that attend an educational seminar or event where a product sponsor or service provider is in attendance should assume that the product sponsor or service provider has paid or reimbursed us or our affiliates for part or all of the total cost of the educational seminar or event, including travel costs. Charles Schwab & Co., Inc. Advisor Services provides RevCap with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For RevCap client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles 19  Schwab & Co., Inc. Advisor Services accounts. information technology, business succession, Charles Schwab & Co., Inc. Advisor Services also makes available to RevCap other products and services that benefit RevCap but may not benefit its clients’ accounts. These benefits may include national, regional or RevCap specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of RevCap by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist REVCAP in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of RevCap’s fees from its clients’ accounts (if applicable), and assist with back- office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of RevCap’s accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to RevCap other services intended to help RevCap manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to RevCap by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to RevCap. RevCap is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. B. Compensation to Non – Advisory Personnel for Client Referrals RevCap does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Item 15: Custody When advisory fees are deducted directly from client accounts at client's custodian, RevCap will be deemed to have limited custody of client's assets and must have written authorization from the client to do so. Clients will receive all account statements and billing invoices that are required in each jurisdiction, and they should carefully review those statements for accuracy. Custody is also disclosed in Form ADV because RevCap has authority to transfer money from client account(s), which constitutes a standing letter of authorization (SLOA). Accordingly, RevCap will follow the safeguards specified by the SEC rather than undergo an annual audit. 20  Item 16: Investment Discretion RevCap provides discretionary and non-discretionary investment advisory services to clients. The advisory contract established with each client sets forth the discretionary authority for trading. Where investment discretion has been granted, RevCap generally manages the client’s account and makes investment decisions without consultation with the client as to when the securities are to be bought or sold for the account, the total amount of the securities to be bought/sold, what securities to buy or sell, or the price per share. In some instances, RevCap’s discretionary authority in making these determinations may be limited by conditions imposed by a client (in investment guidelines or objectives, or client instructions otherwise provided to RevCap. For certain alternative investments, discretionary trading is not possible. In these cases, the client will be consulted prior to the execution of the investment recommendation. Item 17: Voting Client Securities (Proxy Voting) RevCap will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 18: Financial Information A. Balance Sheet RevCap neither requires nor solicits prepayment of more than $ 1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. B. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients Neither RevCap nor its management has any financial condition that is likely to reasonably impair RevCap’s ability to meet contractual commitments to clients. C. Bankruptcy Petitions in Previous Ten Years RevCap has not been the subject of a bankruptcy petition in the last ten years. 21 

Revolution Capital, LLC Wrap Fee Program Brochure This wrap fee program brochure provides information about the qualifications and business practices of Revolution Capital, LLC. If you have any questions about the contents of this brochure, please contact us at (402) 933-3371 or by email at: ryan@revgroupllc.com. The information in this brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. Additional information about Revolution Capital, LLC is also available on the SEC’s website at www.adviserinfo.sec.gov. Revolution Capital, LLC’s CRD number is: 300496. 17838 Burke Street # 103 Omaha, NE 68118 (402) 933-3371 ryan@revgroupllc.com Registration as an investment adviser does not imply a certain level of skill or training. Version Date: 04/06/2026  Item 2: Material Changes Any material changes in this brochure from the last annual updating amendment to this Wrap Fee Program Brochure on February 19, 2026 are shown below. Material changes relate to Revolution Capital, LLC's policies, practices or conflicts of interests only. • None 1  Item 3: Table of Contents Item 1: Cover Page ............................................................................................................................. …i Item 2: Material Changes...................................................................................................................... 1 Item 3: Table of Contents ...................................................................................................................... 2 Item 4: Advisory Business .................................................................................................................... 3 Item 5: Types of Clients ........................................................................................................................ 4 Item 6: Portfolio Manager Selection and Evaluation .......................................................................... 4 Item 7: Client Information Provided to Portfolio Managers ............................................................ 11 Item 8: Client Contact with Portfolio Managers ............................................................................... 11 Item 9: Additional Information .......................................................................................................... 11 Item 10: Requirements For State Registered Advisers ..................................................................... 17 2  Item 4: Advisory Business A. Description of the Advisory Firm Revolution Capital, LLC (hereinafter “RevCap”) provides portfolio management to clients under this wrap fee program as sponsor and portfolio manager. Total Assets Under Management Annual Fee All Assets Up to 2.65% These fees are generally negotiable, and the final fee schedule will be memorialized in the client’s advisory agreement. Portfolio management fees are withdrawn directly from the client’s accounts with client’s written authorization on a quarterly basis or may be invoiced and billed directly to the client on a quarterly, clients may select the method in which they are billed. Fees are paid in arrears. RevCap uses an average of the daily balance in the client’s account throughout the billing period, after taking into account deposits and withdrawals, for purposes of determining the market value of the assets upon which the advisory fee is based. Clients may terminate the agreement without penalty, for full refund of RevCap’s fees, within five business days of signing the Investment Advisory Contract. Thereafter, clients may terminate the Investment Advisory Contract immediately upon written notice. B. Contribution Cost Factors The program may cost the client more or less than purchasing such services separately. There are several factors that bear upon the relative cost of the program, including the trading activity in the client’s account, the adviser’s ability to aggregate trades, and the cost of the services if provided separately (which in turn depends on the prices and specific services offered by different providers). C. Additional Fees RevCap will wrap third party fees (i.e., custodian fees, brokerage fees, mutual fund fees, transaction fees, etc.) for wrap fee portfolio management accounts. RevCap will charge clients one fee and pay all transaction fees using the fee collected from the client. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that RevCap has an incentive to limit trading activities for those accounts since the firm absorbs those transaction costs. 3  Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, fees associated with “step out” transactions if the account uses different custodians or broker-dealers, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. D. Compensation of Client Participation Neither RevCap, nor any representatives of RevCap receive any additional compensation beyond advisory fees for the participation of clients in the wrap fee program. However, compensation received may be more than what would have been received if client paid separately for investment advice, brokerage, and other services. Therefore, RevCap may have a financial incentive to recommend the wrap fee program to clients. Item 5: Types of Clients RevCap generally offers advisory services to the following types of clients: ❖ Individuals ❖ High-Net-Worth Individuals ❖ Family Offices ❖ Pension Funds ❖ Corporations or Business Entities RevCap’s minimum account size is $1,000,000 but this can be waived at the firm’s discretion. Item 6: Portfolio Manager Selection and Evaluation A. Selecting/Reviewing Portfolio Managers RevCap will not select outside portfolio managers for management of this wrap fee program. RevCap will be the sole portfolio manager for this wrap fee program. RevCap will use industry standards to calculate portfolio manager performance. RevCap reviews the performance information to determine and verify its accuracy and compliance with presentation standards. The performance information is calculated annually and is reviewed by RevCap. 4  B. Related Persons RevCap and its personnel serve as the portfolio managers for all wrap fee program accounts. This is a conflict of interest in that no outside adviser assesses RevCap’s management of the wrap fee program. However, RevCap addresses this conflict by acting in its clients’ best interest consistent with its fiduciary duty as sponsor and portfolio manager of the wrap fee program. C. Advisory Business RevCap offers ongoing wrap fee portfolio management services based on the individual goals, objectives, time horizon, and risk tolerance of each client. RevCap creates an Investment Policy Statement for each client, which outlines the client’s current situation (income, tax levels, and risk tolerance levels). Portfolio management services include, but are not limited to, the following: Determine investment strategy Asset allocation Assessment of risk tolerance • • • Personal investment policy Asset selection Regular portfolio monitoring • • • RevCap evaluates the current investments of each client with respect to their risk tolerance levels and time horizon. RevCap will request discretionary authority from clients in order to select securities and execute transactions without permission from the client prior to each transaction. For certain alternative investments, discretionary trading is not possible. In these cases, the client will be consulted prior to the execution of the investment recommendation. Risk tolerance levels are documented in the Investment Policy Statement, which is given to each client. Portfolio management accounts participating in the wrap fee program will not have to pay for transaction or trading fees. RevCap will charge clients one fee, and pay transaction fees using the advisory fee collected from the client. Certain other fees are not included in the wrap fee and are paid for separately by the client. These include, but are not limited to, margin costs, charges imposed directly by a mutual fund or exchange traded fund, deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Accounts participating in the wrap fee program are not charged higher advisory fees based on trading activity, but clients should be aware that RevCap has an incentive to limit trading activities for those accounts since the firm absorbs those transaction costs. To address this conflict, RevCap will always act in the best interest of its clients consistent with its fiduciary duty as an investment adviser. 5  Services Limited to Specific Types of Investments RevCap generally limits its investment advice to mutual funds, fixed income securities, equities, hedge funds, private equity funds, ETFs (including ETFs in the gold and precious metal sectors), treasury inflation protected/inflation linked bonds, non-U.S. securities, venture capital funds and private placements. RevCap may use other securities as well to help diversify a portfolio when applicable. Client Tailored Services and Client Imposed Restrictions RevCap will tailor a program for each individual client. This will include an interview session to get to know the client’s specific needs and requirements as well as a plan that will be executed by RevCap on behalf of the client. RevCap may use model allocations together with a specific set of recommendations for each client based on their personal restrictions, needs, and targets. Clients are not permitted to impose restrictions in investing in certain securities or types of securities in accordance with their values or beliefs. Wrap Fee Programs As discussed herein, RevCap sponsors and acts as portfolio manager for this wrap fee program. RevCap manages the investments in the wrap fee program and will manage wrap fee accounts differently than non-wrap fee accounts. Securities purchased can be the same but may be different based on the client's individual situation. The fees paid to the wrap account program will be given to RevCap as a management fee. Amounts Under Management RevCap has the following assets under management: Discretionary Amounts: Non-discretionary Amounts: Date Calculated: $241,915,426 $0 December 2025 Performance-Based Fees and Side-By-Side Management RevCap does not accept performance-based fees or other fees based on a share of capital gains on or capital appreciation of the assets of a client. Clients paying a performance-based fee should be aware that investment advisers have an incentive to invest in riskier investments when paid a performance-based fee due to the higher risk/higher reward attributes. 6  Methods of Analysis and Investment Strategies Methods of Analysis RevCap’s methods of analysis include charting analysis, fundamental analysis, technical analysis, cyclical analysis, quantitative analysis, and the use of modern portfolio theory. Charting analysis involves the use of patterns in performance charts. RevCap uses this technique to search for patterns used to help predict favorable conditions for buying and/or selling a security. Fundamental analysis involves the analysis of financial statements, the general financial health of companies, and/or the analysis of management or competitive advantages. Technical analysis involves the analysis of past market data; primarily price and volume. Cyclical analysis involves the analysis of business cycles to find favorable conditions for buying and/or selling a security. Quantitative analysis deals with measurable factors as distinguished from qualitative considerations such as the character of management or the state of employee morale, such as the value of assets, the cost of capital, historical projections of sales, and so on. Modern portfolio theory is a theory of investment that attempts to maximize portfolio expected return for a given amount of portfolio risk, or equivalently minimize risk for a given level of expected return, each by carefully choosing the proportions of various assets. Investment Strategies RevCap uses/recommends long term investing, margin transactions, and options transactions. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Material Risks Involved Methods of Analysis Charting analysis strategy involves using and comparing various charts to predict long and short term performance or market trends. The risk involved in using this method is that only past performance data is considered without using other methods to crosscheck data. Using charting analysis without other methods of analysis would be making the assumption that past performance will be indicative of future performance. This may not be the case. 7  Fundamental analysis concentrates on factors that determine a company’s value and expected future earnings. This strategy would normally encourage equity purchases in stocks that are undervalued or priced below their perceived value. The risk assumed is that the market will fail to reach expectations of perceived value. Technical analysis attempts to predict a future stock price or direction based on market trends. The assumption is that the market follows discernible patterns and if these patterns can be identified then a prediction can be made. The risk is that markets do not always follow patterns and relying solely on this method may not take into account new patterns that emerge over time. Cyclical analysis assumes that the markets react in cyclical patterns which, once identified, can be leveraged to provide performance. The risks with this strategy are two- fold: 1) the markets do not always repeat cyclical patterns; and 2) if too many investors begin to implement this strategy, then it changes the very cycles these investors are trying to exploit. Quantitative Model Risk: Investment strategies using quantitative models may perform differently than expected as a result of, among other things, the factors used in the models, the weight placed on each factor, changes from the factors’ historical trends, and technical issues in the construction and implementation of the models. Modern portfolio theory assumes that investors are risk averse, meaning that given two portfolios that offer the same expected return, investors will prefer the less risky one. Thus, an investor will take on increased risk only if compensated by higher expected returns. Conversely, an investor who wants higher expected returns must accept more risk. The exact trade-off will be the same for all investors, but different investors will evaluate the trade-off differently based on individual risk aversion characteristics. The implication is that a rational investor will not invest in a portfolio if a second portfolio exists with a more favorable risk-expected return profile – i.e., if for that level of risk an alternative portfolio exists which has better expected returns. Investment Strategies RevCap’s use of margin transactions and margin transactions generally holds greater risk, and clients should be aware that there is a material risk of loss using any of those strategies. Long term investing is designed to capture market rates of both return and risk. Due to its nature, the long-term investment strategy can expose clients to various types of risk that will typically surface at various intervals during the time the client owns the investments. These risks include but are not limited to inflation (purchasing power) risk, interest rate risk, economic risk, market risk, and political/regulatory risk. 8  Margin transactions use leverage that is borrowed from a brokerage firm as collateral. When losses occur, the value of the margin account may fall below the brokerage firm’s threshold thereby triggering a margin call. This may force the account holder to either allocate more funds to the account or sell assets on a shorter time frame than desired. Options transactions involve a contract to purchase a security at a given price, not necessarily at market value, depending on the market. This strategy includes the risk that an option may expire out of the money resulting in minimal or no value, as well as the possibility of leveraged loss of trading capital due to the leveraged nature of stock options. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Risks of Specific Securities Utilized RevCap’s use of margin transactions and margin transactions generally holds greater risk of capital loss. Clients should be aware that there is a material risk of loss using any investment strategy. The investment types listed below (leaving aside Treasury Inflation Protected/Inflation Linked Bonds) are not guaranteed or insured by the FDIC or any other government agency. Equity investment generally refers to buying shares of stocks in return for receiving a future payment of dividends and/or capital gains if the value of the stock increases. The value of equity securities may fluctuate in response to specific situations for each company, industry conditions and the general economic environments. Fixed income investments generally pay a return on a fixed schedule, though the amount of the payments can vary. This type of investment can include corporate and government debt securities, leveraged loans, high yield, and investment grade debt and structured products, such as mortgage and other asset-backed securities, although individual bonds may be the best known type of fixed income security. In general, the fixed income market is volatile and fixed income securities carry interest rate risk. (As interest rates rise, bond prices usually fall, and vice versa. This effect is usually more pronounced for longer-term securities.) Fixed income securities also carry inflation risk, liquidity risk, call risk, and credit and default risks for both issuers and counterparties. The risk of default on treasury inflation protected/inflation linked bonds is dependent upon the U.S. Treasury defaulting (extremely unlikely); however, they carry a potential risk of losing share price value, albeit rather minimal. Risks of investing in foreign fixed income securities also include the general risk of non-U.S. investing described below. Exchange Traded Funds (ETFs): An ETF is an investment fund traded on stock exchanges, similar to stocks. Investing in ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Areas of concern include the lack of transparency in products and increasing complexity, conflicts of interest and the possibility of inadequate regulatory compliance. Because ETFs use "authorized participants" (APs) as agents to facilitate creations or redemptions (primary market), there is a risk that an AP decides to no longer participate for a particular ETF; however, that risk is mitigated by the fact that other APs can step in to fill the vacancy of the 9  withdrawing AP [an ETF typically has multiple APs] and ETF transactions predominantly take place in the secondary market without need for an AP. Like other liquid securities, ETF pricing changes throughout the trading day and there can be no guarantee that an ETF is purchased at the optimal time in terms of market movements. Moreover, due to market fluctuations, ETF brokerage costs, differing demand and characteristics of underlying securities, and other factors, the price of an ETF can be lower that the aggregate market price of its cash and component individual securities (net asset value – NAV). An ETF is subject to the same market risks as those of its underlying individual securities, and also has internal expenses that can lower investment returns. Mutual Funds: Investing in mutual funds carries the risk of capital loss and thus you may lose money investing in mutual funds. All mutual funds have costs that lower investment returns. The funds can be of bond “fixed income” nature (lower risk) or stock “equity” nature. Precious Metal ETFs (e.g., Gold, Silver, or Palladium Bullion backed “electronic shares” not physical metal) specifically may be negatively impacted by several unique factors, among them (1) large sales by the official sector which own a significant portion of aggregate world holdings in gold and other precious metals, (2) a significant increase in hedging activities by producers of gold or other precious metals, (3) a significant change in the attitude of speculators and investors. Hedge Funds often engage in leveraging and other speculative investment practices that may increase the risk of investment loss; can be highly illiquid; are not required to provide periodic pricing or valuation information to investors; May involve complex tax structures and delays in distributing important tax information; are not subject to the same regulatory requirements as mutual funds; and often charge high fees. In addition, hedge funds may invest in risky securities and engage in risky strategies. Private equity funds carry certain risks. Capital calls will be made on short notice, and the failure to meet capital calls can result in significant adverse consequences, including but not limited to a total loss of investment. Private placements carry a substantial risk as they are subject to less regulation than are publicly offered securities, the market to resell these assets under applicable securities laws may be illiquid, due to restrictions, and liquidation may be taken at a substantial discount to the underlying value or result in the entire loss of the value of such assets. Venture capital funds invest in start-up companies at an early stage of development in the interest of generating a return through an eventual realization event; the risk is high as a result of the uncertainty involved at that stage of development. Options are contracts to purchase a security at a given price, risking that an option may expire out of the money resulting in minimal or no value. An uncovered option is a type of options contract that is not backed by an offsetting position that would help mitigate risk. The risk for a “naked” or uncovered put is not unlimited, whereas the potential loss for an uncovered call option is limitless. Spread option positions entail buying and selling 10  multiple options on the same underlying security, but with different strike prices or expiration dates, which helps limit the risk of other option trading strategies. Option transactions also involve risks including but not limited to economic risk, market risk, sector risk, idiosyncratic risk, political/regulatory risk, inflation (purchasing power) risk and interest rate risk. Non-U.S. securities present certain risks such as currency fluctuation, political and economic change, social unrest, changes in government regulation, differences in accounting and the lesser degree of accurate public information available. Past performance is not indicative of future results. Investing in securities involves a risk of loss that you, as a client, should be prepared to bear. Voting Client Securities (Proxy Voting) RevCap will not ask for, nor accept voting authority for client securities. Clients will receive proxies directly from the issuer of the security or the custodian. Clients should direct all proxy questions to the issuer of the security. Item 7: Client Information Provided to Portfolio Managers All client information material to managing the portfolio (including basic information, risk tolerance, sophistication level, and income level) is provided to the portfolio manager. The portfolio manager will also have access to that information as it changes and is updated. Item 8: Client Contact with Portfolio Managers RevCap does not restrict clients from contacting portfolio managers. RevCap’s representatives can be contacted during regular business hours using the information on the Form ADV Part 2B cover page. Item 9: Additional Information A. Disciplinary Action and Other Financial Industry Activities Criminal or Civil Actions There are no criminal or civil actions to report. Administrative Proceedings There are no administrative proceedings to report. 11  Self-Regulatory Organization (SRO) Proceedings There are no self-regulatory organization proceedings to report. Registration as a Broker/Dealer or Broker/Dealer Representative Neither RevCap nor its representatives are registered as, or have pending applications to become, a broker/dealer or a representative of a broker/dealer. Registration as a Futures Commission Merchant, Commodity Pool Operator, or a Commodity Trading Advisor Neither RevCap nor its representatives are registered as or have pending applications to become either a Futures Commission Merchant, Commodity Pool Operator, or Commodity Trading Advisor or an associated person of the foregoing entities. Registration Relationships Material to this Advisory Business and Possible Conflicts of Interests Ryan Fleischer, and Chad McKown, are licensed insurance agents and operate under Revolution Group, LLC. Revolution Group, LLC is a licensed insurance agency. From time to time, will offer clients advice or products from those activities. Clients should be aware that these services pay a commission or other compensation and involve a conflict of interest, as commissionable products conflict with the fiduciary duties of a registered investment adviser. RevCap always acts in the best interest of the client; including the sale of commissionable products to advisory clients. Clients are in no way required to utilize the services of any representative of RevCap in connection with such individual's activities outside of RevCap. RevGroup, along with its affiliates, offers Outsourced Chief Investment Officer (OCIO) services to foundations, endowments, and family offices that require investment sourcing, due diligence, and governance support without delegating full portfolio management. In this non-discretionary capacity, RevGroup conducts due diligence and sources investment opportunities, asset allocation options, and third-party managers that conform to the client’s existing investment mandate, policy, risk profile, and objectives. These services are intended for clients who retain full decision-making authority over their portfolios and engage RevGroup to locate and evaluate investments within their established framework. RevGroup and its affiliates do not exercise discretionary authority or take custody of client assets under this service. Instead, we work with the client’s investment committee, board, or designated fiduciaries to source and perform due diligence on investment opportunities (such as private equity deals, real assets, or other alternative investments) that fit the institution’s or family’s given investment policy, and to provide governance support. Governance services may include reviewing or drafting investment policy statements, assisting with fiduciary best practices, and supporting committee reporting or 12  oversight processes. This OCIO sourcing, due diligence, and governance support may be provided on a project-specific, interim, or ongoing basis, depending on the client’s needs. This service creates a conflict of interest insofar as it incentivizes RevGroup to recommend this service to clients. This conflict is mitigated by the fact the members of RevGroup apply the fiduciary standard of care to all advisory clients by placing their interests ahead of their own and should OCIO services be needed by an advisory client, they are free to seek an alternate service provider besides RevGroup. Revolution Capital, LLC (RevCap) is a subsidiary of Revolution Group LLC and a sister company to Revolution Tax LLC, which provides accounting, tax preparation, and tax planning services. These services are performed by a CPA who is an employee of Revolution Group LLC. Fees for these services are paid to Revolution Tax LLC. This affiliated structure may present a conflict of interest, as Revolution Capital, LLC and Revolution Tax LLC, through their common ownership under Revolution Group LLC, could benefit financially from referrals of advisory clients to Revolution Tax LLC. To address this, the IA discloses that clients are under no obligation to use these services and are free to select any qualified provider. Referrals to Revolution Tax LLC are made only when deemed appropriate for the client’s needs, and the IA maintains policies to ensure that such recommendations prioritize the client’s best interests over the financial interests of Revolution Group LLC or its subsidiaries. Revolution Advanced Tax, LLC is an affiliated firm offering attest services. The firm is owned 51% by the CPA that performs these services and 49% by Ryan Fleischer. Attest services consist of CPAs offering independent, objective examinations or reviews of financial information, systems, processes, or controls. These services provide assurance to third parties – such as investors, creditors, or regulators – regarding the reliability and accuracy of that information. This firm creates a conflict of interest since Ryan Fleischer (Revolution Capital, LLC’s Chief Compliance Officer) owns 49% of this firm and business sent to this entity would provide indirect compensation. To address this, the IA discloses that clients are under no obligation to use the attest services offered by this firm and are free to select any other qualified provider. Should a referral be made to Revolution Advanced Tax, LLC, it would only be in a case deemed appropriate for the client’s needs, and RevCap maintains policies to ensure that such recommendations prioritize the clients’ best interests over the financial interests of Revolution Group, LLC or its subsidiaries. Ryan Mathew Fleischer is a Founder/President at Revolution Group, LLC. Selection of Other Advisers or Managers and How This Adviser is Compensated for Those Selections RevCap has discretion to choose third-party investment advisers to manage client assets. Clients will pay RevCap its standard fee in addition to the advisory fee of the third-party adviser. RevCap will always act in the best interests of the client, including when determining which third-party investment adviser to recommend to clients, and the aggregate advisory fee will not exceed any limit imposed by regulatory agencies. RevCap will confirm that all recommended advisers are licensed, notice filed, or exempt in the states in which RevCap is recommending them to clients. 13  B. Code of Ethics, Client Referrals, and Financial Information Code of Ethics RevCap has a written Code of Ethics that covers the following areas: Prohibited Purchases and Sales, Insider Trading, Personal Securities Transactions, Exempted Transactions, Prohibited Activities, Conflicts of Interest, Gifts and Entertainment, Confidentiality, Service on a Board of Directors, Compliance Procedures, Compliance with Laws and Regulations, Procedures and Reporting, Certification of Compliance, Reporting Violations, Compliance Officer Duties, Training and Education, Recordkeeping, Annual Review, and Sanctions. RevCap’s Code of Ethics is available free upon request to any client or prospective client. Recommendations Involving Material Financial Interests RevCap does not recommend that clients buy or sell any security in which RevCap or a related person has a material financial interest. Investing Personal Money in the Same Securities as Clients From time to time, representatives of RevCap may buy or sell securities for themselves that they also recommend to clients. This may provide an opportunity for representatives of RevCap to buy or sell the same securities before or after recommending the same securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest. RevCap will always document any transactions that could be construed as conflicts of interest and will never engage in trading that operates to the client’s disadvantage when similar securities are being bought or sold. Trading Securities At/Around the Same Time as Clients’ Securities From time to time, representatives of RevCap may buy or sell securities for themselves at or around the same time as clients. This may provide an opportunity for representatives of RevCap to buy or sell securities before or after recommending securities to clients resulting in representatives profiting off the recommendations they provide to clients. Such transactions may create a conflict of interest; however, RevCap will never engage in trading that operates to the client’s disadvantage if representatives of RevCap buy or sell securities at or around the same time as clients. Frequency and Nature of Periodic Reviews Accounts are reviewed at least annually by Ryan M Fleischer, CEO, with regard to clients’ respective investment policies and risk tolerance levels. 14  Factors That Will Trigger a Non-Periodic Review of Client Accounts Reviews may be triggered by material market, economic or political events, or by changes in client's financial situations (such as retirement, termination of employment, physical move, or inheritance). Content and Frequency of Regular Reports Provided to Clients Each client will receive a quarterly account statement from the custodian. RevCap will also provide at least quarterly a separate written report to the client. Economic Benefits Provided by Third Parties for Advice Rendered to Clients Charles Schwab & Co., Inc. Advisor Services provides RevCap with access to Charles Schwab & Co., Inc. Advisor Services’ institutional trading and custody services, which are typically not available to Charles Schwab & Co., Inc. Advisor Services retail investors. These services generally are available to independent investment advisers on an unsolicited basis, at no charge to them so long as a total of at least $10 million of the adviser’s clients’ assets are maintained in accounts at Charles Schwab & Co., Inc. Advisor Services. Charles Schwab & Co., Inc. Advisor Services includes brokerage services that are related to the execution of securities transactions, custody, research, including that in the form of advice, analyses and reports, and access to mutual funds and other investments that are otherwise generally available only to institutional investors or would require a significantly higher minimum initial investment. For RevCap client accounts maintained in its custody, Charles Schwab & Co., Inc. Advisor Services generally does not charge separately for custody services but is compensated by account holders through commissions or other transaction-related or asset-based fees for securities trades that are executed through Charles Schwab & Co., Inc. Advisor Services or that settle into Charles Schwab & Co., Inc. Advisor Services accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to RevCap other products and services that benefit RevCap but may not benefit its clients’ accounts. These benefits may include national, regional or RevCap specific educational events organized and/or sponsored by Charles Schwab & Co., Inc. Advisor Services. Other potential benefits may include occasional business entertainment of personnel of RevCap by Charles Schwab & Co., Inc. Advisor Services personnel, including meals, invitations to sporting events, including golf tournaments, and other forms of entertainment, some of which may accompany educational opportunities. Other of these products and services assist REVCAP in managing and administering clients’ accounts. These include software and other technology (and related technological training) that provide access to client account data (such as trade confirmations and account statements), facilitate trade execution (and allocation of aggregated trade orders for multiple client accounts, if applicable), provide research, pricing information and other market data, facilitate payment of RevCap’s fees from its clients’ accounts (if applicable), and assist with back- office training and support functions, recordkeeping and client reporting. Many of these services generally may be used to service all or some substantial number of RevCap’s 15  accounts. Charles Schwab & Co., Inc. Advisor Services also makes available to RevCap other services intended to help RevCap manage and further develop its business enterprise. These services may include professional compliance, legal and business consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, employee benefits providers, and human capital consultants, insurance and marketing. In addition, Charles Schwab & Co., Inc. Advisor Services may make available, arrange and/or pay vendors for these types of services rendered to RevCap by independent third parties. Charles Schwab & Co., Inc. Advisor Services may discount or waive fees it would otherwise charge for some of these services or pay all or a part of the fees of a third-party providing these services to RevCap. RevCap is independently owned and operated and not affiliated with Charles Schwab & Co., Inc. Advisor Services. From time to time we or our affiliates may receive compensation from product sponsors and service providers in the form of sponsorship fees for educational seminars or events. Our receipt of these sponsorship fees is for the purpose of defraying costs associated with coordinating and hosting the sponsored event. These sponsorship fees do not entitle the sponsor to any preferential treatment, and no sponsor will present their specific products or investments at any of the events. Accordingly, a conflict of interest may exist where we receive compensation from sponsors and service providers willing to contribute sponsorship fees more frequently or in greater amounts than other product sponsors and service providers. However, consideration of product sponsors and service providers for sponsorship fee compensation by us is based on the quality of the product sponsor or service provider and is not solely based on the anticipated sponsorship fees our Firm will receive. Clients or potential investors that attend an educational seminar or event where a product sponsor or service provider is in attendance should assume that the product sponsor or service provider has paid or reimbursed us or our affiliates for part or all of the total cost of the educational seminar or event, including travel costs. Compensation to Non – Advisory Personnel for Client Referrals RevCap does not directly or indirectly compensate any person who is not advisory personnel for client referrals. Balance Sheet RevCap neither requires nor solicits prepayment of more than $1,200 in fees per client, six months or more in advance, and therefore is not required to include a balance sheet with this brochure. Financial Conditions Reasonably Likely to Impair Ability to Meet Contractual Commitments to Clients RevCap does not have any financial condition that would impair its ability to meet contractual commitments to clients. 16  Bankruptcy Petitions in Previous Ten Years RevCap has not been the subject of a bankruptcy petition. Item 10: Requirements For State Registered Advisers RevCap is an SEC registered investment adviser, and as such, is not required to provide information for this Section 17