SANCHEZ GAUNT CAPITAL MANAGEMENT, LLC

Item 1: Cover Page Form ADV Part 2A Sanchez Gaunt Capital Management LLC 9160 Double Diamond Parkway Suite 100 Reno, NV 89521 775-800-1801 December 18, 2025 This brochure provides information about the qualifications and business practices of Sanchez Gaunt Capital Management LLC. If you have any questions about the contents of this brochure, please contact us at 775-800-1801. 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 Sanchez Gaunt Capital Management LLC is available on the SEC’s website at www.adviserinfo.sec.gov. Sanchez Gaunt Capital Management LLC is a registered investment adviser. Registration does not imply any level of skill or training.  Item 2: Material Changes The following material changes have been made to the Form ADV Part 2A since the initial filing of the form:  On December 18, 2025, the following sections were amended to disclose services related to Estate Planning services and to disclose the conflict of interest that exists between Sanchez Gaunt Capital Management and Estate Planning Network of America, LLC: Item 4: Advisory Business Item 5: Fees and Compensation o o o Item 10: Other Financial Industry Activities and Affiliations Page | 2  Item 3: Table of Contents Item 1: Cover Page ......................................................................................................................................... 1 Item 2: Material Changes ............................................................................................................................ 2 Item 3: Table of Contents ............................................................................................................................ 3 Item 4: Advisory Business .......................................................................................................................... 4 Item 5: Fees and Compensation .............................................................................................................. 8 Item 6: Performance-Based Fees and Side-by-Side Management .............................................. 10 Item 7: Types of Clients ............................................................................................................................ 11 Item 8: Methods of Analysis, Investment Strategies and Risk of Loss ...................................... 11 Item 9: Disciplinary Information .......................................................................................................... 16 Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ......................................................................................................................................................... 19 Item 12: Brokerage Practices ................................................................................................................. 20 Item 13: Review of Accounts ................................................................................................................... 21 Item 14: Client Referrals and Other Compensation ........................................................................ 21 Item 15: Custody ........................................................................................................................................ 22 Item 16: Investment Discretion ............................................................................................................. 23 Item 17: Voting Client Securities ........................................................................................................... 23 Item 18: Financial Information ............................................................................................................ 23 Page | 3  Item 4: Advisory Business Sanchez Gaunt Capital Management LLC (“Adviser” or “SGCM”) was founded in April 2025. We are an investment adviser registered with the U.S. Securities and Exchange Commission with its principal place of business located in Nevada. The Principal Owners are Mr. Jon Sanchez and Mr. Jason Gaunt. Portfolio Management Services Sanchez Gaunt Capital Management LLC offers the following services to its clients: At SGCM, our portfolio management service provides a comprehensive approach to investing that begins with an in-depth assessment of your financial circumstances, goals, time horizon, and risk tolerance. Through personal consultations and detailed questionnaires, we develop a thorough understanding of your investment objectives, which forms the foundation for your customized Investment Policy Statement. Based on this framework, we construct a diversified portfolio using a strategic mix of investment vehicles including stocks, bonds, ETFs, mutual funds, and when appropriate, alternative investments - all specifically selected to align with your financial objectives while adhering to your risk parameters. Our management process involves ongoing discretionary oversight of your investments, where we continuously monitor performance against established benchmarks, maintain target allocations through disciplined rebalancing, implement tax-efficient strategies when beneficial, and make tactical adjustments in response to changing market conditions or shifts in your personal circumstances. We provide transparent communication through regular performance reporting, online account access, and scheduled review meetings to discuss your portfolio's progress and any necessary modifications. Our dynamic approach to portfolio management remains responsive to both evolving market environments and changes in your life situation, with the ultimate goal of helping you achieve your long-term Third-Party Money Manager Services financial objectives. investment advisory services by At SGCM, provide identifying, evaluating, and recommending third-party money managers to manage client assets. Our role includes conducting due diligence on potential money managers, matching clients with appropriate managers based on their investment objectives and risk tolerance and providing ongoing monitoring of the selected managers' performance and service quality. We maintain relationships with various institutional money managers across different investment styles and asset classes, allowing us to offer clients access to specialized investment expertise that may not be available through traditional advisory relationships. Page | 4  As part of this service, we assist clients in completing the necessary documentation to establish accounts with selected third-party managers, facilitate the initial funding process, and serve as a liaison between clients and managers for ongoing account administration matters. We also provide periodic reporting and performance analysis to help clients understand how their selected managers are performing relative to agreed-upon benchmarks and objectives. This service model allows clients to benefit from institutional- quality money management while receiving personalized advisory services and ongoing oversight from our firm. SGCM may offer third-party money manager services to Clients by selecting the AssetMark Platform. For more information regarding the AssetMark Platform, refer to AssetMark Platform or Referral Disclosure Brochure. The minimum investment required on the AssetMark Platform depends upon the Investment Solution chosen for a Client’s account and is generally $10,000 for Mutual Fund and $25,000 for Exchange Traded Funds (“ETF”) Accounts, and from $25,000 to $1,000,000 for Individually Managed Accounts (“IMA”), depending on the investment strategy selected for the account. These minimums are described in more detail in the Fees & Minimums Page in the AssetMark Platform or Referral Disclosure Brochure. Accounts below the stated minimums may be accepted on an individual basis at the discretion of AssetMark. Estate Planning Services Estate planning services—including living trusts, wills, powers of attorney, and medical directives—are offered through Estate Planning Network of America, LLC, a separate entity related to Sanchez Gaunt Capital Management, LLC. Through our partnership with an independent third-party technology company, Wealth, Inc. (“Wealth”), we can facilitate the preparation of various estate planning documents for clients. Such services are generally separate from any investment management and/or financial planning services that we may render to a client, and the exact scope of such estate planning services will depend on the nature of a client's specific estate planning needs. As a condition of utilizing Wealth, you must agree to the terms and conditions, available at wealth.com We may pay for your access to Wealth. For the avoidance of doubt, neither Advisor or Wealth renders legal advice or services. Wealth offers the ability to consult with licensed attorneys in various jurisdictions at an additional charge, and subject to additional terms and conditions. Page | 5  Periodicals/Newsletter Subscriptions SGCM offers services through the publication of newsletters, periodicals, and reports containing financial and investment information, analysis, and recommendations. Our publications provide educational content and investment insights on various securities, investment strategies, and market trends. These publications are offered on a subscription basis and may focus on specific investment approaches, asset classes, sectors, or market segments. Our newsletters and periodicals are designed to provide subscribers with information to assist them in making their own investment decisions.  Our publications typically include:      Market analysis and commentary Economic trend assessments Investment recommendations and ideas Portfolio construction concepts Risk management strategies Educational content on various investment topics We do not provide personalized investment advice tailored to individual subscribers' specific financial situations or objectives through our publication services. Subscribers are responsible for determining the appropriateness of any investment ideas or strategies presented in our publications for their individual circumstances. Educational Seminars and Workshops SGCM provides educational seminars and workshops to clients, prospective clients, and other entities such as businesses, nonprofit organizations, and educational institutions. These educational programs are offered on topics relevant to investing and financial planning, including but not limited to retirement planning, investment strategies, market trends, risk management, college funding, estate planning, and social security optimization. Our educational events are designed to provide general information on financial concepts and principles rather than specific investment recommendations. Seminars and workshops are typically conducted in-person at various locations, though we may also offer virtual events through online platforms. These educational sessions may be presented as one-time events, a series of sessions, or recurring programs depending on the subject matter and audience needs. The content is developed by our firm’s qualified financial professionals who possess the knowledge and experience necessary to present complex financial information in an accessible and understandable format. Page | 6  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 of 1974, as amended (ERISA) and/or the Internal Revenue Code of 1986, as amended (the Code), as applicable, which are laws  governing retirement accounts. As such, we are bound by the following duties:  We must act in your best interest and not place our interests ahead of yours.  We must provide investment advice that is based on your financial needs and circumstances.  We must charge no more than is reasonable for our services.  We must make no misleading statements about investments, compensation, conflicts of interest, or other matters related to investment decisions.  We must follow policies and procedures designed to ensure that we give advice that is in your best interest. We must avoid prohibited transactions and disclose potential conflicts of interest to you. This fiduciary acknowledgment is being provided to satisfy the disclosure requirements under Department of Labor Prohibited Transaction Exemption 2020-02. The way we make money creates some conflicts with your interests. You should understand and ask us about these conflicts because they can affect the investment advice we provide you.  For retirement accounts subject to ERISA and/or the Code, we will:  Provide services at a level of care, skill, prudence, and diligence that a prudent person acting in a like capacity and familiar with such matters would use.  Disclose to you any conflict of interest that might incline us to render advice which is not disinterested. Not receive any compensation for services rendered that would violate applicable law. Assets Under Management (AUM) As of September 2025, we were actively managing $244,990,016 in client assets on a discretionary basis. Page | 7  Item 5: Fees and Compensation We provide our services on a fee-only basis. Our fees are based on a percentage of assets under management. The specific manner in which fees are charged by SGCM is established in the client’s written agreement with the Adviser. We will generally bill our fees on a quarterly basis, in advance. Portfolio Management Services Fees The annual fee paid for investment advisory services will not exceed 2.00% of the total assets under management. Fees are assessed quarterly and are based on the account value as of the last business day of the previous calendar quarter. The quarterly fee is calculated by multiplying the market value of the assets under management by the annual percentage rate and then dividing by four (4). For example, a client account valued at $500,000 at the end of the previous quarter, with an annual fee rate of 1.50%, would be charged $1,875 for that quarter ($500,000 × 1.50% ÷ 4 = $1,875). In the event a client terminates the advisory agreement with our firm before the end of the billing period, we will refund any unearned fees on a pro-rata basis. The amount of the refund will be based on the number of days remaining in the billing period after the effective date of termination. For example, if a client terminates the advisory agreement 45 days into a 90-day quarter, they would receive a refund of 50% of the quarterly fee previously paid. Refunds will be processed within 30 days of the effective date of termination and will be issued using the same method as the original payment (either credited back to the client's account or sent directly to the client, depending on how fees were initially paid). Third-Party Money Manager Services Fees When we recommend third-party money managers to manage your assets, you will pay investment advisory fees directly to the third-party money manager, not to us. The third- party money manager will then pay us a portion of the fee they receive from you as compensation for our services. Third-party money managers typically charge annual advisory fees not to exceed 2% of assets under management. The exact fee arrangement varies by third-party manager and is disclosed in their Form ADV Part 2A brochure, which will be provided to you. Fees and compensation for using the AssetMark Platform are provided in more detail in the AssetMark Platform or Referral Disclosure Brochure. Fees and Investment Minimums schedules are included in AssetMark’s Platform or Referral Disclosure Brochure, and the Page | 8  Client Billing Authorization will also state the fee applicable to your account. 1. The fees applicable to each Account on the AssetMark Platform will include: 2. Financial Advisor Fee, AssetMark’s Platform Fee, which includes any Strategist or Manager Fee, as applicable, and most custody fees. The Platform Fee Schedules for the various Investment Solutions are listed in the Fees & Minimum table, at the end of AssetMark’s Platform or Referral Disclosure Brochure. Other fees for special services may also be charged. The Client should consider all applicable fees. AssetMark Client fees are payable quarterly, in advance, based on assets under management. Clients may terminate AssetMark accounts at any time and receive a full pro- rata refund of any unearned fees. Estate Planning Services Fees Estate planning services—including living trusts, wills, powers of attorney, and medical directives—are offered through Estate Planning Network of America, LLC, a separate entity related to Sanchez Gaunt Capital Management, LLC. If estate planning services are recommended, the Client would engage directly with Estate Planning Network of America, LLC. Fees for these services are billed separately and will be outlined in the Client's agreement with Estate Planning Network of America, LLC. The Client is under no obligation to use Estate Planning Network of America, LLC for estate planning services. You are free to work with any estate planning provider of your choice. Periodicals/Newsletter Subscriptions Our firm may provide clients with access to various periodicals, newsletters, and other publications as part of our advisory services. These publications are currently provided at no additional cost to clients and are included as part of our standard advisory fee structure. The content of these publications is intended to be educational in nature and to provide general market information and insights. We do not separately bill for these publications, and clients are under no obligation to use or act upon the information contained within them. Should our policy regarding the cost of these publications change in the future, we will update this brochure accordingly and provide proper notice to clients and prospects. Page | 9  Educational Seminars and Workshops Our firm provides educational seminars and workshops to clients and prospective clients on various financial topics at no charge. These seminars and workshops are purely educational in nature and do not involve the sale of any investment products. Topics may include issues related to financial planning, retirement strategies, estate planning, tax considerations, and investment management. The information presented during these events is not intended to provide specific advice regarding attendees' personal financial situations, nor does it constitute a recommendation to purchase specific products or services. Attendees are under no obligation to engage our firm’s advisory services as a result of participating in these educational events. While we currently offer these educational programs at no charge, we reserve the right to charge fees for such events in the future. Should we implement a fee structure for our educational seminars and workshops, we will update this brochure accordingly and provide proper notice to clients and prospects. Negotiable Fee Disclosure At its discretion, SGCM may charge a lesser investment advisory fee, charge a flat fee, waive its fee entirely, or charge a fee on a different interval, based upon certain criteria (i.e. anticipated future earning capacity, anticipated future additional assets, the dollar amount of assets to be managed, related accounts, account composition, the complexity of the engagement, anticipated services to be rendered, grandfathered fee schedules, employees and family members, courtesy accounts, competition, negotiations with client, etc.). As a result, similarly situated clients could pay different fees. In addition, similar advisory services may be available from other investment advisers for similar or lower fees. Payment of Fees � The Advisory Agreement and the separate agreement with any Financial Institutions generally authorizes SGCM to debit the client’s account for the amount of advisory fee and to directly remit that fee to the irm. Any Financial Institutions recommended by SGCM have agreed to send a statement to the client, at least quarterly, indicating all amounts disbursed from the account including the amount of advisory fees paid directly to Adviser. Item 6: Performance-Based Fees and Side-by-Side Management SGCM does not charge performance-based fees (fees based on a share of capital gains on or Page | 10  capital appreciation of the assets of a client). All fees are calculated as described in Item 5 - Fees and Compensation and are not charged on the basis of income or capital gains or capital appreciation of the funds or any portion of the funds of an advisory client. We do not manage both accounts that are charged a performance-based fee and accounts that are charged another type of fee, such as an hourly, flat, or asset-based fee. As a result, we do not face the potential conflicts of interest arising from "side-by-side management" where an adviser might be incentivized to favor accounts from which it receives performance- based compensation. Our firm believes in a transparent fee structure that aligns our interests with those of our clients without creating potential conflicts that can arise from performance-based compensation arrangements. Our advisory fees are based solely on assets under management and/or fixed fees as outlined in our fee schedule in Item 5. Item 7: Types of Clients  We provide advisory services to the following types of clients:    Individuals High Net Worth Individuals Trusts, Estates, and Charitable Organizations Corporations or Business Entities SGCM does not require a minimum account size or minimum annual fee to open or maintain an account. We believe that investment advice should be accessible to clients regardless of portfolio size, and we work with clients at various stages of their financial journey. While we do not impose minimums, certain third-party investment managers or sub- advisers that we recommend may have minimum account size requirements. In such cases, these minimums will be disclosed to clients prior to engagement of these services. We reserve the right to decline to manage an account if we determine that the account size would not allow us to effectively implement our investment strategy or if we believe we cannot provide a suitable level of service relative to the client's needs. Item 8: Methods of Analysis, Investment Strategies and Risk of Loss Our methods of analysis include charting analysis, fundamental analysis, technical analysis, Page | 11  and cyclical analysis. The investment strategies we use to implement any investment advice given to clients include long-term purchases (securities held at least a year), short-term purchases (securities sold within a year), trading, and option writing. Investing in securities involves risk of loss that clients should be prepared to bear. We do not represent or guarantee that the services or methods of analysis we offer can or will predict future results. METHODS OF ANALYSIS We use the following methods of analysis in formulating our investment advice and/or Charting. managing client assets: In this type of technical analysis, we review charts of market and security activity in an attempt to identify when the market is moving up or down and to predict when and Fundamental Analysis. how long the trend may last and when that trend might reverse. We attempt to measure the intrinsic value of a security by looking at economic and financial factors (including the overall economy, industry conditions, and the financial condition and management of the company itself) to determine if the company is underpriced (indicating it may be a good time to buy) or overpriced (indicating it may be time to sell). Fundamental analysis does not attempt to anticipate market movements. This presents a potential risk, as the price of a security can move up or down along with the overall market Technical Analysis. regardless of the economic and financial factors considered in evaluating the stock. We analyze past market movements and apply that analysis to the present in an attempt to recognize recurring patterns of investor behavior and potentially predict future price movement. Technical analysis does not consider the underlying financial condition of a company. This presents a risk in that a poorly managed or financially unsound company may Cyclical Analysis. underperform regardless of market movement. In this type of technical analysis, we measure the movements of a particular stock against the overall market in an attempt to predict the price movement of Risks for all forms of analysis. the security. Our securities analysis methods rely on the assumption that the companies whose securities we purchase and sell, the rating agencies that review these securities, and other publicly available sources of information about these securities, are providing accurate and unbiased data. While we are alert to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or Page | 12  misleading information. INVESTMENT STRATEGIES Investment strategies will be selected based on client needs. Adviser may utilize strategies such as asset allocation, trend analysis, fundamental analysis, technical analysis or economic indicators. Each investment adviser representative (IAR) of the Adviser may have their own strategies; therefore, a client should discuss his/her objectives with the IAR thoroughly. No assumption can be made that any particular strategy will provide better returns than other investment strategies. Investing in securities involves the risk of loss that clients should be prepared to bear. Before investing in any specific asset class, client should discuss their tolerance for risk with the IAR and carefully consider the risks associated with the investment by reviewing, as applicable, the prospectus, offering memorandum or disclosure brochure. All investment decisions involve risk including the potential loss of principal. RISK OF LOSS Investing in securities involves the risk of loss that clients should be prepared to bear. While we work diligently to help you achieve your financial goals, we cannot guarantee any level of performance or that you will not experience financial loss. Below are some of the General Market Risk primary risks that may affect your investments: The market value of securities may fluctuate, sometimes rapidly and unpredictably. These fluctuations may cause a security to be worth less than the price originally paid for it, or less than it was worth at an earlier time. Market risk may affect a single issuer, an entire industry, or the market as a whole. U.S. and international markets have experienced significant volatility in recent years, which may increase the risks associated with investing in Equity Securities Risk securities. Equity securities (stocks) may experience sudden, unpredictable drops in value or long periods of decline in value. This may occur because of factors that affect securities markets Fixed Income Securities Risk generally or factors affecting specific industries, sectors, or companies. Fixed income securities (bonds) are subject to interest rate risk, credit risk, inflation risk, call risk, and liquidity risk. Interest rate risk is the risk that bond prices will decline because of rising interest rates. Credit risk is the risk that a bond issuer will fail to make interest or principal payments when due. Inflation risk arises because the value of the income stream Page | 13  from a bond will decline due to inflation. Call risk occurs when an issuer redeems a bond before maturity. Liquidity risk refers to the risk that an investor may not be able to sell a Mutual Fund and ETF Risk bond quickly at an appropriate price. Investments in mutual funds and ETFs are subject to all the risks of the underlying securities in which those vehicles invest. In addition, the value of your investment in a mutual fund or ETF will fluctuate depending on the performance of the investments chosen by the fund's manager, market conditions, and other factors. Mutual funds and ETFs also Alternative Investment Risk charge internal expenses and management fees that are disclosed in the fund's prospectus. Alternative investments, including real estate investment trusts (REITs), commodities, managed futures, and private equity, among others, may involve unique risks such as limited liquidity, tax considerations, incentive fee structures, speculative investment Environment, Social, and Corporate Governance Risk strategies, and different regulatory and reporting requirements. Clients utilizing responsible investing strategies and environment, social responsibility, and corporate governance (ESG) factors may underperform strategies that do not utilize such considerations. Responsible investing and ESG strategies may operate by either excluding the investments of certain issuers or by selecting investments based on their compliance with factors such as ESG. These strategies may exclude certain securities, issuers, sectors, or industries from a client’s portfolio, potentially negatively affecting the client’s investment performance if an excluded security, issuer, sector, or industry outperforms. Responsible investing and ESG are subjective by nature, and SGCM may rely on rankings, ratings, scores, and other analytic metrics provided by third parties in determining whether an issuer meets the firm’s standards for inclusion or exclusion. A client’s perception may differ from that of SGCM or a third party on how to judge an issuer’s adherence to Private Placement Securities Risk responsible investing principles. Where the Adviser believes it to be suitable and in the Client's best interest, the Adviser may recommend private placement securities. These recommendations are typically  related to real estate and may include the following types of investments:  Real estate-focused private placements  Delaware Statutory Trusts (DSTs), including those used in 1031 exchange transactions Limited partnerships (LPs) or limited liability companies (LLCs) investing in real estate Page | 14   Non-traded real estate investment trusts (REITs) Private placement securities are generally illiquid, may have limited transparency, and often carry higher risk than publicly traded securities. Clients should carefully review offering documents and consider their liquidity needs, investment time horizon, and risk Foreign Securities Risk tolerance before investing in these types of securities. Investments in foreign securities involve risks relating to political, social, and economic developments abroad, as well as risks resulting from differences between the regulations to which U.S. and foreign issuers and markets are subject. These risks may include instability, and different expropriation, currency blockages, political or economic Small and Mid-Cap Company Risk accounting standards. Securities of companies with small and medium market capitalizations are often more volatile and less liquid than investments in larger companies. Small and mid-cap companies may face higher costs of capital, greater business risk, limited product lines, limited Concentrated Portfolio Risk financial resources, and less management depth. Portfolios that are concentrated in a specific sector, industry, or issuer may be subject to greater risk of loss and volatility than more diversified portfolios. A concentrated portfolio Cybersecurity Risk will generally be more volatile than a more diversified portfolio. With the increased use of technology, our firm and client accounts are potentially vulnerable to cyber-attacks, identity theft, and fraud. While we maintain policies and procedures designed to protect your assets, personal information, and privacy, there is no Pandemic Risk guarantee that such measures will prevent all security breaches. Global health events, such as the COVID-19 pandemic, have caused significant market volatility and economic disruption. Such events may have unpredictable and far-reaching Strategy and Analysis Risk impacts on global financial markets. The success of our investment strategies depends on the accuracy of our analysis. There is no guarantee that our analysis will be accurate or that our investment strategies will be successful. Furthermore, our strategies and analyses may not be suitable for all clients. Page | 15  Tax Risk Tax laws and regulations are subject to change, which may have significant impacts on investment strategies and after-tax returns. We are not tax professionals, and clients should consult with qualified tax advisors regarding the tax implications of any investment General Risk of Loss strategy or transaction. All investments involve different degrees of risk. You should be aware of your risk tolerance level and financial situations at all times. We cannot guarantee the successful performance of an investment and we are expressly prohibited from guaranteeing accounts against losses arising from market conditions. AssetMark In advising retail clients of SGCM investing in AssetMark Platform, SGCM may select from non-discretionary Model Providers that can include mutual funds, Exchange Traded Funds (ETF’s), and other investment solutions offered on the Platform. These solutions are provided by a number of institutional investment strategists and are based on the information, research, asset allocation methodology and investment strategies of these institutional strategists, including AssetMark. SGCM also introduces clients to and advises on the selection of independent investment managers who provide discretionary management of individual portfolios using a variety of different securities analysis methods, sources of information and investment strategies. Clients will receive a separate disclosure brochure from these investment managers regarding their investment advisory services. With respect to clients investing in the AssetMark Platform, SGCM introduces clients to, and advises on the selection of independent investment managers who provide discretionary management of individual portfolios including a wide variety of security types. Clients will receive a separate disclosure from such investment managers regarding any such investment manager’s advisory services. Item 9: Disciplinary Information Sanchez Gaunt Capital Management is required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of our advisory business or the integrity of our management. We have no disciplinary events to disclose regarding Sanchez Gaunt Capital Management LLC. Additionally, there are no disciplinary events to disclose regarding Mr. Jason Gaunt. Page | 16  The following disclosure relates to a regulatory action involving Mr. Jon Sanchez: On September 25, 2020, pursuant to Article VI, Section 3 of FINRA By-Laws and FINRA Rule 9554, Mr. Sanchez was temporarily suspended by the Financial Industry Regulatory Authority (FINRA) for failure to comply with an arbitration award or settlement agreement or to satisfactorily respond to a FINRA request to provide information concerning the status of compliance. This suspension was subsequently lifted on October 8, 2020, after Mr. Sanchez satisfied the requirements set forth by FINRA. During the suspension period (September 25, 2020 - October 8, 2020), Mr. Sanchez was prohibited from associating with any FINRA member firm in any capacity. This matter has been fully resolved, and Mr. Sanchez is currently in good standing with regulatory authorities. Item 10: Other Financial Industry Activities and Affiliations SGCM is not and does not have a related person that is a broker-dealer, municipal securities dealer, or government securities dealer or broker. We are not and do not have a related person that is an investment company, financial planning firm, commodity pool operator, or commodity trading advisor. Jon Sanchez is licensed as an insurance agent and offers fixed and variable life insurance products for commission- based compensation. As an agent Jon Sanchez also receives other compensation such as - fixed or variable life renewals from insurance carriers. Being an agent of an insurance company inherently causes a conflict of interest. As an agent, Jon Sanchez represents the insurance company, which precludes Jon Sanchez from being a fiduciary to you in that transaction. It is important when selecting between available commission-based products or advisory based products to ask how Jon Sanchez will be compensated for that insurance product/transaction. When acting as an IAR Jon Sanchez has an inherent fiduciary obligation to serve your best interest. Please note that you are under no obligation to purchase insurance products through Jon Sanchez. If you elect to purchase insurance through Jon Sanchez, at or before the time of the transaction, disclosures are made regarding the nature of the relationship, services offered, and compensation received. Jason Gaunt is licensed as an insurance agent and offers fixed and variable life insurance products for commission- based compensation. As an agent Jason Gaunt also receives other compensation such as - fixed or variable life renewals from insurance carriers. Being an agent of an insurance company inherently causes a conflict of interest. As an agent, Jason Page | 17  Gaunt represents the insurance company, which precludes Jason Gaunt from being a fiduciary to you in that transaction. It is important when selecting between available commission-based products or advisory based products to ask how Jason Gaunt will be compensated for that insurance product/transaction. When acting as an IAR Jason Gaunt has an inherent fiduciary obligation to serve your best interest. Please note that you are under no obligation to purchase insurance products through Jason Gaunt. If you elect to purchase insurance through Jason Gaunt, at or before the time of the transaction, disclosures are made regarding the nature of the relationship, services offered, and compensation received. SGCM maintains relationships with various third-party money managers to whom we may refer clients. These relationships are based on our assessment of the managers' investment capabilities, client service, and operational standards. As disclosed in Item 5, we receive compensation from third-party money managers when we refer clients to them. This compensation is paid from the fees you pay to the third-party manager and does not result in additional charges to you. To mitigate the conflict of interest created by our compensation arrangements with third- party money managers, we have established objective selection criteria that prioritize client interests over compensation levels. Our evaluation process focuses primarily on each manager's investment philosophy and track record, risk management capabilities, operational infrastructure, and client service quality. We maintain standardized due diligence procedures that assess managers based on these investment merits rather than the compensation they provide to us. While compensation arrangements may vary among managers, we do not allow these differences to influence our recommendations, and we regularly review our selection process to ensure it remains focused on identifying managers who are most suitable for our clients' investment objectives and risk profiles. Jason Gaunt and Jon Sanchez are owners of both Sanchez Gaunt Capital Management, LLC and Estate Planning Network of America, LLC. Estate Planning Network of America, LLC offers estate planning services—including living trusts, powers of attorney, and medical directives—that may be recommended to Clients of Sanchez Gaunt Capital Management, LLC. This common ownership creates a conflict of interest, as Mr. Gaunt and Mr. Sanchez have a financial incentive to recommend estate planning services through their related entity rather than an unaffiliated provider. Clients should be aware of this conflict when evaluating any such recommendation. Clients are under no obligation to use Estate Planning Network of America, LLC for estate planning services and are free to engage any provider of their choice. Page | 18  Item 11: Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Code of Ethics SGCM maintains a Code of Ethics requiring high ethical standards of business conduct from all employees, including compliance with applicable securities laws. The Code establishes our fiduciary duty to clients and requires reporting of personal securities transactions and holdings by access persons. It prohibits the use of material non-public information and includes provisions for oversight, enforcement, and recordkeeping. A copy of our Code of Ethics is available upon request via email at jason@sanchezgaunt.com or by phone at 775-800-1801. Participation or Interest in Client Transactions The Adviser does not recommend to client’s, securities in which we have a material financial interest. We do not act as principal in transactions with clients, nor do we engage in agency cross transactions. We do not invest client funds in securities for which we act as underwriter, market maker, or have any other sales interest. We fully disclose all material facts concerning any potential conflicts of interest that could reasonably be expected to impair our rendering of unbiased advice. Clients always maintain the unrestricted right to decline any investment recommendation. Personal Trading Client interests must always take precedence over personal interests Associates may not trade based on information unavailable to the public Prior approval is required for IPO or private placement investments We maintain and monitor records of reportable securities holdings and transactions Our firm and associated persons may buy or sell securities identical to those recommended to  clients. To address potential conflicts, we have established the following policies:      We prohibit "front-running" client trades (trading ahead of clients) Personal trades may be aggregated with client trades where appropriate We review all personal trading activity regularly to ensure compliance. Violations may result in disciplinary action up to termination. Violations of these policies may result in disciplinary action up to termination. We review all personal trading activity regularly to ensure compliance with our procedures. Page | 19  Item 12: Brokerage Practices SGCM assists the client in selecting the risk/return objective and Portfolio Strategists that best suit the client’s objectives. The client then specifically directs the account to be invested in accordance with the chosen investment solution. When the client selects the investment solutions, the client further directs that the account be automatically adjusted to reflect any adjustment in the asset allocation by the selected Portfolio Strategist. This client authorization results in the purchase and sale of certain mutual funds, stocks, bonds, ETFs or other securities without further authorization by the client or any other party at such time as the Portfolio Strategist changes the composition of the selected model asset allocation. The client receives confirmation of all transactions in the account and is free to terminate participation in the Platform and retain or dispose of any assets in the account at any time. SGCM has no authority to cause any purchase or sale of securities in any client account or change the selected model asset allocation or to direct the account to be invested in any manner other than as previously authorized by the client. However, the client may place reasonable restrictions in the account. If a client selects an IMA investment solution, the third-party Discretionary Managers are granted the authority to manage the accounts on a discretionary basis, including the authority to buy, sell, select, and remove securities and other investments for the account, and to select broker-dealers or others through which transactions will be effected. Research and Other Soft Dollar Benefits SGCM does not have any soft-dollar arrangements and does not receive any soft-dollar Economic Benefits benefits. SGCM has access to research products and services from account custodians and/or other Registered Investment Advisers. These products may include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Such research products and services are generally provided to all Registered Investment Advisers that maintain a relationship with such third parties and are not considered to be paid for with soft dollars. Brokerage for Client Referrals We do not receive client referrals from broker-dealers in exchange for cash or other compensation, such as brokerage services or research. Page | 20  Trade Aggregation SGCM may buy or sell the same security for two or more Clients (including the firm’s personal accounts) when concurrent orders are placed to be executed together as a single “block” in order to facilitate orderly and efficient execution. Each Client account will be charged or credited with the average price per unit. SGCM receives no additional compensation or remuneration of any kind because we aggregate Client transactions, and no Client is favored over any other Client. The aggregation should, on average, slightly reduce the costs of execution. We will not aggregate a Client’s order if, in a particular instance, we believe that aggregation would cause the Client’s cost of execution to be increased. SGCM and/or its Associated Persons may participate in block trades with Clients and may also participate on a pro-rata basis for partial fills, but only after the determination has been made that Clients will receive fair and equitable treatment. Item 13: Review of Accounts SGCM conducts regular and systematic reviews of client accounts. Investment advisory accounts are reviewed on a scheduled basis, with different levels of review performed by appropriate personnel. Our investment management accounts undergo daily monitoring of market conditions and security-specific events by our investment team. Portfolio allocations are formally reviewed at least annually to ensure alignment with client objectives and investment policies. Each client is assigned a primary Investment Adviser Representative (IAR) who is responsible for overseeing their accounts. The primary IAR conducts comprehensive account reviews at least annually and more frequently when market conditions dictate or when changes in a client's financial situation occur. Reviews examine key factors including but not limited to asset allocation, investment performance relative to benchmarks, risk exposures, progress toward financial goals, and any significant changes in the client's financial situation or objectives. 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). Item 14: Client Referrals and Other Compensation Economic Benefits Provided by Third Parties for Advice Rendered to Clients We receive compensation from third-party money managers when we refer clients to their Page | 21  services. This compensation is typically a percentage of the advisory fee you pay to the third-party manager and is paid directly by the manager to us. The compensation we receive does not increase the total fees you pay. You pay the same fee to the third-party manager whether or not we receive compensation from them. With respect to the AssetMark Platform, SGCM may, subject to negotiation with AssetMark, receive certain allowances, reimbursements or services from AssetMark in connection with SGCM’s investment advisory services to its clients, as described below and in further detail in the Appendix 1 of the AssetMark Platform or Referral Disclosure Brochure. Compensation to Non-Advisory Personnel for Client Referrals SGCM does not compensate any individual or entity for client referrals. We may receive referrals from current clients, attorneys, accountants, friends, and other similar sources, but we do not directly or indirectly compensate referring parties for these referrals. If our compensation arrangements change in the future to include payments for client referrals, we will disclose this practice to our clients and comply with all applicable regulations, including disclosure of the referral arrangement to clients and ensuring that clients are provided with appropriate disclosure forms prior to entering into an advisory agreement. Item 15: Custody We do not take custody of client funds or securities. Clients will receive account statements directly from the broker-dealer, bank, or other qualified custodian holding their assets. Clients should carefully review those statements promptly. With regard to the AssetMark Platform, SGCM does not provide custodial services to its clients. Client assets are held with banks, financial institutions or registered broker-dealers that are “qualified custodians.” Clients will receive statements directly from the qualified custodians at least quarterly. We urge clients to carefully review those statements and compare the custodial statements to the reports that we provide them. The information in our reports may vary from custodial statements based on accounting procedures, reporting dates or valuation methodologies of certain securities. • The AssetMark Platform provides access to the following Platform Custodians: • AssetMark Trust, an Arizona trust company and affiliate of AssetMark, 3200 North Central Avenue, Seventh Floor, Phoenix, Arizona 85012. Its mailing address is P.O. Box 80007, Phoenix, Arizona 85060. Charles Schwab & Co., Inc. (“Schwab”). 7801 Mesquite Bend Drive, Ste. 112, Irving, TX Page | 22  • • 75063 Fidelity Brokerage Services, LLC (“Fidelity”). 200 Seaport Boulevard, Boston, MA 02210. Pershing Advisor Solutions (“PAS”). One Pershing Plaza, Jersey City, NJ 07399. Item 16: Investment Discretion SGCM provides investment management services on a discretionary basis only. This means that our firm has the authority to determine, without obtaining specific client consent for each transaction, the securities to be bought or sold and the amount of securities to be bought or sold. Prior to assuming discretionary authority over any client account, SGCM requires clients to execute an Advisory Agreement which includes a limited power of attorney granting our firm discretionary authority over the client's account. The Advisory Agreement outlines the scope of our discretionary authority, which includes selecting investments in accordance with the client's stated investment objectives, risk tolerance, and other factors as documented in their Investment Policy Statement. While SGCM maintains full discretionary authority over client accounts, clients may impose reasonable restrictions on the management of their accounts. These restrictions may include prohibitions on the purchase of specific securities or types of securities (such as specific companies, industries, or asset classes) or requirements to maintain specific securities within the portfolio. Any such restrictions must be provided to the Adviser in writing and will be documented in the client's Investment Policy Statement. Item 17: Voting Client Securities SGCM does not accept authority to vote client securities. Clients will receive their proxies or other solicitations directly from the custodian. Item 18: Financial Information We do not require prepayment of fees of more than $1,200 per client, six months or more in advance. Therefore, we are not required to include a balance sheet with this brochure. Page | 23