Sawyer Capital Management

Item 1 – Cover Page [Adviser’s Logo] Sawyer Capital Management, Inc. 17821 Suzanne Ridge Drive Wildwood, MO 63038 314-401-8604 www.sawcap.com June 18, 2026 . The information in this This Brochure provides information about the qualifications and business practices of Sawyer Capital Management, Inc. [“SCM or the Firm”]. If you have any questions about the contents of this Brochure, please contact us at 314-401-8604 Brochure has not been approved or verified by the United States Securities and Exchange Commission or by any state securities authority. SCM is a registered investment adviser. Registration of an Investment Adviser does not imply any level of skill or training. The oral and written communications of an Adviser provide you with information about which you determine to hire or retain an Adviser. Additional information about SCM also is available on the SEC’s website at www.adviserinfo.sec.gov. You can search this site by a unique identifying number, known as a CRD number. The CRD number for SCM is 161054. i  Item 2 – Material Changes This Item of the Brochure will discuss only specific material changes that are made to the Brochure since the last annual update and provide clients with a summary of such changes. Our current Brochure has been updated as follows: • We have removed Item 19-Requirements for State-Registered Advisers as Sawyer Capital Management, Inc. is transitioning to registration with the Securities and Exchange Commission. (Brochure Date: 06/18/2026) (Date of Most Recent Annual Updating Amendment: 03/24/2026) We will further provide you with a new Brochure as necessary based on changes or new information, at any time, without charge. Currently, our Brochure may be requested by contacting Curtis C. Sawyer, President and Chief Compliance Officer at 314-401-8604. 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 ........................................................................................................................... 1 Item 5 – Fees and Compensation ................................................................................................................. 3 Item 6 – Performance-Based Fees and Side-By-Side Management ............................................................. 5 Item 7 – Types of Clients ............................................................................................................................... 5 Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................ 5 Item 9 – Disciplinary Information ................................................................................................................. 7 Item 10 – Other Financial Industry Activities and Affiliations ...................................................................... 8 Item 11 – Code of Ethics , Participation in Client Transactions and Personal Trading ................................. 8 Item 12 – Brokerage Practices ...................................................................................................................... 9 Item 13 – Review of Accounts..................................................................................................................... 11 Item 14 – Client Referrals and Other Compensation .................................................................................. 12 Item 15 – Custody ....................................................................................................................................... 13 Item 16 – Investment Discretion ................................................................................................................ 13 Item 17 – Voting Client Securities ............................................................................................................... 13 Item 18 – Financial Information .................................................................................................................. 14 Brochure Supplement(s) (provided to clients) iii  Item 4 – Advisory Business SCM is owned by Curtis C. Sawyer and has been providing investment advisory services since February 2012. As of December 31, 2025, SCM managed $124,876,998 on a discretionary basis. Investment Management Services: SCM manages investment portfolios for individuals (including high net worth individuals), qualified retirement plans, trusts, charitable organizations and small businesses. SCM will work with a client to determine the client's investment objectives and investor risk profile and will design a written investment policy statement. Investment and portfolio allocation software may be used to evaluate alternative portfolio designs. SCM evaluates the client's existing investments with respect to the client's investment policy statement. The Firm works with new clients to develop a plan to transition from the client's existing portfolio to the desired portfolio. SCM will then continuously monitor the client's portfolio holdings and the overall asset allocation strategy and hold regular progress meetings with the client regarding their account and other wealth management issues, as necessary. SCM will typically create a portfolio of no-load mutual funds and may use model portfolios if the models match the client's investment policy. SCM will allocate the client's assets among various investments taking into consideration the overall management style selected by the client. The Firm primarily recommends portfolios consisting of no-load mutual funds offered by Dimensional Fund Advisors ("DFA"). DFA sponsored mutual funds follow a passive asset class investment philosophy with low holdings turnover. SCM may also utilize other passively managed mutual funds or exchange traded funds, including funds offered by Vanguard and Bridgeway. Client portfolios may also include some individual equity securities in situations where disposition of these securities would present an overriding tax implication, or the client specifically requests they be retained for a personal reason. These situations will be specifically identified in the client’s Investment Policy Statement (IPS). SCM manages mutual fund and equity portfolios on a discretionary basis according to the investment policy selected by the client. A client may impose any reasonable restrictions on SCM’s discretionary authority, including restrictions on the types of securities in which SCM may invest client’s assets and on specific securities, which the client may believe to be appropriate. 1  On an ongoing basis, SCM will answer clients' inquiries regarding their accounts and review periodically with clients the performance of their accounts. The Firm will periodically review each client's investment policy, risk profile, and discuss the re- balancing of each client's accounts to the extent appropriate. In addition to managing the client’s investment portfolio, SCM may consult with clients on various financial areas including income and estate tax planning, business sale structures, college financial planning, retirement planning, insurance analysis, personal cash flow analysis, establishment and design of retirement plans and trust designs, among other things. Employee Benefit Retirement Plan Services: SCM also provides advisory services to participant-directed retirement plans through third party administration services, which are online bundled service providers offering an opportunity for plan sponsors to provide their participants with daily account access, valuation, and investment education. SCM will analyze the plan's current investment platform and assist the plan in creating an investment policy statement defining the types of investments to be offered and the restrictions that may be imposed. SCM will recommend investment options to achieve the plan's objectives, provide participant education meetings, and monitor the performance of the plan's investment vehicles. SCM will recommend changes in the plan's investment vehicles as may be appropriate from time to time. SCM generally will review the plan's investment vehicles and investment policy, as necessary. For certain retirement plans, SCM also works in coordination and support with Focus Partners Advisor Solutions (f.k.a. Buckingham Strategic Partners). Retirement plan clients will engage both SCM and Focus Partners Advisor Solutions. Focus Partners Advisor Solutions will provide to the client additional discretionary investment management services and will exercise discretionary authority to select the plan investments made available to the plans’ participants by selecting and maintaining the plans’ investments according to the goals and investment objectives of the plan. SCM will continue to work with plans to monitor plan investments, provide fiduciary plan advice including regular considerations of the goals and objectives of the plan, and provide participant education services to the plan. 2  Item 5 – Fees and Compensation In certain circumstances, all fees, account minimums and their applications to family or other circumstances may be negotiable. SCM requires a minimum account size of $250,000 for Investment Management Services. Individual accounts for immediate family members (such as husband, wife and dependent children) are aggregated, and the fee is charged based on the total value of all family members’ accounts. SCM has contracted with Focus Partners Advisor Solutions for services including trade processing, collection of management fees, record maintenance, report preparation, marketing assistance, and research. SCM pays a fee for Focus Partners Advisor Solutions services based on management fees paid to the Firm on accounts which use Focus Partners Advisor Solutions. The fee paid by SCM to Focus Partners Advisor Solutions consists of a portion of the fee paid by clients to SCM and varies based on the total client assets participating in Focus Partners Advisor Solutions through SCM. These fees are not separately charged to advisory clients. The fee charged by SCM to its clients includes all sub-advisory fees charged by Focus Partners Advisor Solutions. The specific manner in which fees are charged by SCM is established in a client’s written agreement with the Firm. Generally, clients will be invoiced in arrears at the beginning of each calendar quarter based upon the value (market value or fair market value in the absence of market value; client account balances on which SCM calculates fees may vary from account custodial statements based on independent asset valuations and other accounting variances, including mechanisms for including accrued interest in account statements) of the client's account at the end of the previous quarter. New accounts are charged a prorated fee for the remainder of the quarter in which the account is incepted. SCM charges fees in arrears; no fee refund policy is necessary. The fee schedule may be amended from time-to-time by SCM upon at least forty-five (45) days advance written notice to clients. For Investment Management and Employee Benefit Plan clients, SCM will request authority from the client to receive quarterly payments directly from the client's account held by an independent custodian. Clients may provide written limited authorization to SCM or its designated service provider, Focus Partners Advisor Solutions, to withdraw fees from the account. Clients will receive custodial statements showing the advisory fees debited from their account(s). Certain third-party administrators will calculate and debit SCM’s fee and remit such fee to the Firm. 3  A client agreement may be canceled at any time, by either party, for any reason upon receipt of 30 days written notice. Upon termination of any account at any time after the required 30-day notice, any prepaid, unearned fees will be promptly refunded. SCM’s fees are exclusive of brokerage commissions, transaction fees, and other related costs and expenses which shall be incurred by the client. Clients may incur certain charges imposed by custodians, brokers, third party investments and other third parties such as fees charged by managers, custodial fees, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees, and other fees and taxes on brokerage accounts and securities transactions. Mutual funds and exchange traded funds also charge internal management fees, which are disclosed in a fund’s prospectus. Mutual funds and exchange traded funds (ETFs) also charge internal management fees, which are disclosed in a fund’s prospectus. These fees will generally include a management fee and other fund expenses. All fees paid to SCM for investment advisory services are separate and distinct from the fees and expenses charged by mutual funds and ETFs to their shareholders. The services provided by SCM are designed, among other things, to assist the client in determining which mutual fund, ETF or funds are most appropriate to each client's financial condition and objectives. Accordingly, the client should review both the fees charged by the funds and the fees charged by SCM to fully understand the total amount of fees to be paid by the client and to thereby evaluate the advisory services being provided. Such charges, fees and commissions are exclusive of and in addition to SCM’s fee, and the Firm shall not receive any portion of these commissions, fees and costs. Advisory Fees Investment Management Services: The annual fee for Investment Management Services will be charged as a percentage of assets under management, according to the schedule below: Assets Under Management Annual Fee (%) On the first $500,000 On the next $500,000 On the next $1 million On the next $1 million On the next $2 million On all amounts thereafter 0.95% 0.85% 0.70% 0.50% 0.40% 0.35% 4  Employee Benefit Retirement Plan Services: The annual fee for plan services will be charged as a percentage of assets within the plan. SCM Annual Fee Total Fee Assets Under Management Focus Partners Advisor Solutions Annual Fee 0.20% 0.15% 0.08% 0.05% 0.70% 0.45% 0.25% 0.15% 0.90% 0.60% 0.33% 0.20% On the first $1,000,000 On the next $4,000,000 On the next $5,000,000 On all amounts above $10,000,000 Item 6 – Performance-Based Fees and Side-By-Side Management SCM does not charge any performance-based fees (fees based on a share of capital gains on or capital appreciation of the assets of a client). All fees are calculated as described above 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. Item 7 – Types of Clients SCM offers services to individuals (including high net worth individuals), pension and profit-sharing plans, qualified retirement plans, trust, estates or charitable organizations or business entities. SCM requires a minimum account size of $250,000 for Investment Management Services. Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss Methods of Analysis and Investment Strategy SCM's services are based on long-term investment strategies incorporating the principles of Modern Portfolio Theory. SCM's investment approach is firmly rooted in the belief that markets are "efficient" over periods of time and that investors' long-term returns are determined principally by asset allocation decisions, rather than market timing or stock picking. SCM recommends diversified portfolios, principally through the use of passively 5  managed, asset class mutual funds. The Firm selects or recommends to clients portfolios of securities, principally broadly-traded open end mutual funds to implement this investment strategy. Although all investments involve risk, SCM's investment advice seeks to limit risk through broad diversification among asset classes. SCM's investment philosophy is designed for investors who desire a buy and hold strategy. The frequent trading of securities increases brokerage and other transaction costs that the Firm's strategy seeks to minimize. In the implementation of investment plans, SCM therefore primarily uses mutual funds. SCM may also utilize Exchange Traded Funds (ETFs) to represent a market sector. Clients may hold or retain other types of assets as well, and the Firm may offer advice regarding those various assets as part of its services. Advice regarding such assets will generally not involve asset management services but may help to more generally assist the client. SCM's strategies do not utilize securities that we believe would be classified as having any unusual risks, and we do not recommend frequent trading, which can increase brokerage and other costs and taxes. SCM receives supporting research from Focus Partners Advisor Solutions and from other consultants, including economists affiliated with Dimensional Fund Advisors (“DFA”). The Firm utilizes DFA mutual funds in client portfolios. DFA mutual funds follow a passive asset class investment philosophy with low holdings turnover. DFA provides historical market analysis, risk/return analysis, and continuing education to SCM. Analysis of a Client’s Financial Situation In the development of investment plans for clients, including the recommendation of an appropriate asset allocation, SCM relies on an analysis of the client’s financial objectives, current and estimated future resources, and tolerance for risk. To derive a recommended asset allocation, SCM may use a Monte Carlo simulation, a standard statistical approach for dealing with uncertainty. As with any other methods used to make projections into the future, there are several risks associated with this method, which may result in the client not being able to achieve their financial goals. They include: • • • 6 The risk that expected future cash flows will not match those used in the analysis The risk that future rates of return will fall short of the estimates used in the simulation The risk that inflation will exceed the estimates used in the simulation  • For taxable clients, the risk that tax rates will be higher than was assumed in the analysis Risk of Loss Investing in securities involves risk of loss that clients should be prepared to bear. All investments present the risk of loss of principal – the risk that the value of securities (mutual funds, ETFs and individual bonds), when sold or otherwise disposed of, may be less than the price paid for the securities. Even when the value of the securities when sold is greater than the price paid, there is the risk that the appreciation will be less than inflation. In other words, the purchasing power of the proceeds may be less than the purchasing power of the original investment. The mutual funds and ETFs utilized by SCM may include funds invested in domestic and international equities, including real estate investment trusts (REITs). Equity securities may include large capitalization, medium capitalization and small capitalization stocks. Mutual funds and ETF shares invested in fixed income securities are subject to the same interest rate, inflation and credit risks associated with the underlying bond holdings. Among the riskiest mutual funds used in SCM’s investment strategies are the U.S. and International small capitalization and small capitalization value funds, emerging markets funds, and commodity futures funds. Certain funds utilized by SCM may contain international securities. Investing outside the United States involves additional risks, such as currency fluctuations, periods of illiquidity and price volatility. These risks may be greater with investments in developing countries. More information about the risks of any particular market sector can be reviewed in representative prospectuses for funds managing assets within each applicable sector. Item 9 – Disciplinary Information Registered investment advisers are required to disclose all material facts regarding any legal or disciplinary events that would be material to your evaluation of SCM or the integrity of SCM’s management. The Firm has no information applicable to this Item. 7  Item 10 – Other Financial Industry Activities and Affiliations Focus Partners Advisor Solutions The Firm contracts with Focus Partners Advisor Solutions for back-office services and assistance with portfolio modeling and believes that Focus Partners Advisor Solutions effectively provides the back-office services that assist with its overall investment advisory practice. The management of SCM continuously makes this assessment. As a fiduciary, SCM has certain legal obligations, including the obligation to act in clients’ best interest. SCM maintains a Business Continuity and Succession Plan and seeks to avoid a disruption of service to clients in the event of an unforeseen loss of key personnel, due to disability or death. To that end, SCM has entered into a succession agreement with Focus Financial Partners, LLC effective June 30, 2024. SCM can provide additional information to any current or prospective client upon request to Curtis Sawyer, at 314-401-8604 or curt@sawcap.com. Item 11 – Code of Ethics , Participation in Client Transactions and Personal Trading SCM has adopted a Code of Ethics for all supervised persons of the firm describing its high standard of business conduct, and fiduciary duty to its clients. The Code of Ethics includes provisions relating to the confidentiality of client information, a prohibition on insider trading, restrictions on the acceptance of significant gifts and the reporting of certain gifts and business entertainment items, and personal securities trading procedures, among other things. All supervised persons at SCM must acknowledge the terms of the Code of Ethics annually, or as amended. SCM or individuals associated with SCM may buy or sell securities identical to those recommended to customers for their personal accounts. In addition, any related person(s) may have an interest or position in a certain security(ies) which may also be recommended to a client. It is the expressed policy of SCM that no person employed by SCM will take inappropriate advantage of their positions, and the interests of client accounts will be placed first at all times. SCM anticipates that, in appropriate circumstances, consistent with clients’ investment objectives, it will cause accounts over which SCM has management authority to effect and will recommend to investment advisory clients or prospective clients, the purchase or sale of securities in which SCM, its affiliates and/or clients, directly or indirectly, have a position of interest. SCM’s employees and persons associated with SCM are required to follow SCM’s 8  Code of Ethics. Subject to satisfying this policy and applicable laws, officers, directors and employees of SCM and its affiliates may trade for their own accounts in securities which are recommended to and/or purchased for SCM’s clients. The Code of Ethics is designed to assure that the personal securities transactions, activities and interests of the employees of SCM will not interfere with (i) making decisions in the best interest of advisory clients and (ii) implementing such decisions while, at the same time, allowing employees to invest for their own accounts. Under the Code, certain classes of securities have been designated as exempt transactions, based upon a determination that these would materially not interfere with the best interest of SCM’s clients. In addition, the Code requires pre-clearance of certain transactions. Nonetheless, because the Code of Ethics in some circumstances would permit employees to invest in the same securities as clients, there is a possibility that employees might benefit from market activity by a client in a security held by an employee. Employee trading is continually monitored under the Code of Ethics, and to reasonably prevent conflicts of interest between SCM and its clients. It is SCM’s policy that the firm will not affect any principal or agency cross securities transactions for client accounts. SCM will also not cross trades between client accounts. Principal transactions are generally defined as transactions where an advisor, acting as principal for its own account or the account of an affiliated broker-dealer, buys from or sells any security to any advisory client. A principal transaction may also be deemed to have occurred if a security is crossed between an affiliated private fund and another client account. An agency cross transaction is defined as a transaction where a person acts as an investment advisor in relation to a transaction in which the investment advisor, or any person controlled by or under common control with the investment advisor, acts as broker for both the advisory client and for another person on the other side of the transaction. Agency cross transactions may arise where an advisor is dually registered as a broker- dealer or has an affiliated broker-dealer. SCM will provide a complete copy of its Code of Ethics to any client or prospective client upon request. Item 12 – Brokerage Practices SCM arranges for the execution of securities transactions with the assistance of Focus Partners Advisor Solutions. Through Focus Partners Advisor Solutions, SCM participates in the Schwab Advisor Services (SAS) program offered to independent investment advisers by Charles Schwab & Company, Inc. (“Schwab”). Schwab is an unaffiliated SEC-registered broker dealer and FINRA member broker dealer. Schwab offers to independent investment 9  advisers services, which include custody of securities, trade execution, clearance and settlement of transactions. The Schwab brokerage program will generally be recommended to advisory clients for the execution of mutual fund and equity securities transactions. SCM regularly reviews this program to ensure that its recommendations are consistent with its fiduciary duty. The trading platform is essential to SCM’s service arrangements and capabilities, and the Firm may not accept clients who direct the use of other brokers. As part of this program, SCM receives benefits that it would not receive if it did not offer investment advice (See the disclosure under Item 14 of this Brochure). As SCM will not request the discretionary authority to determine the broker dealer to be used or the commission rates to be paid in these situations, clients must direct SCM as to the broker dealer to be used. In directing the use of a particular broker or dealer, it should be understood that the Firm will not have authority to negotiate commissions among various brokers or obtain volume discounts, and best execution may not be achieved. Not all investment advisers require clients to direct the use of specific brokers. Schwab does not generally charge clients a custody fee and is compensated by account holders through commissions or other transaction related fees for securities trades that are executed through the broker or that settle into the clients’ accounts at the broker. Trading client accounts through other brokers may result in fees (including mark-ups and mark- downs) being charged by the custodial broker or a custodian and an additional broker. SCM does not have a formal soft dollar contractual agreement with any brokerage firm and does not use client commissions to purchase research and brokerage. However, SCM does receive access to trading platforms and research materials as part of its participation in the above referenced platform at no cost to the firm. SCM generally does not aggregate any client transactions in mutual funds or other securities. Client accounts are individually reviewed and managed, and transaction costs are not saved by aggregating orders in almost all circumstances in which SCM arranges transactions. SCM does not have any arrangements to compensate any broker dealer for client referrals. When trading client accounts, errors may periodically occur. SCM does not maintain any client trade error gains. The Firm makes client whole with respect to any trade error losses incurred by client and caused by SCM. 10  Employee Benefit Plan Services: SCM does not arrange for the execution of securities transactions for participant directed plans utilizing Employee Benefit Retirement Plan Services. Transactions are executed directly through employee plan participation. Item 13 – Review of Accounts Reviews: Investment Management Services: Account assets are supervised continuously and generally formally reviewed quarterly by Curtis C. Sawyer of SCM. The review process contains each of the following elements: a. b. c. d. assessing client goals and objectives; evaluating the employed strategy(ies); monitoring the portfolio(s); and addressing the need to rebalance. Additional account reviews may be triggered by any of the following events: a. b. c. d. a specific client request; a change in client goals and objectives; an imbalance in a portfolio asset allocation; and market/economic conditions. Employee Benefit Retirement Plan Services: Retirement plan assets are reviewed no more than quarterly, and according to the standards and situations described above for investment management accounts. Reports: Investment Management Services and Employee Benefit Plan Services: All clients will receive quarterly performance reports, prepared by Focus Partners Advisor Solutions and reviewed by SCM. These quarterly reports summarize the client's account, asset allocation, portfolio performance, current positions, and current market value. Clients will also receive statements from account custodians. 11  Plan sponsors are provided with quarterly information and annual performance reviews from SCM. In addition, plan participant education information may also be provided to the Plan Sponsor or Administrator for distribution to the participants of the plan. Item 14 – Client Referrals and Other Compensation Other Compensation As indicated under the disclosure for Item 12, Schwab provides SCM with access to services which are not available to retail investors. These services generally are available to independent investment advisors on an unsolicited basis at no charge to them. products These services benefit SCM but may not benefit its clients' accounts. Many of the and services assist the Firm in managing and administering clients’ accounts. These include software and other technology 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), provide research, pricing information and other market data, facilitate payment of SCM's fees from its clients accounts, and assist with back-office functions, recordkeeping and client reporting. Many of these services generally may be used to service all or a substantial number of SCM's accounts. Recommended brokers also make available to SCM other services intended to help the Firm manage and further develop its business enterprise. These services may include consulting, publications and conferences on practice management, information technology, business succession, regulatory compliance, and marketing. SCM does not, however, enter into any commitments with the brokers for transaction levels in exchange for any services or products from the brokers. While as a fiduciary, SCM endeavors to act in its clients best interests, the Firm's requirement that clients maintain their assets in accounts at Schwab may be based in part on the benefit to SCM of the availability of some of the foregoing products and services and not solely on the nature, cost or quality of custody and brokerage services provided by the brokers, which may create a potential conflict of interest. SCM also receives software from DFA, which the Firm utilizes in forming assets allocation strategies and producing performance reports. DFA also provides continuing education for SCM personnel. These services are designed to assist the Firm plan and design its services for business growth. 12  Item 15 – Custody Investment Management and Employee Benefit Plan Clients should receive at least quarterly statements from the broker dealer, bank or other qualified custodian that holds and maintains client’s investment assets. SCM urges you to carefully review such statements and compare such official custodial records to the account statements that we may provide to you. Our statements may vary from custodial statements based on accounting procedures, reporting dates, or valuation methodologies of certain securities. Item 16 – Investment Discretion SCM requests that it be provided with written authority to determine which securities and the amounts of securities that are bought or sold. Any limitations on this discretionary authority shall be included in this written authority statement. Clients may change/amend these limitations as required. Such amendments shall be submitted in writing. When selecting securities and determining amounts, SCM observes the investment policies, limitations and restrictions of the clients for which it advises. Investment guidelines and restrictions must be provided to SCM in writing. Item 17 – Voting Client Securities Proxy Voting: As a matter of firm policy and practice, SCM does not generally have any authority to and does not vote proxies on behalf of advisory clients. The firm may offer assistance as to proxy matters upon a client’s request, but the client always retains the proxy voting responsibility. In very limited circumstances, SCM will vote proxies for accounts. In these limited circumstances, SCM is provided with the discretionary authority to vote the proxies on behalf of clients. When SCM votes client proxies, they will vote those proxies in the best interests of clients and in accordance with their established policies and procedures. Clients may request, in writing, information on how proxies for his/her shares were voted. Class Actions, Bankruptcies and Other Legal Proceedings: Clients should note that SCM will neither advise nor act on behalf of the client in legal proceedings involving companies whose securities are held or were previously held in the client’s account(s), including, but not limited to, the filing of “Proofs of Claim” in class action settlements. If desired, clients may direct SCM to transmit copies of class action notices to the client or a third party. 13  Upon such direction, the Firm will make commercially reasonable efforts to forward such notices in a timely manner. Item 18 – Financial Information Registered investment advisers are required in this Item to provide you with certain financial information or disclosures about SCM’s financial condition. The Firm has no financial commitment that impairs its ability to meet contractual and fiduciary commitments to clients and has not been the subject of a bankruptcy proceeding. 14