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Sequentis Capital LLC
Form ADV Part 2A – Disclosure Brochure
Effective: April 24, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business
practices of Sequentis Capital LLC (“Sequentis” or the “Advisor”). If you have any questions about the content of
this Disclosure Brochure, please contact the Advisor at (617) 419-7133 or by email at admin@sequentis-
capital.com.
Sequentis is a registered investment advisor with the U.S. Securities and Exchange Commission (“SEC”). The
information in this Disclosure Brochure has not been approved or verified by the SEC or by any state securities
authority. Registration of an investment advisor does not imply any specific level of skill or training. This
Disclosure Brochure provides information through Sequentis to assist you in determining whether to retain the
Advisor.
Additional information about Sequentis and its Advisory Persons are available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 298533.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http://www.sequentis-capital.com/
Item 2 – Material Changes
Form ADV 2 is divided into two parts: Part 2A (the "Disclosure Brochure") and Part 2B (the "Brochure
Supplement"). The Disclosure Brochure provides information about a variety of topics relating to an Advisor’s
business practices and conflicts of interest. The Brochure Supplement provides information about the Advisory
Persons of Sequentis. For convenience, the Advisor has combined these documents into a single disclosure
document.
Sequentis believes that communication and transparency are the foundation of its relationship with clients and
will continually strive to provide you with complete and accurate information at all times. Sequentis encourages
all current and prospective clients to read this Disclosure Brochure and discuss any questions you may have with
the Advisor.
Material Changes
The following material changes have been made to this Disclosure Brochure since the last annual amendment
filing on February 28, 2025:
• The Advisor is transitioning from a state registered advisor to an advisor registered with the U.S.
Securities and Exchange Commission (“SEC”).
Future Changes
From time to time, the Advisor may amend this Disclosure Brochure to reflect changes in business practices,
changes in regulations or routine annual updates as required by the securities regulators. This complete
Disclosure Brochure or a Summary of Material Changes shall be provided to you annually and if a material
change occurs.
At any time, you may view the current Disclosure Brochure on-line at the SEC’s Investment Adviser Public
Disclosure website at www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 298533. You
may also request a copy of this Disclosure Brochure at any time, by contacting the Advisor at (617) 419-7133 or
by email at admin@sequentis-capital.com.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
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 Services .................................................................................................................................... 4
A. Firm Information ............................................................................................................................................................. 4
B. Advisory Services Offered .............................................................................................................................................. 4
C. Client Account Management .......................................................................................................................................... 5
D. Wrap Fee Programs ....................................................................................................................................................... 6
E. Assets Under Management ............................................................................................................................................ 6
Item 5 – Fees and Compensation ......................................................................................................................... 6
A. Fees for Advisory Services ............................................................................................................................................. 6
B. Fee Billing ....................................................................................................................................................................... 7
C. Other Fees and Expenses .............................................................................................................................................. 7
D. Advance Payment of Fees and Termination .................................................................................................................. 7
E. Compensation for Sales of Securities ............................................................................................................................ 8
Item 6 – Performance-Based Fees and Side-By-Side Management .................................................................. 8
Item 7 – Types of Clients ....................................................................................................................................... 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss ........................................................... 9
A. Methods of Analysis ....................................................................................................................................................... 9
B. Risk of Loss .................................................................................................................................................................... 9
Item 9 – Disciplinary Information ........................................................................................................................ 11
Item 10 – Other Financial Industry Activities and Affiliations ......................................................................... 11
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 11
A. Code of Ethics .............................................................................................................................................................. 11
B. Personal Trading with Material Interest ........................................................................................................................ 11
C. Personal Trading in Same Securities as Clients .......................................................................................................... 12
D. Personal Trading at Same Time as Client .................................................................................................................... 12
Item 12 – Brokerage Practices ............................................................................................................................ 12
A. Recommendation of Custodian[s] ................................................................................................................................ 12
B. Aggregating and Allocating Trades .............................................................................................................................. 13
Item 13 – Review of Accounts ............................................................................................................................. 13
A. Frequency of Reviews .................................................................................................................................................. 13
B. Causes for Reviews ...................................................................................................................................................... 13
C. Review Reports ............................................................................................................................................................ 13
Item 14 – Client Referrals and Other Compensation ........................................................................................ 13
A. Compensation Received by Sequentis ......................................................................................................................... 13
B. Compensation for Client Referrals ............................................................................................................................... 14
Item 15 – Custody ................................................................................................................................................ 14
Item 16 – Investment Discretion ......................................................................................................................... 14
Item 17 – Voting Client Securities ...................................................................................................................... 15
Item 18 – Financial Information .......................................................................................................................... 15
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 16
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 18
Form ADV Part 2B – Brochure Supplement ...................................................................................................... 20
Privacy Policy ....................................................................................................................................................... 23
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 3
Item 4 – Advisory Services
A. Firm Information
Sequentis Capital LLC (“Sequentis” or the “Advisor”) is a registered investment advisor located with the U.S.
Securities and Exchange Commission (“SEC”). The Advisor is organized as a Limited Liability Company (LLC)
under the laws of Massachusetts. Sequentis was founded in July 2018, and is owned and operated by Ryan T.
Nagle (Principal and Chief Compliance Officer). This Disclosure Brochure provides information regarding the
qualifications, business practices, and the advisory services provided by Sequentis.
B. Advisory Services Offered
Sequentis offers investment advisory services to individuals and high net worth individuals (each referred to as a
“Client”).
The Advisor serves as a fiduciary to Clients, as defined under the applicable laws and regulations. As a fiduciary,
the Advisor upholds a duty of loyalty, fairness and good faith towards each Client and seeks to mitigate potential
conflicts of interest. Sequentis’ fiduciary commitment is further described in the Advisor’s Code of Ethics. For
more information regarding the Code of Ethics, please see Item 11 – Code of Ethics, Participation or Interest in
Client Transactions and Personal Trading.
Investment Management Services
Sequentis provides discretionary investment management and financial planning services to investment advisory
account Clients. Sequentis provides investment solutions that employ an asset allocation approach focused on
constructing portfolios designed to grow and protect wealth through the changing market environment. Sequentis
provides security selection, portfolio management, and asset allocation advice to its clients. The Advisor uses
risk measures to identify when the market is changing, and have the ability to adjust portfolio exposures to
accommodate for these changes. Sequentis’ investment advice may utilize U.S. equities, global equities, large
and small capitalization issues, emerging market equities and commodities, exchange traded funds (“ETFs”),
global real estate, global fixed income, commodities, options, mutual funds, cash, bonds and cash equivalent
investments. The Advisor may retain other types of investments from the Client’s legacy portfolio due to fit with
the overall portfolio strategy, tax-related reasons, or other reasons as identified between the Advisor and the
Client.
Sequentis’ investment strategies are primarily long-term focused, but the Advisor may buy, sell or re-allocate
positions that have been held for less than one year to meet the objectives of the Client or due to market
conditions. Sequentis will construct, implement and monitor the portfolio to ensure it meets the goals, objectives,
circumstances, and risk tolerance agreed to by the Client. Each Client will have the opportunity to place
reasonable restrictions on the types of investments to be held in their respective portfolio, subject to acceptance
by the Advisor.
At no time will Sequentis accept or maintain custody of a Client’s funds or securities, except for the limited
authority as outlined in Item 15 – Custody. All Client assets will be managed within the designated account[s] at
the Custodian, pursuant to the terms of the advisory agreement. Please see Item 12 – Brokerage Practices.
Retirement Accounts – When the Advisor provides investment advice to Clients regarding ERISA retirement
accounts or individual retirement accounts (“IRAs”), the Advisor is a fiduciary within the meaning of Title I of the
Employee Retirement Income Security Act (“ERISA”) and/or the Internal Revenue Code (“IRC”), as applicable,
which are laws governing retirement accounts. When deemed to be in the Client’s best interest, the Advisor will
provide investment advice to a Client regarding a distribution from an ERISA retirement account or to roll over
the assets to an IRA, or recommend a similar transaction including rollovers from one ERISA sponsored Plan to
another, one IRA to another IRA, or from one type of account to another account (e.g. commission-based
account to fee-based account). Such a recommendation creates a conflict of interest if the Advisor will earn a
new (or increase its current) advisory fee as a result of the transaction. No client is under any obligation to roll
over a retirement account to an account managed by the Advisor.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 4
Financial Planning Services
Sequentis will typically provide a variety of financial planning and consulting services to Clients, either as a
component of investment management services or pursuant to a written financial planning agreement. Services
are offered in several areas of a Client’s financial situation, depending on their goals and objectives.
Generally, such financial planning services involve preparing a formal financial plan or rendering a specific
financial consultation based on the Client’s financial goals and objectives. This planning or consulting may
encompass one or more areas of need, including but not limited to, investment planning, retirement planning,
personal savings, education savings, and other areas of a Client’s financial situation.
A financial plan developed for, or financial consultation rendered to the Client will usually include general
recommendations for a course of activity or specific actions to be taken by the Client. For example,
recommendations may be made that the Client start or revise their investment programs, commence or alter
retirement savings, establish education savings and/or charitable giving programs.
Sequentis may also refer Clients to an accountant, attorney or other specialists, as appropriate for their unique
situation. For certain financial planning engagements, the Advisor will provide a written summary of the Client’s
financial situation, observations, and recommendations. For consulting or ad-hoc engagements, the Advisor may
not provide a written summary. Plans or consultations are typically completed within six (6) months of contract
date, assuming all information and documents requested are provided promptly.
Financial planning and consulting recommendations poses a conflict between the interests of the Advisor and the
interests of the Client. For example, the Advisor has an incentive to recommend that Clients engage the Advisor
for investment management services or to increase the level of investment assets with the Advisor, as it would
increase the amount of advisory fees paid to the Advisor. Clients are not obligated to implement any
recommendations made by the Advisor or maintain an ongoing relationship with the Advisor. If the Client elects
to act on any of the recommendations made by the Advisor, the Client is under no obligation to implement the
transaction through the Advisor.
Retirement Plan Advisory Services
Sequentis provides 3(21) retirement plan advisory services on behalf of the retirement plans (each a “Plan”) and
the company (the “Plan Sponsor”). The Advisor’s retirement plan advisory services are designed to assist the
Plan Sponsor in meeting its fiduciary obligations to the Plan and its Plan Participants. Each engagement is
customized to the needs of the Plan and Plan Sponsor. Services generally include:
• Vendor Analysis
• Plan Participant Enrollment and Education Tracking
• Investment Policy Statement (“IPS”) Design and Monitoring
• Investment Management
• Performance Reporting
• Ongoing Investment Recommendation and Assistance
• ERISA 404(c) Assistance
• Benchmarking Services
These services are provided by Sequentis serving in the capacity as a fiduciary under the Employee Retirement
Income Security Act of 1974, as amended (“ERISA”). In accordance with ERISA Section 408(b)(2), the Plan
Sponsor is provided with a written description of Sequentis’s fiduciary status, the specific services to be rendered
and all direct and indirect compensation the Advisor reasonably expects under the engagement.
C. Client Account Management
Prior to engaging Sequentis to provide investment advisory services, each Client is required to enter into an
agreement with the Advisor that define the terms, conditions, authority and responsibilities of the Advisor and the
Client. These services may include:
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 5
● Establishing an Investment Strategy – Sequentis, in connection with the Client, will develop a strategy
that seeks to achieve the Client’s goals and objectives.
● Asset Allocation – Sequentis will develop a strategic asset allocation that is targeted to meet the
investment objectives, time horizon, financial situation and tolerance for risk for each Client.
● Portfolio Construction – Sequentis will develop a portfolio for the Client that is intended to meet the stated
goals and objectives of the Client.
●
Investment Management and Supervision – Sequentis will provide investment management and ongoing
oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Sequentis does not manage or place Client assets into a wrap fee program. Investment management services
are provided directly by Sequentis.
E. Assets Under Management
As of December 31, 2025, Sequentis manages $101,535,976 in Client assets, all of which are managed on a
discretionary basis. Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Investment Management Services
Investment advisory fees are paid monthly, at the end of each month pursuant to the terms of the agreement.
Investment advisory fees are based on the market value of assets under management at the end of the prior
month. Investment advisory fees range from 0.58% to 1.50% annually based on several factors, including: the
complexity of the services to be provided, the level of assets to be managed, and the overall relationship with the
Advisor. Relationships with multiple objectives, specific reporting requirements, portfolio restrictions and other
complexities may be charged a higher fee.
The investment advisory fee in the first month of service is prorated from the inception date of the account[s] to
the end of the first month. Fees may be negotiable at the sole discretion of the Advisor. The Client’s fees will take
into consideration the aggregate assets under management with the Advisor. All securities held in accounts
managed by Sequentis will be independently valued by the Custodian. Sequentis will conduct periodic reviews of
the Custodian’s valuations to ensure accurate billing.
The Advisor’s fee is exclusive of, and in addition to any applicable securities transaction and custody fees, and
other related costs and expenses described in Item 5.C below, which may be incurred by the Client. However,
the Advisor shall not receive any portion of these commissions, fees, and costs.
Financial Planning Services
Sequentis offers financial planning services either on an hourly basis or a fixed fee. Hourly engagements range
from $100 to $300. Fixed fees range from $300 to $25,000. Fees may be negotiable based on the nature and
complexity of the services to be provided and the overall relationship with the Advisor. An estimate for total hours
and total costs will be provided to the Client prior to engaging for these services.
Retirement Plan Advisory Services
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00% and are billed in
arrears, pursuant to the terms of the retirement plan advisory agreement. Retirement plan fees are based on the
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 6
market value of assets under management at the end of the prior calendar month. Fees may be negotiable
depending on the size and complexity of the Plan.
Fees for retirement plan advisory services are charged an annual asset-based fee of up to 1.00%, billed in arrears,
pursuant to the terms of the agreement. Retirement plan fees are based on the market value of assets under
management at the end of the prior calendar month.
B. Fee Billing
Investment Management Services
Investment advisory fees are calculated by the Advisor or its delegate and deducted from the Client’s account[s]
at the Custodian. The Advisor shall send an invoice to the Custodian indicating the amount of the fees to be
deducted from the Client’s account[s] at the respective month end date. The amount due is calculated by
applying the monthly rate (annual rate divided by [12]) to the total assets under management with Sequentis at
the end of each month. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting
deduction of the investment advisory fee. Clients provide written authorization permitting advisory fees to be
deducted by Sequentis to be paid directly from their account[s] held by the Custodian as part of the investment
advisory agreement and separate account forms provided by the Custodian.
Financial Planning Services
Financial planning fees are invoiced by the Advisor and are due upon completion of the agreed upon
deliverable[s].
Retirement Plan Advisory Services
Retirement plan advisory fees may be directly invoiced to the Plan Sponsor or deducted from the assets of the
Plan, depending on the terms of the retirement plan advisory agreement.
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Sequentis, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all securities execution and
custody fees charged by the Custodian, if applicable. The Advisor's recommended Custodian does not charge
securities transaction fees for ETF and equity trades in a Client's account, provided that the account meets the
terms and conditions of the Custodian's brokerage requirements. However, the Custodian typically charges for
mutual funds and other types of investments. The fees charged by Sequentis are separate and distinct from
these custody and execution fees.
In addition, all fees paid to Sequentis for investment advisory services are separate and distinct from the
expenses charged by mutual funds and ETFs to their shareholders, if applicable. These fees and expenses are
described in each fund’s prospectus. These fees and expenses will generally be used to pay management fees
for the funds, other fund expenses, account administration (e.g., custody, brokerage and account reporting), and
a possible distribution fee. A Client may be able to invest in these products directly, without the services of
Sequentis, but would not receive the services provided by Sequentis which are designed, among other things, to
assist the Client in determining which products or services are most appropriate for each Client’s financial
situation and objectives. Accordingly, the Client should review both the fees charged by the fund[s] and the fees
charged by Sequentis to fully understand the total fees to be paid. Please refer to Item 12 – Brokerage Practices
for additional information.
D. Advance Payment of Fees and Termination
Investment Management Services
Sequentis is compensated for its services at the end of the month after investment advisory services are
rendered. Either party may terminate the investment advisory agreement, at any time, by providing advance
written notice to the other party. The Client may also terminate the investment advisory agreement within five (5)
business days of signing the Advisor’s agreement at no cost to the Client. After the five-day period, the Client will
incur charges for bona fide advisory services rendered to the point of termination and such fees will be due and
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 7
payable by the Client. The Client’s investment advisory agreement with the Advisor is non-transferable without
the Client’s prior consent.
Financial Planning Services
Sequentis is compensated for its services upon completion of the engagement deliverable[s]. Either party may
terminate the financial planning agreement by providing advance written notice to the other party. The Client may
also terminate the financial planning agreement within five (5) business days of signing the Advisor’s agreement
at no cost to the Client. After the five-day period, the Client will incur charges for bona fide advisory services
rendered to the point of termination and such fees will be due and payable by the Client. Upon termination, the
Client shall be billed for actual hours logged on the planning project times the contractual hourly rate or in the
case of a fixed fee engagement, the percentage of the engagement scope completed by the Advisor. The
Client’s financial planning agreement with the Advisor is non-transferable without the Client’s prior consent.
Retirement Plan Advisory Services
Sequentis is compensated for its services at the beginning/end of the month before/after advisory services are
rendered. Either party may request to terminate a retirement plan advisory agreement, at any time, by providing
advance written notice to the other party. The Client shall be responsible for investment advisory fees up to and
including the effective date of termination. [OR if Advance] The Advisor will refund any unearned, prepaid
investment advisory fees from the effective date of termination to the end of the month. The Client’s retirement plan
services agreement with the Advisor is non-transferable without the Client’s prior consent.
E. Compensation for Sales of Securities
Sequentis does not buy or sell securities to earn commissions and does not receive any compensation for
securities transactions in any Client account, other than the investment advisory fees noted above.
Insurance Agency Affiliations
Certain Advisory Persons are licensed as independent insurance professionals. As an independent insurance
professional, an Advisory Person will earn commission-based compensation for selling insurance products,
including insurance products offered to Clients. Insurance commissions earned by the Advisory Person are
separate and in addition to advisory fees. This practice presents a conflict of interest because an Advisory
Person who is also an insurance professional will have an incentive to recommend insurance products to Clients
for the purpose of generating commissions rather than solely based on Client needs. However, Clients are under
no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with the
Advisor. Please see Item 10 – Other Financial Industry Activities and Affiliations.
Item 6 – Performance-Based Fees and Side-By-Side Management
Sequentis does not charge performance-based fees for its investment advisory services. The fees charged by
Sequentis are as described in Item 5 – Fees and Compensation above and are not based upon the capital
appreciation of the funds or securities held by any Client.
Sequentis does not manage any proprietary investment funds or limited partnerships (for example, a mutual fund
or a hedge fund) and has no financial incentive to recommend any particular investment options to its Clients.
Item 7 – Types of Clients
Sequentis offers investment advisory services to individuals and high net worth individuals. These amounts may
change over time and are updated at least annually by the Advisor.
Generally, the minimum dollar account value required to open an account for clients of Sequentis is $1,000,000.
Sequentis reserves the right to reduce this minimum on a case-by-case basis.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 8
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Investment strategies, methods of analysis and risks will be discussed in detail with potential investment advisory
account clients. In general, Sequentis uses a fundamental method of analysis and asset allocation to provide
diversification. Sequentis will suggest multiple strategies that will be used to meet client objectives. Methods of
analysis will differ for individual securities and for mutual funds. For mutual funds, Sequentis will look at factors
such as investment process, corporate culture, management tenure, expense ratios, portfolio turnover, load
structure. Research and analysis from Sequentis is derived from numerous sources, including financial media
companies, third-party research materials, Internet sources, and review of company activities, including annual
reports, prospectuses, press releases and research prepared by others.
Fundamental analysis utilizes economic and business indicators as investment selection criteria. This criteria
consists generally of ratios and trends that may indicate the overall strength and financial viability of the entity
being analyzed. Assets are deemed suitable if they meet certain criteria to indicate that they are a strong
investment with a value discounted by the market. While this type of analysis helps the Advisor in evaluating a
potential investment, it does not guarantee that the investment will increase in value. Assets meeting the
investment criteria utilized in the fundamental analysis may lose value and may have negative investment
performance. The Advisor monitors these economic indicators to determine if adjustments to strategic allocations
are appropriate. More details on the Advisor’s review process are included below in Item 13 – Review of
Accounts.
As noted above, Sequentis generally employs a long-term investment strategy for its Clients, as consistent with
their financial goals. Sequentis will typically hold all or a portion of a security for more than a year, but may hold
for shorter periods for the purpose of rebalancing a portfolio or meeting the cash needs of Clients. At times,
Sequentis may also buy and sell positions that are more short-term in nature, depending on the goals of the
Client and/or the fundamentals of the security, sector or asset class.
B. Risk of Loss
Investing in securities involves certain investment risks. Securities may fluctuate in value or lose value. Clients
should be prepared to bear the potential risk of loss. Sequentis will assist Clients in determining an appropriate
strategy based on their tolerance for risk and other factors noted above. However, there is no guarantee that a
Client will meet their investment goals. Please see Item 8.B. for risks associated with the Advisor’s investment
strategies as well as general risks of investing.
While the methods of analysis help the Advisor in evaluating a potential investment, it does not guarantee that
the investment will increase in value. Assets meeting the investment criteria utilized in these methods of analysis
may lose value and may have negative investment performance. The Advisor monitors these economic
indicators to determine if adjustments to strategic allocations are appropriate. More details on the Advisor’s
review process are included below in Item 13 – Review of Accounts.
Each Client engagement will entail a review of the Client's investment goals, financial situation, time horizon,
tolerance for risk and other factors to develop an appropriate strategy for managing a Client's account. Client
participation in this process, including full and accurate disclosure of requested information, is essential for the
analysis of a Client's account[s]. The Advisor shall rely on the financial and other information provided by the
Client or their designees without the duty or obligation to validate the accuracy and completeness of the provided
information. It is the responsibility of the Client to inform the Advisor of any changes in financial condition, goals
or other factors that may affect this analysis.
The risks associated with a particular strategy are provided to each Client in advance of investing Client
accounts. The Advisor will work with each Client to determine their tolerance for risk as part of the portfolio
construction process. Following are some of the risks associated with the Advisor’s investment strategies:
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 9
Stock Portfolios
Client accounts will be subject to the risks associated with any equity investment strategy. Sharp downward
market moves may adversely impact a client’s positions and result in losses. Losses may also be incurred on
individual positions as a result of issuer-specific matters such as unexpectedly disappointing earnings, lawsuits,
patent issues, analyst action or other matters. Equity returns are volatile and may fluctuate substantially over
time.
Market Risks
The value of a Client’s holdings may fluctuate in response to events specific to companies or markets, as well as
economic, political, or social events in the U.S. and abroad. This risk is linked to the performance of the overall
financial markets.
Information Sources and Analysis
Sequentis selects investments for its clients based in part on information and data that the issuers of securities
file with various government agencies or make directly available to Sequentis or that it obtains from other
sources. Sequentis is not in a position to confirm the completeness, genuineness or accuracy of such information
and data, and in some cases, complete and accurate information may not be readily available. Sequentis is not
in a position to obtain all relevant information regarding a company or a security. Further, Sequentis may
misinterpret or incorrectly analyze the information that is about a particular fund, company or security. These and
other factors may cause Sequentis to (a) invest a client’s securities at times that will lead to losses, in a client’s
portfolio and may cause a client to lose a significant portion of its investment or (b) refrain from investing in
particular securities at times that would have resulted in gains in the client’s portfolio if Sequentis would have
cause the client’s account to invest.
Portfolio Valuation
Because of the size and nature of the positions held by a client account, the value at which its investments can
be liquidated may differ, sometimes significantly, from the interim valuations arrived at by using Sequentis’
methodology. In addition, the timing of liquidations may also affect the values obtained on liquidation. Securities
to be held by a client account may routinely trade with bid-ask spreads that may be significant. At times, third-
party pricing information may not be available for certain positions held by a client.
ETF Risks
The performance of ETFs is subject to market risk, including the possible loss of principal. The price of the ETFs
will fluctuate with the price of the underlying securities that make up the funds. In addition, ETFs have a trading
risk based on the loss of cost efficiency if the ETFs are traded actively and a liquidity risk if the ETFs have a large
bid-ask spread and low trading volume. The price of an ETF fluctuates based upon the market movements and
may dissociate from the index being tracked by the ETF or the price of the underlying investments. An ETF
purchased or sold at one point in the day may have a different price than the same ETF purchased or sold a
short time later. There is also a risk that Authorized Participants are unable to fulfill their responsibilities.
Authorized Participants are one of the major parties involved with ETF creation/redemption mechanism in the
markets. The Authorized Participants play a critical role in the liquidity of ETFs and essentially have the exclusive
right to change the supply of ETF shares in the market. If the Authorized Participants does not fulfill this expected
role, there could be an adverse impact on liquidity and the valuation of an ETF.
Bond ETFs
Bond ETFs are subject to specific risks, including the following: (1) interest rate risks, i.e. the risk that bond prices
will fall if interest rates rise, and vice versa, the risk depends on two things, the bond's time to maturity, and the
coupon rate of the bond. (2) reinvestment risk, i.e. the risk that any profit gained must be reinvested at a lower
rate than was previously being earned, (3) inflation risk, i.e. the risk that the cost of living and inflation increase at
a rate that exceeds the income investment thereby decreasing the investor’s rate of return, (4) credit default risk,
i.e. the risk associated with purchasing a debt instrument which includes the possibility of the company defaulting
on its repayment obligation, (5) rating downgrades, i.e. the risk associated with a rating agency’s downgrade of
the company’s rating which impacts the investor’s confidence in the company’s ability to repay its debt and (6)
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 10
Liquidity Risks, i.e. the risk that a bond may not be sold as quickly as there is no readily available market for the
bond.
Mutual Fund Risks
The performance of mutual funds is subject to market risk, including the possible loss of principal. The price of
the mutual funds will fluctuate with the value of the underlying securities that make up the funds. The price of a
mutual fund is typically set daily therefore a mutual fund purchased at one point in the day will typically have the
same price as a mutual fund purchased later that same day.
Past performance is not a guarantee of future returns. Investing in securities and other investments
involve a risk of loss that each Client should understand and be willing to bear. Clients are reminded to
discuss these risks with the Advisor.
Item 9 – Disciplinary Information
There are no legal, regulatory or disciplinary events involving Sequentis or its Supervised Persons.
Sequentis values the trust Clients place in the Advisor. The Advisor encourages Clients to perform the requisite
due diligence on any advisor or service provider that the Client engages. The backgrounds of the Advisor and its
Advisory Persons are available on the Investment Adviser Public Disclosure website at www.adviserinfo.sec.gov
by searching with the Advisor’s firm name or CRD# 298533.
Item 10 – Other Financial Industry Activities and Affiliations
Insurance Agency Affiliations
As noted in Item 5, certain Advisory Persons are also licensed insurance professionals. Implementations of
insurance recommendations are separate and apart from an Advisory Person's role with the Advisor. As an
insurance professional, the Advisory Person will receive customary commissions and other related revenues
from the various insurance companies whose products are sold. An Advisory Person is not required to offer the
products of any particular insurance company. Commissions generated by insurance sales do not offset regular
advisory fees. This practice presents a conflict of interest in recommending certain products of the insurance
companies. Clients are under no obligation to implement any recommendations made by an Advisory Person or
the Advisor.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Sequentis has implemented a Code of Ethics (the “Code”) that defines the Advisor’s fiduciary commitment to
each Client. This Code applies to all persons associated with Sequentis ( “Supervised Persons”). The Code was
developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to the
Client. Sequentis and its Supervised Persons owe a duty of loyalty, fairness and good faith towards each Client.
It is the obligation of Sequentis’s Supervised Persons to adhere not only to the specific provisions of the Code,
but also to the general principles that guide the Code. The Code covers a range of topics that address employee
ethics and conflicts of interest. To request a copy of the Code, please contact the Advisor at (617) 419-7133 or
via email at admin@sequentis-capital.com.
B. Personal Trading with Material Interest
Sequentis allows Supervised Persons to purchase or sell the same securities that may be recommended to and
purchased on behalf of Clients. Sequentis does not act as principal in any transactions. In addition, the Advisor
does not act as the general partner of a fund, or advise an investment company. Sequentis does not have a
material interest in any securities traded in Client accounts.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 11
C. Personal Trading in Same Securities as Clients
Sequentis allows Supervised Persons to purchase or sell the same securities that are recommended to and
purchased on behalf of Clients. Owning the same securities we recommend (purchase or sell) to Clients presents
a conflict of interest that, as fiduciaries, must be disclosed to Clients and mitigated through policies and
procedures. As noted above, the Advisor has adopted the Code to address insider trading (material non-public
information controls); gifts and entertainment; outside business activities and personal securities reporting. When
trading for personal accounts, Supervised Persons have a conflict of interest if trading in the same securities.
The fiduciary duty to act in the best interest of its Clients can be violated if personal trades are made with more
advantageous terms than Client trades, or by trading based on material non-public information. This risk is
mitigated by Sequentis requiring reporting of personal securities trades by its Supervised Persons for review by
the Chief Compliance Officer (“CCO”) or delegate. The Advisor has also adopted written policies and procedures
to detect the misuse of material, non-public information.
D. Personal Trading at Same Time as Client
While Sequentis allows Supervised Persons to purchase or sell the same securities that may be recommended
to and purchased on behalf of Clients, such trades are typically aggregated with Client orders or traded
afterward. At no time will Sequentis, or any Supervised Person of Sequentis, transact in any security to
the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Sequentis does not have discretionary authority to select the broker-dealer/custodian for custody and execution
services. The Client will engage the broker-dealer/custodian (herein the "Custodian") to safeguard Client assets
and authorize Sequentis to direct trades to the Custodian as agreed upon in the investment advisory agreement.
Further, Sequentis does not have the discretionary authority to negotiate commissions on behalf of Clients on a
trade-by-trade basis.
Where Sequentis does not exercise discretion over the selection of the Custodian, it may recommend the
Custodian to Clients for custody and execution services. Clients are not obligated to use the recommended
Custodian and will not incur any extra fee or cost associated with using a custodian not recommended by
Sequentis. However, the Advisor may be limited in the services it can provide if the recommended Custodian is
not engaged. Sequentis may recommend the Custodian based on criteria such as, but not limited to,
reasonableness of commissions charged to the Client, services made available to the Client, its reputation and/or
location of the Custodian’s offices. Sequentis will generally recommend that Clients establish their account[s] at
Charles Schwab & Co, Inc. (“Schwab”), a FINRA-registered broker-dealer and member SIPC. Schwab will serve
as the Client’s “qualified custodian”. Sequentis maintains an institutional relationship with Schwab, whereby the
Advisor receives economic benefits from Schwab. Please see Item 14 below.
The following are additional details regarding the brokerage practices of the Advisor:
1. Soft Dollars - Soft dollars are revenue programs offered by broker-dealers/custodians whereby an
advisor enters into an agreement to place security trades with the broker/dealers/custodians in exchange
for research and other services. Sequentis does not participate in soft dollar programs sponsored
or offered by any broker-dealer/custodian. However, the Advisor receives certain economic
benefits from the Custodian. Please see Item 14 below.
2. Brokerage Referrals - Sequentis does not receive any compensation from any third party in
connection with the recommendation for establishing an account.
3. Directed Brokerage - All Clients are serviced on a “directed brokerage basis”, where Sequentis will
place trades within the established account[s] at the Custodian designated by the Client. Further, all
Client accounts are traded within their respective account[s]. The Advisor will not engage in any principal
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 12
transactions (i.e., trade of any security from or to the Advisor’s own account) or cross transactions with
other Client accounts (i.e., purchase of a security into one Client account from another Client’s
account[s]). Sequentis will not be obligated to select competitive bids on securities transactions and does
not have an obligation to seek the lowest available transaction costs. These costs are determined by the
Custodian.
B. Aggregating and Allocating Trades
The primary objective in placing orders for the purchase and sale of securities for Client accounts is to obtain the
most favorable net results taking into account such factors as 1) price, 2) size of the order, 3) difficulty of
execution, 4) confidentiality and 5) skill required of the broker-dealer/custodian. Sequentis will execute its
transactions through the Custodian as authorized by the Client. Sequentis may aggregate orders in a block trade
or trades when securities are purchased or sold through the Custodian for multiple (discretionary) accounts in the
same trading day. If a block trade cannot be executed in full at the same price or time, the securities actually
purchased or sold by the close of each business day must be allocated in a manner that is consistent with the
initial pre-allocation or other written statement. This must be done in a way that does not consistently advantage
or disadvantage any particular Clients’ accounts.
Item 13 – Review of Accounts
A. Frequency of Reviews
Securities in Client accounts are monitored on a regular and continuous basis by Ryan Nagle, Chief Compliance
Officer of Sequentis. Formal reviews are generally conducted at least annually or more or less frequently
depending on the needs of the Client.
B. Causes for Reviews
In addition to the investment monitoring noted in Item 13.A., each Client account shall be reviewed at least
annually. Reviews may be conducted more frequently at the Client’s request. Accounts may be reviewed as a
result of major changes in economic conditions, known changes in the Client’s financial situation, and/or large
deposits or withdrawals in the Client’s account[s]. The Client is encouraged to notify Sequentis if changes occur
in the Client’s personal financial situation that might adversely affect the Client’s investment plan. Additional
reviews may be triggered by material market, economic or political events.
C. Review Reports
The Client will receive brokerage statements no less than quarterly from the Custodian. These brokerage
statements are sent directly from the Custodian to the Client. The Client may also establish electronic access to
the Custodian’s website so that the Client may view these reports and their account activity. Client brokerage
statements will include all positions, transactions and fees relating to the Client’s account[s]. The Advisor may
also provide Clients with periodic reports regarding their holdings, allocations, and performance.
Item 14 – Client Referrals and Other Compensation
A. Compensation Received by Sequentis
Sequentis is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment
product. Sequentis does not receive commissions or other compensation from product sponsors, broker-dealers
or any un-related third party. Sequentis may refer Clients to various unaffiliated, non-advisory professionals (e.g.
attorneys, accountants, estate planners) to provide certain financial services necessary to meet the goals of its
Clients. Likewise, Sequentis may receive non-compensated referrals of new Clients from various third-parties.
Participation in Institutional Advisor Platform
Sequentis has established an institutional relationship with Schwab through its “Schwab Advisor Services” unit, a
division of Schwab dedicated to serving independent advisory firms like Sequentis. As a registered investment
advisor participating on the Schwab Advisor Services platform, Sequentis receives access to software and
related support without cost because the Advisor renders investment management services to Clients that
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 13
maintain assets at Schwab. Services provided by Schwab Advisor Services benefit the Advisor and many, but
not all services provided by Schwab will benefit Clients. In fulfilling its duties to its Clients, the Advisor endeavors
at all times to put the interests of its Clients first. Clients should be aware, however, that the receipt of economic
benefits from a custodian creates a potential conflict of interest since these benefits may influence the Advisor's
recommendation of this custodian over one that does not furnish similar software, systems support, or services.
Services that Benefit the Client – Schwab’s institutional brokerage services include access to a broad range of
investment products, execution of securities transactions, and custody of Client’s funds and securities. Through
Schwab, the Advisor may be able to access certain investments and asset classes that the Client would not be
able to obtain directly or through other sources. Further, the Advisor may be able to invest in certain mutual funds
and other investments without having to adhere to investment minimums that might be required if the Client were
to directly access the investments.
Services that May Indirectly Benefit the Client – Schwab provides participating advisors with access to
technology, research, discounts and other services. In addition, the Advisor receives duplicate statements for
Client accounts, the ability to deduct advisory fees, trading tools, and back office support services as part of its
relationship with Schwab. These services are intended to assist the Advisor in effectively managing accounts for
its Clients, but may not directly benefit all Clients.
Services that May Only Benefit the Advisor – Schwab also offers other services and financial support to
Sequentis that may not benefit the Client, including: educational conferences and events, financial start-up
support, consulting services and discounts for various service providers. Access to these services creates a
financial incentive for the Advisor to recommend Schwab, which results in a potential conflict of interest.
Sequentis believes, however, that the selection of Schwab as Custodian is in the best interests of its Clients.
B. Compensation for Client Referrals
Sequentis does not compensate, either directly or indirectly, any persons who are not supervised persons, for
Client referrals.
Item 15 – Custody
The Advisor is authorized to deduct its fees from the Client’s account[s] at the Custodian. The Client must place
all assets with a “qualified custodian”. The Client is required to engage the Custodian to retain all funds and
securities and direct the Advisor to utilize that Custodian for security transactions in the account[s]. The Client
should review statements provided by the Custodian, as the Custodian does not perform this review. For more
information about custodians and brokerage practices, see Item 12 – Brokerage Practices.
If the Client gives the Advisor authority to move money from one account to another account, the Advisor may
have custody of those assets. In order to avoid additional regulatory requirements, the Custodian and the Advisor
have adopted safeguards to ensure that the money movements are completed in accordance with the Client’s
instructions.
Item 16 – Investment Discretion
Sequentis generally has discretion over the selection and amount of securities to be bought or sold in Client
accounts without obtaining prior consent or approval from the Client. However, these purchases or sales may be
subject to specified investment objectives, guidelines, or limitations previously set forth by the Client and agreed
to by Sequentis. Discretionary authority will only be authorized upon full disclosure to the Client. The granting of
such authority will be evidenced by the Client's execution of an investment advisory agreement containing all
applicable limitations to such authority. All discretionary trades made by Sequentis will be in accordance with
each Client's investment objectives and goals.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 14
Item 17 – Voting Client Securities
Sequentis does not accept proxy-voting responsibility for any Client. Clients will receive proxy statements directly
from the Custodian. The Advisor will assist in answering questions relating to proxies, however, the Client retains
the sole responsibility for proxy decisions and voting.
Item 18 – Financial Information
Neither Sequentis, nor Ryan Nagle, have any adverse financial situations that would reasonably impair the ability
of Sequentis to meet all obligations to its Clients. Neither Sequentis, nor any of its Advisory Persons, have been
subject to a bankruptcy or financial compromise. Sequentis is not required to deliver a balance sheet along with
this Disclosure Brochure as the Advisor does not collect advance fees of $1,200 or more for services to be
performed six months or more in the future.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 15
Form ADV Part 2B – Brochure Supplement
for
Ryan T. Nagle
Principal and Chief Compliance Officer
Effective: April 24, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Ryan T. Nagle (CRD# 5790873) in addition to the information contained in the Sequentis Capital LLC
(“Sequentis” or the “Advisor”, CRD# 298533) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Sequentis Disclosure Brochure or this
Brochure Supplement, please contact the Advisor at (617) 419-7133 or by email at admin@sequentis-
capital.com.
Additional information about Mr. Nagle is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 5790873.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 16
Item 2 – Educational Background and Business Experience
Ryan T. Nagle, born in 1982, is dedicated to advising Clients of Sequentis as the Principal. Mr. Nagle earned a
BA from Fordham University in 2004. Additional information regarding Mr. Nagle’s employment history is
included below.
Employment History:
Principal and Chief Compliance Officer, Sequentis Capital LLC
Financial Advisor, Merrill Lynch, Pierce, Fenner & Smith Inc
Financial Advisor, Morgan Stanley Smith Barney
10/2018 to Present
05/2012 to 10/2018
05/2010 to 08/2011
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Nagle. Mr. Nagle has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Nagle.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Nagle.
However, we do encourage you to independently view the background of Mr. Nagle on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
5790873.
Item 4 – Other Business Activities
Mr. Nagle is dedicated to the investment advisory activities of Sequentis’ Clients. Mr. Nagle does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Nagle is dedicated to the investment advisory activities of Sequentis’ Clients. Mr. Nagle does not receive any
additional forms of compensation.
Item 6 – Supervision
Mr. Nagle serves as the Principal and Chief Compliance Officer of Sequentis. Mr. Nagle can be reached at (617)
419-7133.
Sequentis has implemented a Code of Ethics and internal compliance that guide each Supervised Person in
meeting their fiduciary obligations to Clients of Sequentis. Further, Sequentis is subject to regulatory oversight by
various agencies. These agencies require registration by Sequentis and its Supervised Persons. As a registered
entity, Sequentis is subject to examinations by regulators, which may be announced or unannounced. Sequentis
is required to periodically update the information provided to these agencies and to provide various reports
regarding the business activities and assets of the Advisor.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 17
Form ADV Part 2B – Brochure Supplement
for
Charles K. Butler III
Managing Director
Effective: April 24, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Charles K. Butler III (CRD# 2761367) in addition to the information contained in the Sequentis Capital LLC
(“Sequentis” or the “Advisor”, CRD# 298533) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Sequentis Disclosure Brochure or this
Brochure Supplement, please contact us at (617) 419-7133 or by email at ryan.nagle@sequentis-capital.com.
Additional information about Mr. Butler is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 2761367.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 18
Item 2 – Educational Background and Business Experience
Charles K. Butler III, born in 1972, is dedicated to advising Clients of Sequentis as a Managing Director. Mr.
Butler earned a B.A Arts & Science from Boston College in 1995Additional information regarding Mr. Butler’s
employment history is included below.
Employment History:
Managing Director, Sequentis Capital LLC
Sales, Vision 4 Fund Distributors
Regional Vice President, Advisors Asset Management
Regional Vice-President, TSC Distributors, LLC
09/2020 to Present
03/2000 to 09/2020
02/2008 to 08/2015
11/2009 to 08/2015
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Butler. Mr. Butler has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Butler.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Butler.
However, we do encourage you to independently view the background of Mr. Butler on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
2761367.
Item 4 – Other Business Activities
Mr. Butler is dedicated to the investment advisory activities of Sequentis’s Clients. Mr. Butler does not have any
other business activities.
Item 5 – Additional Compensation
Mr. Butler is dedicated to the investment advisory activities of Sequentis’s Clients. Mr. Butler does not receive
any additional forms of compensation.
Item 6 – Supervision
Mr. Butler serves as a Managing Director of Sequentis and is supervised by Ryan Nagle, the Chief Compliance
Officer. Mr. Nagle can be reached at (617) 419-7133.
Sequentis has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Sequentis. Further, Sequentis is subject to regulatory
oversight by various agencies. These agencies require registration by Sequentis and its Supervised Persons. As
a registered entity, Sequentis is subject to examinations by regulators, which may be announced or
unannounced. Sequentis is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 19
Form ADV Part 2B – Brochure Supplement
for
Patrick R. Davis
Managing Director
Effective: April 24, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of
Patrick R. Davis (CRD# 725504) in addition to the information contained in the Sequentis Capital LLC
(“Sequentis” or the “Advisor”, CRD# 298533) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Sequentis Disclosure Brochure or this
Brochure Supplement, please contact us at (617) 419-7133 or by email at ryan.nagle@sequentis-capital.com.
Additional information about Mr. Davis is available on the SEC’s Investment Adviser Public Disclosure website at
www.adviserinfo.sec.gov by searching with his full name or his Individual CRD# 725504.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 20
Item 2 – Educational Background and Business Experience
Patrick R. Davis, born in 1957, is dedicated to advising Clients of Sequentis as the Managing Director. Mr. Davis
earned a Bachelor’s of Science from Syracuse University. Additional information regarding Mr. Davis’s
employment history is included below.
Employment History:
Managing Director, Sequentis Capital LLC
Investment Advisor Representative, Integrated Wealth Concepts LLC
Director of Business_, M3 Advisory Group LLC________
01/2023 to Present
04/2019 to 01/2023
10/2013 to 04/2019
Chartered Financial Consultant™ (“ChFC ® ”)
The Chartered Financial Consultant™ (ChFC ® ) program prepares you to meet the advanced financial
planning needs of individuals, professionals, and small business owners. You'll gain a sustainable
advantage in this competitive field with in-depth coverage of the key financial planning disciplines,
including insurance, income taxation, retirement planning, investments, and estate planning. The ChFC ®
requires three years of full-time, relevant business experience, nine two-hour course-specific proctored
exams, and 30 hours of continuing education every two years. Holders of the ChFC ® designation must
adhere to The American College’s Code of Ethics.
Program Objectives:
● Function as an ethical, competent and articulate practitioner in the field of financial planning
● Utilize the intellectual tools and framework needed to maintain relevant and current financial planning
knowledge and strategies.
● Apply financial planning theory and techniques through the development of case studies and solutions.
● Apply in-depth knowledge in a holistic manner from a variety of disciplines, namely, estate planning,
retirement planning, or non-qualified deferred compensation.
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Davis. Mr. Davis has never been
involved in any regulatory, civil or criminal action. There have been no client complaints, lawsuits, arbitration
claims or administrative proceedings against Mr. Davis.
Securities laws require an advisor to disclose any instances where the advisor or its advisory persons have been
found liable in a legal, regulatory, civil or arbitration matter that alleges violation of securities and other statutes;
fraud; false statements or omissions; theft, embezzlement or wrongful taking of property; bribery, forgery,
counterfeiting, or extortion; and/or dishonest, unfair or unethical practices. As previously noted, there are no
legal, civil or disciplinary events to disclose regarding Mr. Davis.
However, we do encourage you to independently view the background of Mr. Davis on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
725504.
Item 4 – Other Business Activities
Insurance Agency Affiliations
Mr. Davis is also a licensed insurance professional. Implementations of insurance recommendations are
separate and apart from Mr. Davis’s role with Sequentis. As an insurance professional, Mr. Davis will receive
customary commissions and other related revenues from the various insurance companies whose products are
sold. Mr. Davis is not required to offer the products of any particular insurance company. Commissions
generated by insurance sales do not offset regular advisory fees. This practice presents a conflict of interest in
recommending certain products of the insurance companies. Clients are under no obligation to implement any
recommendations made by Mr. Davis or the Advisor. Mr. Davis spends approximately 20 hours per month of his
time per month in this capacity.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 21
Item 5 – Additional Compensation
Mr. Davis has additional business activities where compensation is received that are detailed in Item 4 above.
Item 6 – Supervision
Mr. Davis serves as the Managing Director of Sequentis and is supervised by Ryan Nagle, the Chief Compliance
Officer. Mr. Nagle can be reached at (617) 419-7133.
Sequentis has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Sequentis. Further, Sequentis is subject to regulatory
oversight by various agencies. These agencies require registration by Sequentis and its Supervised Persons. As
a registered entity, Sequentis is subject to examinations by regulators, which may be announced or
unannounced. Sequentis is required to periodically update the information provided to these agencies and to
provide various reports regarding the business activities and assets of the Advisor.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 22
Privacy Policy
Effective: April 24, 2026
Our Commitment to You
Sequentis Capital LLC (“Sequentis” or the “Advisor” and also referred to as “we”, “our” and “us”) is committed to
safeguarding the use of personal information of our Clients (also referred to as “you” and “your”) that we obtain
as your Investment Advisor, as described here in our Privacy Policy (“Policy”).
Our relationship with you is our most important asset. We understand that you have entrusted us with your
private information, and we do everything that we can to maintain that trust. Sequentis (also referred to as "we",
"our" and "us”) protects the security and confidentiality of the personal information we have and implements
controls to ensure that such information is used for proper business purposes in connection with the
management or servicing of our relationship with you.
Sequentis will never sell your non-public personal information to anyone. Nor do we provide such information to
others except for discrete and reasonable business purposes in connection with the servicing and management
of our relationship with you, as discussed below.
Details of our approach to privacy and how your personal non-public information is collected and used are set
forth in this Policy.
Why you need to know?
Registered Investment Advisors (“RIAs”) must share some of your personal information in the course of servicing
your account. Federal and State laws give you the right to limit some of this sharing and require RIAs to disclose
how we collect, share, and protect your personal information.
What information do we collect from you?
Driver’s license number
Date of birth
Social security or taxpayer identification number Assets and liabilities
Name, address and phone number[s]
Income and expenses
E-mail address[es]
Investment activity
Account information (including other institutions)
Investment experience and goals
What Information do we collect from other sources?
Custody, brokerage and advisory agreements
Other advisory agreements and legal documents
Transactional information with us or others
Account applications and forms
Investment questionnaires and suitability
documents
Other information needed to service account
How do we protect your information?
To safeguard your personal information from unauthorized access and use we maintain physical, procedural and
electronic security measures. These include such safeguards as secure passwords, encrypted file storage and a
secure office environment. Our technology vendors provide security and access control over personal
information and have policies over the transmission of data. Our associates are trained on their responsibilities to
protect Client’s personal information.
We require third parties that assist in providing our services to you to protect the personal information they
receive from us.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
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How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list the
primary reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
Yes
No
Servicing our Clients
With the consent of the Client, the Advisor may share non-public
personal information with non-affiliated third parties (such as
administrations brokers, custodians, regulators, credit agencies other
financial institutions and service providers) as necessary for us to provide
agreed upon services to you, consistent with applicable law, including but
not limited to: processing transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
No
N/A
Marketing Purposes
Sequentis does not disclose, and does not intend to disclose, personal
information with non-affiliated third parties to offer you services. Certain
laws may give us the right to share your personal information with
financial institutions where you are a customer and where Sequentis or
the client has a formal agreement with the financial institution. We will
only share information for purposes of servicing your accounts, not
for marketing purposes.
yes
yes
Authorized Users
Your non-public personal information may be disclosed to you and
persons that we believe to be your authorized agent[s] or
representative[s].
No
N/A
Information About Former Clients
Sequentis does not disclose and does not intend to disclose, non-public
personal information to non-affiliated third parties with respect to persons
who are no longer our Clients, except for inquiries by securities
regulators as noted above.
State-specific Regulations
Massachusetts
In response to a Massachusetts law, the Client must “opt-in” to share non-public personal
information with non-affiliated third parties before any personal information is disclosed.
Client opt-in is obtained through the Client’s execution of authorization forms provided by
the third parties, by executing an Information Sharing Authorization Form, or by other written
consent by the Client, as appropriate and consistent with applicable laws and regulations.
Changes to our Privacy Policy
We will send you a copy of this Policy annually for as long as you maintain an ongoing relationship with us.
Periodically we may revise this Policy and will provide you with a revised Policy if the changes materially alter the
previous Privacy Policy. We will not, however, revise our Privacy Policy to permit the sharing of non-public
personal information other than as described in this notice unless we first notify you and provide you with an
opportunity to prevent the information sharing.
Any Questions?
You may ask questions or voice any concerns, as well as obtain a copy of our current Privacy Policy by
contacting us at (617) 419-7133 or via email at admin@sequentis-capital.com.
Sequentis Capital LLC
One Boston Place, 201 Washington St, 26th Floor, Boston, MA 02108
Phone: (617) 419-7133 * Fax: (800) 515-2157
http//:www.sequentis-capital.com
Page 24