Overview
- Headquarters
- San Jose, CA
- Total Firm Assets
- $1.3 billion
- Average High-Net-Worth Client Portfolio Size
- $3.4 million
Fee Structure
Primary Fee Schedule (DISCLOSURE BROCHURE)
| Min | Max | Marginal Fee Rate |
|---|---|---|
| $0 | and above | 1.00% |
Illustrative Fee Rates
| Total Assets | Annual Fees | Average Fee Rate |
|---|---|---|
| $1 million | $10,000 | 1.00% |
| $5 million | $50,000 | 1.00% |
| $10 million | $100,000 | 1.00% |
| $50 million | $500,000 | 1.00% |
| $100 million | $1,000,000 | 1.00% |
Clients
- High-Net-Worth Share of Firm Assets
- 90.94%
- Number of High-Net-Worth Clients
- 340
- Total Client Accounts
- 1,627
- Discretionary Accounts
- 1,627
Services Offered
Services: Financial Planning, Portfolio Management for Individuals, Portfolio Management for Institutional Clients
Regulatory Filings
- SEC CRD Number
- 125114
Primary Brochure: DISCLOSURE BROCHURE (2026-03-20)
View Document Text
Disclosure Brochure
March 15, 2026
Silicon Valley Capital Partners
a Registered Investment Adviser
This brochure provides information about the qualifications and business practices of Silicon Valley Capital Partners, L.P.
(hereinafter “SVCP” or the “Firm”). If you have any questions about the contents of this brochure, please contact the Firm
at the telephone number listed below. The information in this brochure has not been approved or verified by the United
States Securities and Exchange Commission (SEC) or by any state securities authority. Additional information about the
Firm is available on the SEC’s website at www.adviserinfo.sec.gov. SVCP is an SEC registered investment adviser.
Registration does not imply any level of skill or training.
1731 Technology Drive, Suite 810, San Jose, CA 95110 | (408) 236-7300
www.svcp.com
Item 2. Material Changes
In this Item, SVCP is required to discuss any material changes that have been made to the brochure
since the
last annual amendment
filed February, 3, 2025. Such revisions are based on
the
nature of the updated information since our last annual amendment filing. There have been no material
changes to this Brochure since our last annual amendment on February 3, 2025.
Silicon Valley Capital Partners, L.P. Disclosure Brochure
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 ....................................................................................................................... 4
Item 5.
Fees and Compensation .............................................................................................................. 5
Item 6.
Performance-Based Fees and Side-by-Side Management .......................................................... 7
Item 7.
Types of Clients ........................................................................................................................... 7
Item 8.
Methods of Analysis, Investment Strategies and Risk of Loss ..................................................... 7
Item 9.
Disciplinary Information ................................................................................................................ 8
Item 10. Other Financial Industry Activities and Affiliations ........................................................................ 9
Item 11. Code of Ethics ............................................................................................................................. 9
Item 12. Brokerage Practices................................................................................................................... 10
Item 13. Review of Accounts ................................................................................................................... 12
Item 14. Client Referrals and Other Compensation ................................................................................. 13
Item 15. Custody ..................................................................................................................................... 13
Item 16.
Investment Discretion ................................................................................................................ 14
Item 17. Voting Client Securities .............................................................................................................. 14
Item 18. Financial Information .................................................................................................................. 14
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Silicon Valley Capital Partners, L.P. Disclosure Brochure
Item 4.
Advisory Business
SVCP primarily offers investment management services to its clients. The Firm has been an independent
registered investment adviser since July 2003 and is wholly owned by Christopher K. Combs.
As of December 31, 2025, SVCP has $1,287,983,872 in assets under management, all of
which was managed on a discretionary basis.
Prior to the rendering of any investment management services, clients are required to enter into one or
more written agreements with SVCP setting forth the relevant terms and conditions of the advisory
relationship (the “Agreement”).
While this brochure generally describes the business of SVCP, certain sections also discuss the activities
of its Supervised Persons, which refer to the Firm’s officers, partners, directors (or other persons occupying
a similar status or performing similar functions), employees or any other person who provides investment
advice on SVCP’s behalf and is subject to the Firm’s supervision or control.
Investment Management Services
SVCP manages client investment portfolios on a discretionary basis. Financial planning and consulting
services, as discussed below, may also be rendered in conjunction with investment management services.
SVCP primarily allocates client assets among various types of equity and fixed income securities, in
accordance with the investment objectives of its individual clients. Equity securities include individual
stocks, as well as stock mutual funds and exchange-traded funds (“ETFs”). Fixed income securities include
individual bonds, certificates of deposit, and bond ETFs. When appropriate, the Firm may help its clients
transfer an existing annuity to a Fidelity Personal Retirement Annuity® in order to provide its clients with
investment management services regarding the annuity’s underlying investment options. In more limited
circumstances, the Firm may provide advice about any type of legacy position or other investment held in
client portfolios.
SVCP tailors its advisory services to meet the needs of its individual clients and continuously seeks to
ensure that client portfolios are managed in a manner consistent with their specific investment profiles.
SVCP consults with clients on an initial and ongoing basis to determine their specific risk tolerance, time
horizon, liquidity constraints and other qualitative factors relevant to the management of their portfolios.
Clients are advised to promptly notify SVCP if there are changes in their financial situation or if they wish to
place any limitations on the management of their portfolios. Clients may impose reasonable restrictions
or mandates on the management of their accounts if SVCP determines, in its sole discretion, the conditions
would not materially impact the performance of a management strategy or prove overly burdensome to the
Firm’s management efforts.
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Silicon Valley Capital Partners, L.P. Disclosure Brochure
Financial Planning and Consulting Services
SVCP offers clients a range of financial planning and consulting services, which may include any or all of
the following functions:
Investment Consulting
Business Planning
Insurance Needs Analysis
Cash Flow Forecasting
Asset Allocation
Retirement Plan Analysis
Retirement Planning
Charitable Giving
Estate Planning
Risk Management
Financial Reporting
Distribution Planning
In performing these services, SVCP is not required to verify any information received from the client or from
the client’s other professionals (e.g., attorneys, accountants, etc.) and is expressly authorized to rely on
such information.
SVCP may recommend the services of itself, its Supervised Persons, or other professionals to implement
its recommendations. Clients are advised that a conflict of interest exists if clients engage SVCP to provide
additional fee-based services. Clients retain absolute discretion over all decisions regarding implementation
and are under no obligation to act upon any of the financial planning or consulting recommendations made
by SVCP, or to engage the services of any such recommended professionals, including SVCP itself.
Research Report
SVCP also publishes a proprietary research report at least biannually entitled Where Are We Now®, which
is made available to qualifying clients as part of the Firm’s investment management offering.
Item 5.
Fees and Compensation
SVCP offers its services for a fee based upon assets under management.
Investment Management Fees
SVCP provides investment management services for an annual fee based on the amount of assets under
the Firm’s management. The fee varies between 40 and 100 basis points (0.40% – 1.00%), depending
upon the size of a client’s portfolio and the type of services rendered. The annual fee is prorated and
charged monthly, in arrears, based upon the market value of the assets being managed by SVCP on the
fifth business day from the end of the month. For the initial period of an engagement, the fee is
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calculated on a pro rata basis. In the event the Agreement is terminated, the fee for the final billing period
is prorated through the effective date of the termination and the outstanding balance is charged to the client,
as appropriate. SVCP reserves the right to bill client an account closure fee of $500 per account if
account(s) are closed before the one-year anniversary to compensate for the set-up of accounts, gathering
of data and development of client’s portfolio policy statement, asset allocation and retirement income
strategies recommendations. Certain legacy clients of the Firm may be under a different billing arrangement
with the Firm.
Fee Discretion
SVCP, in its sole discretion, may negotiate to charge a lesser fee based upon certain criteria, such as
anticipated future earning capacity, anticipated future additional assets, dollar amount of assets to be
managed, related accounts, account composition, pre-existing client relationship, account retention and pro
bono activities.
Additional Fees and Expenses
In addition to the advisory fees paid to SVCP, clients may also incur certain charges imposed by other third
parties, such as broker-dealers, custodians, trust companies, banks and other financial institutions
(collectively “Financial Institutions”). These additional charges may include securities brokerage
commissions, transaction fees, custodial fees, charges imposed directly by a mutual fund or ETF in a client’s
account, as disclosed in the fund’s prospectus (e.g., fund management fees and other fund expenses),
deferred sales charges, odd-lot differentials, transfer taxes, wire transfer and electronic fund fees and other
fees and taxes on brokerage accounts and securities transactions. The Firm’s brokerage practices are
described at length in Item 12, below.
Fee Debit
Clients generally provide SVCP with the authority to directly debit their accounts for payment of the Firm’s
investment advisory fees. The Financial Institutions that act as qualified custodian for client accounts have
agreed to send statements to clients not less than quarterly detailing all account transactions, including any
amounts paid to SVCP.
Account Additions and Withdrawals
Clients may make additions to and withdrawals from their account at any time, subject to SVCP’s right to
terminate an account. Additions may be in cash or securities provided that the Firm reserves the right to
liquidate any transferred securities or decline to accept particular securities into a client’s account.
Clients may withdraw account assets on notice to SVCP, subject to the usual and customary securities
settlement procedures. However, SVCP designs its portfolios as long-term investments and the withdrawal
of assets may impair the achievement of a client’s investment objectives. SVCP may consult with its clients
about the options and implications of transferring securities. Clients are advised that when transferred
securities are liquidated, they may be subject to transaction fees, fees assessed at the mutual fund level
(i.e., contingent deferred sales charge) and/or tax ramifications.
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Silicon Valley Capital Partners, L.P. Disclosure Brochure
Item 6.
Performance-Based Fees and Side-by-Side Management
SVCP does not provide any services for a performance-based fee (i.e., a fee based on a share of capital
gains or capital appreciation of a client’s assets).
Item 7.
Types of Clients
SVCP provides its services to individuals, trusts, charitable organizations, corporations and other business
entities.
Methods of Analysis, Investment Strategies and Risk of
Item 8.
Loss
Methods of Analysis and Investment Strategies
SVCP produces periodic research titled, Where Are We Now: Managing Risk Inherent to Global
Macroeconomic and Capital Market Opportunities. This proprietary research includes a top-down analysis
of macroeconomic cycle location, direction and momentum. This analysis is combined with a top-down
and bottom-up future value calculation of the S&P 500 market and sector targets. Several proprietary
momentum indicator models are also included to measure capital market bias and risk.
SVCP also leverages the capital market knowledge of third party research providers, including, but not
limited to Morningstar Institutional Analyst and Standard & Poor’s Capital IQ.
SVCP utilizes this research to structure macro-compliant portfolios with layered and targeted diversification.
The Firm’s goal is to navigate around known risks while at the same time achieving reasonable risk adjusted
returns.
This research program is directly integrated into client portfolio review meetings to achieve three goals: 1)
communicate and support the forward investment strategy, 2) communicate forward capital market bias
and risk, and 3) provide high quality educational services and commentary relevant to investors of all skill
levels.
Risks of Loss
General Risk of Loss
Investing in securities involves the risk of loss. Clients should be prepared to bear potential losses.
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Silicon Valley Capital Partners, L.P. Disclosure Brochure
Market Risks
The profitability of a significant portion of SVCP’s recommendations may depend to a great extent upon
correctly assessing the future course of price movements of stocks and bonds. There can be no assurance
that SVCP will be able to predict those price movements accurately.
Mutual Funds and ETFs
An investment in a mutual fund or ETF involves risk, including the loss of principal. Mutual fund and ETF
shareholders are necessarily subject to the risks stemming from the individual issuers of the fund’s
underlying portfolio securities. Such shareholders are also liable for taxes on any fund-level capital gains,
as mutual funds and ETFs are required by law to distribute capital gains in the event they sell securities for
a profit that cannot be offset by a corresponding loss.
Shares of mutual funds are generally distributed and redeemed on an ongoing basis by the fund itself or a
broker acting on its behalf. The trading price at which a share is transacted is equal to a fund’s stated daily
per share net asset value (“NAV”), plus any shareholders fees (e.g., sales loads, purchase fees, redemption
fees). The per share NAV of a mutual fund is calculated at the end of each business day, although the
actual NAV fluctuates with intraday changes to the market value of the fund’s holdings. The trading prices
of a mutual fund’s shares may differ significantly from the NAV during periods of market volatility, which
may, among other factors, lead to the mutual fund’s shares trading at a premium or discount to actual NAV.
Shares of ETFs are listed on securities exchanges and transacted at negotiated prices in the secondary
market. Generally, ETF shares trade at or near their most recent NAV, which is generally calculated at least
once daily for indexed based ETFs and more frequently for actively managed ETFs. However, certain
inefficiencies may cause the shares to trade at a premium or discount to their pro rata NAV. There is
also no guarantee that an active secondary market for such shares will develop or continue to exist.
Generally, an ETF only redeems shares when aggregated as creation units (usually 20,000 shares or more).
Therefore, if a liquid secondary market ceases to exist for shares of a particular ETF, a shareholder may
have no way to dispose of such shares.
Item 9. Disciplinary Information
SVCP and its management persons have not been involved in any legal or disciplinary events that are
material to a client’s evaluation of its advisory business or the integrity of its management.
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Item 10. Other Financial Industry Activities and Affiliations
A. Broker-Dealer Registration Status
This Item is not applicable.
B. Commodities-Related Registration
This Item is not applicable.
C. Material Relationships or Arrangements with Industry Participants
This Item is not applicable.
D. Material Conflicts of Interest Relating to Other Investment Advisers
This Item is not applicable.
Item 11. Code of Ethics
SVCP has adopted a code of ethics in compliance with applicable securities laws (“Code of Ethics”) that
sets forth the standards of conduct expected of its Supervised Persons. SVCP’s Code of Ethics contains
written policies reasonably designed to prevent certain unlawful practices such as the use of material non-
public information by the Firm or any of its Supervised Persons and the trading by the same of securities
ahead of clients in order to take advantage of pending orders.
The Code of Ethics also requires certain of SVCP’s personnel (called “Access Persons”) to report their
personal securities holdings and transactions and obtain pre-approval of certain investments (e.g., initial
public offerings, limited offerings). However, SVCP’s Supervised Persons are permitted to buy or sell
securities that it also recommends to clients if done in a manner consistent with the Firm’s policies and
procedures. This Code of Ethics has been established recognizing that some securities trade in sufficiently
broad markets to permit transactions by Access Persons to be completed without any appreciable impact
on the markets of such securities. Therefore, under certain limited circumstances, exceptions may be made
to the policies stated below.
When the Firm is engaging in or considering a transaction in any security on behalf of a client, no Access
Person may knowingly effect for themselves or for their immediate family (i.e., spouse, minor children and
adults living in the same household as the Access Person) a transaction in that security unless:
the transaction has been completed;
the transaction for the Access Person is completed as part of a batch trade (as defined below in
Item 12) with clients; or
a decision has been made not to engage in the transaction for the client.
These requirements are not applicable to: (i) direct obligations of the Government of the United States; (ii)
money market instruments, bankers’ acceptances, bank certificates of deposit, commercial paper,
repurchase agreements and other high quality short-term debt instruments, including repurchase
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Silicon Valley Capital Partners, L.P. Disclosure Brochure
agreements; (iii) shares issued by mutual funds or money market funds; and (iv) shares issued by unit
investment trusts that are invested exclusively in one or more mutual funds.
Clients and prospective clients may contact SVCP to request a copy of its Code of Ethics.
Item 12. Brokerage Practices
SVCP generally recommends that clients utilize the brokerage and clearing services of Fidelity Institutional
Wealth Services (“Fidelity”) for investment management accounts.
Factors which SVCP considers in recommending Fidelity or any other broker-dealer to clients include their
respective financial strength, reputation, execution, pricing, research and service. Fidelity enables SVCP to
obtain many mutual funds without transaction charges and other securities at nominal transaction charges.
The commissions and/or transaction fees charged by Fidelity may be higher or lower than those charged
by other Financial Institutions.
The commissions paid by SVCP’s clients comply with the Firm’s duty to obtain “best execution.” Clients
may pay commissions that are higher than another qualified Financial Institution might charge to effect the
same transaction where SVCP determines that the commissions are reasonable in relation to the value of
the brokerage and research services received. In seeking best execution, the determinative factor is not
the lowest possible cost, but whether the transaction represents the best qualitative execution, taking into
consideration the full range of a Financial Institution’s services, including among others, the value of
research provided, execution capability, commission rates and responsiveness. SVCP seeks competitive
rates but may not necessarily obtain the lowest possible commission rates for client transactions.
SVCP periodically and systematically reviews its policies and procedures regarding its recommendation of
Financial Institutions in light of its duty to obtain best execution.
The client may direct SVCP in writing to use a particular Financial Institution to execute some or all
transactions for the client. In that case, the client will negotiate terms and arrangements for the account
with that Financial Institution and the Firm will not seek better execution services or prices from other
Financial Institutions or be able to “batch” client transactions for execution through other Financial
Institutions with orders for other accounts managed by SVCP (as described below). As a result, the client
may pay higher commissions or other transaction costs, greater spreads or may receive less favorable net
prices, on transactions for the account than would otherwise be the case. Subject to its duty of best
execution, SVCP may decline a client’s request to direct brokerage if, in the Firm’s sole discretion, such
directed brokerage arrangements would result in additional operational difficulties.
Transactions for each client generally will be effected independently, unless SVCP decides to purchase or
sell the same securities for several clients at approximately the same time. SVCP may (but is not
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Silicon Valley Capital Partners, L.P. Disclosure Brochure
obligated to) combine or “batch” such orders to obtain best execution, to negotiate more favorable
commission rates or to allocate equitably among SVCP’s clients differences in prices and commissions or
other transaction costs that might not have been obtained had such orders been placed independently.
Under this procedure, transactions will generally be averaged as to price and allocated among SVCP’s
clients pro rata to the purchase and sale orders placed for each client on any given day. To the extent that
SVCP determines to aggregate client orders for the purchase or sale of securities, including securities in
which SVCP’s Supervised Persons may invest, the Firm generally does so in accordance with applicable
rules promulgated under the Advisers Act and no-action guidance provided by the staff of the U.S. Securities
and Exchange Commission. SVCP does not receive any additional compensation or remuneration as a
result of the aggregation. In the event that the Firm determines that a prorated allocation is not appropriate
under the particular circumstances, the allocation will be made based upon other relevant factors, which
may include: (i) when only a small percentage of the order is executed, shares may be allocated to the
account with the smallest order or the smallest position or to an account that is out of line with respect to
security or sector weightings relative to other portfolios, with similar mandates; (ii) allocations may be given
to one account when one account has limitations in its investment guidelines which prohibit it from
purchasing other securities which are expected to produce similar investment results and can be purchased
by other accounts; (iii) if an account reaches an investment guideline limit and cannot participate in an
allocation, shares may be reallocated to other accounts (this may be due to unforeseen changes in an
account’s assets after an order is placed); (iv) with respect to sale allocations, allocations may be given to
accounts low in cash; (v) in cases when a pro rata allocation of a potential execution would result in a de
minimis allocation in one or more accounts, SVCP may exclude the account(s) from the allocation; the
transactions may be executed on a pro rata basis among the remaining accounts; or (vi) in cases where a
small proportion of an order is executed in all accounts, shares may be allocated to one or more accounts
on a random basis.
Consistent with obtaining best execution, brokerage transactions may be directed to certain broker- dealers
in return for investment research products and/or services which assist SVCP in its investment decision-
making process. Such research generally will be used to service all of the Firm’s clients, but brokerage
commissions paid by one client may be used to pay for research that is not used in managing that client’s
portfolio. The receipt of investment research products and/or services as well as the allocation of the benefit
of such investment research products and/or services poses a conflict of interest because SVCP does not
have to produce or pay for the products or services.
Software and Support Provided by Financial Institutions
SVCP may receive from Fidelity, without cost to SVCP, computer software and related systems support,
which allow SVCP to better monitor client accounts maintained at Fidelity. SVCP may receive the software
and related support without cost because SVCP renders investment management services to clients that
maintain assets at Fidelity. The software and support is not provided in connection with securities
transactions of clients (i.e., not “soft dollars”). The software and related systems support may
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Silicon Valley Capital Partners, L.P. Disclosure Brochure
benefit SVCP, but not its clients directly. In fulfilling its duties to its clients, SVCP endeavors at all times
to put the interests of its clients first. Clients should be aware, however, that SVCP’s receipt of economic
benefits from a broker-dealer creates a conflict of interest since these benefits may influence SVCP’s choice
of broker-dealer over another broker-dealer that does not furnish similar software, systems support or
services.
Additionally, SVCP may receive the following benefits from Fidelity through the Fidelity Institutional Wealth
Services Group: receipt of duplicate client confirmations and bundled duplicate statements; access to a
trading desk that exclusively services its Institutional Wealth Services Group participants; access to block
trading which provides the ability to aggregate securities transactions and then allocate the appropriate
shares to client accounts; and access to an electronic communication network for client order entry and
account information. Clients should be aware, however, that the receipt of economic benefits by SVCP or
its related persons in and of itself creates a potential conflict of interest and may indirectly influence SVCP’s
recommendation of Fidelity for custody and brokerage services.
Item 13. Review of Accounts
Account Reviews
SVCP monitors clients’ portfolios as part of an ongoing process while regular account reviews are
conducted on at least a monthly basis. For those clients to whom SVCP provides financial planning and/or
consulting services, reviews are conducted on an “as needed” basis. Such reviews are conducted by one
of SVCP’s investment adviser representatives. All investment advisory clients are encouraged to discuss
their needs, goals and objectives with SVCP and to keep SVCP informed of any changes thereto. The Firm
contacts ongoing investment advisory clients at least annually to review its previous services and/or
recommendations and to discuss the impact resulting from any changes in the client’s financial situation
and/or investment objectives.
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Silicon Valley Capital Partners, L.P. Disclosure Brochure
Account Statements and Reports
Clients are provided with transaction confirmation notices and regular summary account statements
directly from the Financial Institutions where their assets are custodied. Not less than annually or as
otherwise requested, clients may also receive written or electronic reports from SVCP and/or an outside
service provider, which contain certain account and/or market-related information, such as an inventory of
account holdings or account performance. Clients should compare the account statements they receive
from their custodian with those they receive from SVCP or an outside service provider.
Those clients to whom SVCP provides financial planning and/or consulting services will receive reports
from SVCP summarizing its analysis and conclusions as requested by the client or as otherwise agreed
to in writing by SVCP.
Item 14. Client Referrals and Other Compensation
Client Referrals
SVCP is required to disclose any direct or indirect compensation that it provides for client referrals. SVCP
does not have any required disclosures to this Item.
Other Economic Benefits
In addition, SVCP is required to disclose any relationship or arrangement where it receives an economic
benefit from a third party (non-client) for providing advisory services. This type of relationship poses a
conflict of interest and any such relationship is disclosed in response to Item 12, above.
Item 15. Custody
SVCP’s Agreement and/or the separate agreement with any Financial Institution may authorize SVCP
through such Financial Institution to debit the client’s account for the amount of SVCP’s fee and to directly
remit that management fee to SVCP in accordance with applicable custody rules.
The Financial Institutions recommended by SVCP have agreed to send a statement to the client, at least
quarterly, indicating all amounts disbursed from the account including the amount of management fees
paid directly to SVCP. Because the custodian does not calculate the amount of the fee to be deducted, it
is important for clients to carefully review their custodial statements to verify the accuracy of the
calculation. In addition, as discussed in Item 13, SVCP also provides periodic supplemental reports to
clients. Clients should carefully review the statements sent directly by the Financial Institutions and
compare them to those received from SVCP. Clients should contact us directly if they believe that there
may be an error in their statement.
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Silicon Valley Capital Partners, L.P. Disclosure Brochure
Item 16.
Investment Discretion
SVCP is given the authority to exercise discretion on behalf of clients. SVCP is considered to exercise
investment discretion over a client’s account if it can effect transactions for the client without first having to
seek the client’s consent. SVCP is given this authority through a power-of-attorney included in the
agreement between SVCP and the client. Clients may request a limitation on this authority (such as certain
securities not to be bought or sold). SVCP takes discretion over the following activities:
The securities to be purchased or sold;
The amount of securities to be purchased or sold; and
When transactions are made.
Item 17. Voting Client Securities
SVCP is required to disclose if it accepts authority to vote client securities. SVCP does not vote client
securities on behalf of its clients. Clients receive proxies directly from the Financial Institutions.
Item 18.
Financial Information
SVCP is not required to disclose any financial information pursuant to this Item due to the following:
The Firm does not require or solicit the prepayment of more than $1,200 in fees six months or
more in advance of services rendered;
The Firm does not have a financial condition that is reasonably likely to impair its ability to meet
contractual commitments to clients; and
The Firm has not been the subject of a bankruptcy petition at any time during the past ten years.
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