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Silver Lake Capital Partners LLC
Form ADV Part 2A – Disclosure Brochure
Effective: March 9, 2026
This Form ADV Part 2A (“Disclosure Brochure”) provides information about the qualifications and business practices
of Silver Lake Capital Partners LLC (“Silver Lake Capital” or the “Advisor”). If you have any questions about the
content of this Disclosure Brochure, please contact the Advisor at 972-701-2040.
Silver Lake Capital is a registered investment advisor with the U.S. Securities and Exchange Commission. The
information in this Disclosure Brochure has not been approved or verified by the U.S. Securities and Exchange
Commission (“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 about Silver Lake Capital to assist you
in determining whether to retain the Advisor.
Additional information about Silver Lake Capital and its Advisory Persons is available on the SEC’s website at
www.adviserinfo.sec.gov by searching with the Advisor’s firm name or CRD# 329997.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.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 Silver Lake Capital. For convenience, the Advisor has combined these documents into a single disclosure
document.
Silver Lake Capital 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. Silver Lake Capital
encourages all current and prospective clients to read this Disclosure Brochure and discuss any questions you may
have with the Advisor.
Material Changes
No material changes were made to this Disclosure Brochure since the last annual amendment on March 21, 2025.
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# 329997. You may also
request a copy of this Disclosure Brochure at any time by contacting the Advisor at 972-701-2040.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.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 ........................................................... 8
A. Methods of Analysis ........................................................................................................................................................ 8
B. Risk of Loss ..................................................................................................................................................................... 9
Item 9 – Disciplinary Information ......................................................................................................................... 10
Item 10 – Other Financial Industry Activities and Affiliations .......................................................................... 10
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............... 10
A. Code of Ethics ............................................................................................................................................................... 10
B. Personal Trading with Material Interest ......................................................................................................................... 10
C. Personal Trading in Same Securities as Clients ........................................................................................................... 10
D. Personal Trading at Same Time as Client .................................................................................................................... 11
Item 12 – Brokerage Practices ............................................................................................................................. 11
A. Recommendation of Custodian[s] ................................................................................................................................. 11
B. Aggregating and Allocating Trades ............................................................................................................................... 12
Item 13 – Review of Accounts .............................................................................................................................. 12
A. Frequency of Reviews ................................................................................................................................................... 12
B. Causes for Reviews ...................................................................................................................................................... 12
C. Review Reports ............................................................................................................................................................. 12
Item 14 – Client Referrals and Other Compensation ......................................................................................... 12
A. Compensation Received by Silver Lake Capital ........................................................................................................... 12
B. Compensation for Client Referrals ................................................................................................................................ 13
Item 15 – Custody .................................................................................................................................................. 13
Item 16 – Investment Discretion ........................................................................................................................... 13
Item 17 – Voting Client Securities ........................................................................................................................ 13
Item 18 – Financial Information ............................................................................................................................ 13
Form ADV Part 2B – Brochure Supplement ........................................................................................................ 14
Item 2 – Educational Background and Business Experience ........................................................................... 15
Item 3 – Disciplinary Information ......................................................................................................................... 15
Item 4 – Other Business Activities....................................................................................................................... 15
Item 5 – Additional Compensation....................................................................................................................... 15
Item 6 – Supervision .............................................................................................................................................. 16
Privacy Policy......................................................................................................................................................... 17
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 3
Item 4 – Advisory Services
A. Firm Information
Silver Lake Capital Partners LLC (“Silver Lake Capital” or the “Advisor”) is a registered investment advisor with the
U.S. Securities and Exchange Commission. The Advisor is organized as a Limited Liability Company (LLC) under
the laws of the State of Texas. Silver Lake Capital was founded in March 2013 and became a registered investment
advisor in February 2024. Silver Lake Capital is owned and operated by David Malleck (Managing Partner and Chief
Compliance Officer). This Disclosure Brochure provides information regarding the qualifications, business practices,
and the advisory services provided by Silver Lake Capital.
B. Advisory Services Offered
Silver Lake Capital offers investment advisory services to individuals, high net worth individuals, trusts, and estates
(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. Silver Lake Capital's 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.
Wealth Management Services
Silver Lake Capital provides customized investment advisory solutions for its Clients. This is achieved through
continuous personal Client contact and interaction while providing discretionary investment management and a broad
range of comprehensive financial planning. These services are described below.
Investment Management Services - Silver Lake Capital provides customized investment management services for
its Clients. Silver Lake Capital works closely with each Client to identify their investment goals, objectives, risk
tolerance and financial situation in order to create an overall portfolio strategy. Silver Lake Capital will then construct
an investment portfolio primarily consisting of one or more unaffiliated investment managers or investment platforms
(collectively “Independent Managers”). The Advisor may also utilize low-cost, diversified mutual funds, exchange-
traded funds (“ETFs”), or bonds to achieve the Client’s investment goals. 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.
Use of Independent Managers - Silver Lake Capital will recommend that Clients Independent Managers for all or a
portion of a Client’s investment portfolio based on the Client’s needs and investment objectives. The Advisor will
perform initial and ongoing oversight and due diligence over each Independent Manager to ensure the strategy
remains aligned with Client’s investment objectives and overall best interests. The Advisor will also assist the Client
in the development of the initial policy recommendations and managing the ongoing Client relationship. The Advisor
will ensure that each Independent Manager is properly licensed, notice filed, or exempt from registration. The Client
will be provided with the Independent Manager's Form ADV Part 2A - Disclosure Brochure (or a brochure that makes
the appropriate disclosures).
Silver Lake Capital’s 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. Silver Lake Capital 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.
Silver Lake Capital evaluates and selects investments for inclusion in Client portfolios only after applying its internal
due diligence process. Silver Lake Capital may recommend, on occasion, redistributing investment allocations to
diversify the portfolio. Silver Lake Capital may recommend specific positions to increase sector or asset class
weightings. The Advisor may recommend employing cash positions as a possible hedge against market movement.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 4
Silver Lake Capital may recommend selling positions for reasons that include, but are not limited to, harvesting capital
gains or losses, business or sector risk exposure to a specific security or class of securities, overvaluation or
overweighting of the position[s] in the portfolio, change in risk tolerance of the Client, generating cash to meet Client
needs, or any risk deemed unacceptable for the Client’s risk tolerance.
At no time will Silver Lake Capital 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.
Financial Planning Services - Silver Lake Capital will provide a variety of financial planning and consulting services
as part of its overall wealth management services. Financial planning 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, insurance needs, 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.
Silver Lake Capital 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 pose 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.
C. Client Account Management
Prior to engaging Silver Lake Capital 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:
• Establishing an Investment Strategy – Silver Lake Capital, in connection with the Client, will develop a
strategy that seeks to achieve the Client’s goals and objectives.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 5
• Asset Allocation – Silver Lake Capital 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 – Silver Lake Capital will develop a portfolio for the Client that is intended to meet the
stated goals and objectives of the Client.
•
Investment Management and Supervision – Silver Lake Capital will provide investment management and
ongoing oversight of the Client’s investment portfolio.
D. Wrap Fee Programs
Silver Lake Capital does not manage or place Client assets into a wrap fee program. Investment management
services are provided directly by Silver Lake Capital.
E. Assets Under Management
As of December 31, 2025, Silver Lake Capital manages approximately $211,500,000 in Client assets, of which
$210,000,000 are managed on a discretionary basis and $1,500,000 are managed on a non-discretionary basis.
Clients may request more current information at any time by contacting the Advisor.
Item 5 – Fees and Compensation
The following paragraphs detail the fee structure and compensation methodology for services provided by the
Advisor. Each Client engaging the Advisor for services described herein shall be required to enter into a written
agreement with the Advisor.
A. Fees for Advisory Services
Wealth Management Services
Wealth management fees are paid quarterly in advance pursuant to the terms of the wealth management agreement.
Fees are based on the market value of assets under management at the end of the prior calendar quarter. Fees are
based on the following schedule:
Assets Under Management ($)
Up to $500,000
$500,001 to $1,000,000
$1,000,001 to $2,500,000
$2,500,001 to $5,000,000
$5,000,001 to $10,000,000
Annual Rate (%)
1.35%
1.25%
1.15%
1.00%
0.85%
The wealth management fee in the first quarter of service is prorated from the inception date of the account[s] to the
end of the first quarter. 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
Silver Lake Capital will be independently valued by the Custodian. The Advisor will conduct periodic reviews of the
Custodian’s valuation 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.
Use of Independent Managers
As noted in Item 4, the Advisor will implement all or a portion of a Client’s investment portfolio utilizing one or more
Independent Managers. The Advisor does not earn any compensation from an Independent Manager and will only
earn its wealth management fee as described above. The Advisor will be allocated a portion of the investment
advisory fee collected by the Independent Manager pursuant to the terms of the executed agreement between the
Advisor and the Independent Manager. The total blended fee, including the Advisor’s wealth management fee and
the Independent Manager’s investment advisory fee, will not exceed 2.00% annually.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 6
B. Fee Billing
Wealth Management Services
Wealth management 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 beginning of the respective quarter. The amount due is calculated by applying the quarterly
rate (annual rate divided by 4) to the total assets under management with Silver Lake Capital at the end of the prior
quarter. Clients will be provided with a statement, at least quarterly, from the Custodian reflecting deduction of the
investment advisory fee. Clients are urged to also review and compare the statement provided by the Advisor to the
brokerage statement from the Custodian, as the Custodian does not perform a verification of fees. Clients provide written
authorization permitting advisory fees to be deducted by Silver Lake Capital to be paid directly from their account[s]
held by the Custodian as part of the wealth management agreement and separate account forms provided by the
Custodian.
Use of Independent Managers
For Client accounts implemented through Independent Managers, the Client’s overall fees will include the Advisor’s
wealth management fee (as noted above) plus investment management fees and/or platform fees charged by the
Independent Managers. The Independent Managers will assume the responsibility for calculating the Client’s fees and
deducting all fees from the Client’s account[s].
C. Other Fees and Expenses
Clients may incur certain fees or charges imposed by third parties, other than Silver Lake Capital, in connection with
investments made on behalf of the Client’s account[s]. The Client is responsible for all custody and securities
execution fees charged by the Custodian, as 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 Silver Lake Capital are separate and distinct from these custody
and execution fees.
In addition, all fees paid to Silver Lake Capital 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 Silver Lake
Capital, but would not receive the services provided by Silver Lake Capital 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
Silver Lake Capital 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
Wealth Management Services
Silver Lake Capital may be compensated for its wealth management services in advance of the quarter in which services
are rendered. Either party may terminate the wealth management agreement, at any time, by providing advance written
notice to the other party. The Client may also terminate the wealth management 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.
In the event of termination, the Advisor will reimburse any wealth management fees that have been prepaid but remain
unearned. The refund will cover the period from the effective date of termination to the end of the quarter. The Client’s
wealth management agreement with the Advisor is non-transferable without the Client’s prior consent.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 7
Use of Independent Managers
In the event that the Advisor has determined that an Independent Manager is no longer in the Client’s best interest,
the Advisor will have the discretion to terminate the relationship with the Independent Manager. The terms for
termination are set forth in the respective agreements between the Advisor and the Independent Managers.
E. Compensation for Sales of Securities
Silver Lake Capital 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.
Item 6 – Performance-Based Fees and Side-By-Side Management
Silver Lake Capital does not charge performance-based fees for its investment advisory services. The fees charged
by Silver Lake Capital are as described in Item 5 above and are not based upon the capital appreciation of the funds
or securities held by any Client.
Silver Lake Capital 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
Silver Lake Capital offers investment advisory services to individuals, high net worth individuals, trusts, and estates.
Silver Lake Capital generally does not impose a minimum relationship size.
Item 8 – Methods of Analysis, Investment Strategies and Risk of Loss
A. Methods of Analysis
Silver Lake Capital primarily relies on unaffiliated independent managers for the development and implementation of
investment strategies for its Clients. Research and analysis from Silver Lake Capital and independent managers are
derived from numerous sources, including the Advisor’s Custodian, 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.
Technical analysis involves the analysis of past market data rather than specific company data in determining the
recommendations made to clients. Technical analysis may involve the use of charts to identify market patterns and
trends, which may be based on investor sentiment rather than the fundamentals of the company. The primary risk in
using technical analysis is that spotting historical trends may not help to predict such trends in the future. Even if the
trend will eventually reoccur, there is no guarantee that Silver Lake Capital will be able to accurately predict such a
reoccurrence.
As noted above, Silver Lake Capital generally employs a long-term investment strategy for its Clients through the use
of independent managers, as consistent with a Client’s financial goals. While securities will typically be held for more
than a year, Silver Lake Capital and/ or independent managers may hold for shorter periods for the purpose of
rebalancing a portfolio or meeting the cash needs of Clients. At times, Silver Lake Capital or the independent
manager(s) 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.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 8
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. Silver Lake Capital 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.
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:
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.
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 has 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.
Bond Risks
Bonds 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) 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.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 9
Independent Manager Risks
The Advisor may select certain Independent Managers to manage a portion of the Client’s portfolio. The Advisor
will conduct due diligence, monitor the performance and adherence to the investment mandates and objectives on
the selected Independent Managers. However, the Advisor will not have an active role in the day-to-day
management of this portion of the Client’s portfolio. A failure by an Independent Managers to achieve its investment
objectives could result in a negative impact on the Client’s overall investment portfolio.
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 Silver Lake Capital or its owner. Silver Lake
Capital 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 or 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# 329997.
Item 10 – Other Financial Industry Activities and Affiliations
Use of Independent Managers
As noted in Item 4, the Advisor may select Independent Managers to assist with the implementation of a Client’s
investment strategy. In such arrangements, the Advisor will receive a portion of the investment advisory fees collected
by the Independent Manager from the Client. The Advisor will not charge its own investment advisory fee for assets
referred to an Independent Manager.
Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading
A. Code of Ethics
Silver Lake Capital 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 Silver Lake Capital (“Supervised Persons”). The
Code was developed to provide general ethical guidelines and specific instructions regarding the Advisor’s duties to
each Client. Silver Lake Capital and its Supervised Persons owe a duty of loyalty, fairness and good faith towards
each Client. It is the obligation of Silver Lake Capital’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 972-
701-2040.
B. Personal Trading with Material Interest
Silver Lake Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Silver Lake Capital 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. Silver Lake Capital does
not have a material interest in any securities traded in Client accounts.
C. Personal Trading in Same Securities as Clients
Silver Lake Capital allows Supervised Persons to purchase or sell the same securities that may be recommended to
and purchased on behalf of Clients. Owning the same securities that are recommended (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
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 10
by Silver Lake Capital 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 Silver Lake Capital 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
afterwards. At no time will Silver Lake Capital, or any Supervised Person of Silver Lake Capital, transact in
any security to the detriment of any Client.
Item 12 – Brokerage Practices
A. Recommendation of Custodian[s]
Silver Lake Capital 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 Silver Lake Capital to direct trades to the Custodian as agreed upon in the investment advisory
agreement. Further, Silver Lake Capital does not have the discretionary authority to negotiate commissions on behalf
of Clients on a trade-by-trade basis.
Where Silver Lake Capital 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 from the Advisor associated with using a custodian not recommended by Silver
Lake Capital. However, the Advisor may be limited in the services it can provide if the recommended Custodian is
not engaged. Silver Lake Capital 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, and its reputation and/or
the location of the Custodian’s offices.
The Advisor will generally recommend that Clients establish their account[s] at Raymond James & Associates, Inc.
(“Raymond James”). Raymond James is a FINRA-registered broker-dealer and New York Stock Exchange/SIPC
member. Raymond James will serve as the Client’s “qualified custodian”. The Advisor maintains institutional
relationships with Raymond James, whereby the Advisor receives economic benefits from the Custodian. Please see
Item 14 below.
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 a broker-dealer/custodian in exchange for research and other
services. Silver Lake Capital 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 - Silver Lake Capital 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 Silver Lake Capital 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 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]). Silver Lake Capital 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.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 11
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 Custodian. Silver Lake Capital will execute its transactions through the
Custodian as authorized by the Client. While the Advisor generally relies on independent managers for the execution
of transactions for Clients, Silver Lake Capital 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 Advisory Persons and at least
annually by David Malleck, Chief Compliance Officer of Silver Lake Capital. Formal reviews are generally conducted
at least annually or more frequently depending on the needs of the Client. Formal reviews are conducted for
allocation, investment selection, and suitability. For Client accounts managed by independent managers, the Advisor
will conduct reviews to ensure accounts are managed in accordance with Client profiles, which may include meetings
with independent managers, reviews of Client accounts, and assessments of the independent managers’ investment
philosophy.
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 Silver Lake Capital 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 Silver Lake Capital
Silver Lake Capital is a fee-based advisory firm, that is compensated solely by its Clients and not from any investment
product. Silver Lake Capital does not receive commissions or other compensation from product sponsors, broker-
dealers or any un-related third party. Silver Lake Capital 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, Silver Lake Capital may receive non-compensated referrals of new Clients from various
third-parties.
Participation in Institutional Advisor Platform
As noted in Item 12, the Advisor has established an institutional relationship with Raymond James to assist the
Advisor in managing Client account[s]. As part of the arrangement, Raymond James makes available to the Advisor,
certain research and brokerage services, including research services obtained by Raymond James directly from
independent research companies. The Advisor may also receive additional services and support from Raymond
James. The Advisor has an incentive to continue to use or expand the use of Raymond James's services. The Advisor
examined this potential conflict of interest when it chose to enter into the relationship with Raymond James and has
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 12
determined that the relationship is in the best interests of the Advisor’s Clients and satisfies its Client obligations,
including its duty to seek best execution. The Advisor receives access to software and related support because the
Advisor renders investment management services to Clients that maintain assets at Raymond James. The software
and related systems support may benefit the Advisor, but not its Clients directly. 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 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. In addition, Raymond James has provided the Advisor with financial support in the launch of the Advisor
and reimbursements for various third-party service providers.
B. Compensation for Client Referrals
The Advisor 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.
Item 16 – Investment Discretion
Silver Lake Capital 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 Silver Lake Capital. 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 Silver Lake Capital will be in accordance
with each Client's investment objectives and goals.
Item 17 – Voting Client Securities
Silver Lake Capital 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 Silver Lake Capital, nor its management, have any adverse financial situations that would reasonably impair
the ability of Silver Lake Capital to meet all obligations to its Clients. Neither Silver Lake Capital, nor any of its Advisory
Persons, have been subject to a bankruptcy or financial compromise. Silver Lake Capital 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.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 13
Form ADV Part 2B – Brochure Supplement
for
David T. Malleck, CIMA®
Managing Partner and Chief Compliance Officer
Effective: March 9, 2026
This Form ADV 2B (“Brochure Supplement”) provides information about the background and qualifications of David
T. Malleck, CIMA® (CRD# 1029959) in addition to the information contained in the Silver Lake Capital Partners LLC
(“Silver Lake Capital” or the “Advisor”, CRD# 329997) Disclosure Brochure. If you have not received a copy of the
Disclosure Brochure or if you have any questions about the contents of the Silver Lake Capital Disclosure Brochure
or this Brochure Supplement, please contact us at 972-701-2040.
Additional information about Mr. Malleck 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# 1029959.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 14
Item 2 – Educational Background and Business Experience
David T. Malleck, CIMA®, born in 1958, is dedicated to advising Clients of Silver Lake Capital as a Managing Partner
and Chief Compliance Officer. Mr. Malleck earned a High School Diploma from Republican Valley in 1976. Additional
information regarding Mr. Malleck’s employment history is included below.
Employment History:
05/2024 to Present
05/2024 to 10/2024
01/2009 to 05/2024
Managing Partner and Chief Compliance Officer, Silver Lake Capital Partners
LLC
Registered Representative, Level Four Financial, LLC
Investment Advisor Representative, Raymond James Financial Services
Advisors, Inc.
Financial Advisor, Raymond James Financial Services, Inc.
01/1997 to 05/2024
Certified Investment Management Analyst ™ (“CIMA®”)
The CIMA® certification signifies that an individual has met initial and ongoing experience, ethical, education, and
examination requirements for investment management consulting, including advanced investment management
theory and application. To earn CIMA® certification, candidates must: submit an application, pass a background check
and have an acceptable regulatory history; pass an online Qualification Examination; complete an in-person or online
executive education program at an AACSB® accredited university business school; pass an online Certification
Examination; and have an acceptable regulatory history as evidenced by FINRA Form U-4 or other regulatory
requirements and have three years of financial services experience at the time of certification.
CIMA® certificates must adhere to IMCA’s Code of Professional Responsibility, Standards of Practice, and Rules and
Guidelines for Use of the Marks. CIMA® designees must report 40 hours of continuing education credits, including
two ethics hours every two years to maintain the certification. The designation is administered through the Investment
Management Consultants Association™ (IMCA®).
Item 3 – Disciplinary Information
There are no legal, civil or disciplinary events to disclose regarding Mr. Malleck. Mr. Malleck 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. Malleck.
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. Malleck.
However, we do encourage you to independently view the background of Mr. Malleck on the Investment Adviser
Public Disclosure website at www.adviserinfo.sec.gov by searching with his full name or his Individual CRD#
1029959.
Item 4 – Other Business Activities
Mr. Malleck is dedicated to the investment advisory activities of Silver Lake Capital’s Clients. Mr. Malleck does not
have any other business activities.
Item 5 – Additional Compensation
Mr. Malleck is dedicated to the investment advisory activities of Silver Lake Capital’s Clients. Mr. Malleck does not
receive any additional forms of compensation.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 15
Item 6 – Supervision
Mr. Malleck serves as a Managing Partner and Chief Compliance Officer of Silver Lake Capital. Mr. Malleck can be
reached at 972-701-2040.
Silver Lake Capital has implemented a Code of Ethics, an internal compliance document that guides each Supervised
Person in meeting their fiduciary obligations to Clients of Silver Lake Capital. Further, Silver Lake Capital is subject
to regulatory oversight by various agencies. These agencies require registration by Silver Lake Capital and its
Supervised Persons. As a registered entity, Silver Lake Capital is subject to examinations by regulators, which may
be announced or unannounced. Silver Lake Capital 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.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 16
Privacy Policy
Effective: March 9, 2026
Our Commitment to You
Silver Lake Capital Partners LLC (“Silver Lake Capital” or the “Advisor”) 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. Silver Lake Capital (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.
Silver Lake Capital does not 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.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 17
How do we share your information?
An RIA shares Client personal information to effectively implement its services. In the section below, we list some
reasons we may share your personal information.
Basis For Sharing
Do we share?
Can you limit?
to: processing
Yes
No
Servicing our Clients
We may share non-public personal information with non-affiliated third
parties (such as administrators, brokers, custodians, regulators, credit
agencies, other financial institutions) as necessary for us to provide agreed
upon services to you, consistent with applicable law, including but not
limited
transactions; general account maintenance;
responding to regulators or legal investigations; and credit reporting.
We may share Client information with Level Four Financial, LLC (“Level
Four”). This sharing is due to the oversight Level Four has over certain
Supervised Persons.
No
Not Shared
Yes
Yes
Marketing Purposes
Silver Lake Capital 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 Silver Lake
Capital 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.
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
Not Shared
Information About Former Clients
Silver Lake Capital 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.
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 972-701-2040.
Silver Lake Capital Partners LLC
5005 L.B.J. Freeway, Suite 720, Dallas, TX 75244
Phone: 972-701-2040
https://www.silverlakecp.com
Page 18