STRATEGIC ADVOCATES, LLC

Item 1 – Cover Page Form ADV Part 2A Brochure Strategic Advocates, LLC 500 N Street, Suite 30 Sacramento, California 95814 Phone: (888) 247-7753 Website: https://www.strati.co/ E-Mail: bharsch@strati.co February 25, 2026 This firm brochure (“firm brochure”) provides information about the qualifications and business practices of Strategic Advocates, LLC (“StratiCo”). If you have any questions about the contents of this brochure, please contact us by phone at (888) 247-7753. 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 StratiCo is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number for StratiCo is 316858. Please note that the use of the term “registered investment advisor” and description of our firm and/or our associates as “registered” does not imply a certain level of skill or training. Clients are encouraged to review this brochure and brochure supplements (“brochure supplements”) for more information on the qualifications of our firm and our associates. 1  Item 2 – Material Changes This firm brochure reflects the following material changes since the previous version dated March 24, 2025. • On or about February 24, 2026, we applied for registration as an investment advisor with the States of California and Utah. It is our expectation that registration in both of these jurisdictions will be completed during the second calendar quarter of 2026. Upon the grant of registration in these jurisdictions, it is our intention to withdraw from registration with the United States Securities and Exchange Commission (“SEC”) in accordance with the requirements of applicable law. As part of this transition to state level registration, we have added a new Item 19 to this firm brochure. • Item 4 has been amended to reflect that our main offices have been relocated to 500 N Street, Suite 30, Sacramento, California 95814, effective as of December 29, 2025. We no longer maintain an office at 255 South Main Street, Suite 140, Logan, Utah 84321. • Item 4 has been amended to reflect that Bradley R. Harsch became the sole owner and managing principal of the firm on December 31, 2025. James P. Jenkins and John R. Mickelson are no longer owners or supervised persons of the firm as of the same date. • Item 4 and Item 5 have been amended to reflect that we no longer offer retirement plan consulting services to pension, profit sharing and 401(k) plans. We continue to assist individuals and high net worth individuals with the management of their personal and employer-sponsored retirement accounts. • Item 5 has been amended to reflect that StratiCo charges an annual asset-based management fee ranging between 1.00% - 2.00% of the market value of the client’s assets under management for portfolio management services. • Item 5 has been amended to reflect that StratiCo typically charges a negotiable fixed fee of up to $5,000 or an hourly fee of up to $350/hour for stand-alone financial planning services. • We have added a new additional information section discussing our use of artificial intelligence-based notetaking software during telephonic and/or virtual client meetings (e.g., Zoom, Microsoft Teams, etc.). We will update this firm brochure and summarize in this Item 2 the occurrence of any material changes with respect to our advisory business in accordance with applicable law. All current clients will receive a Summary of Material Changes to this and subsequent firm brochures within 120 days of the close of our fiscal year and certain additional other-than-annual updates regarding changes with respect to our firm and our business practices promptly following their occurrence. Updated information concerning these changes will be provided to you free of charge. A Summary of Material Changes is also included within our firm brochure found on the SEC’s website at www.adviserinfo.sec.gov. You can obtain additional information about our firm by searching for us on the foregoing website by name or by our unique IARD/CRD number (316858). A copy of this firm brochure will be provided to you free of charge by contacting us at the telephone number reflected on the cover page or by e-mail to bharsch@strati.com 2  Item 3 – Table of Contents Form ADV Part 2A – Strategic Advocates, LLC Item 1 – Cover Page..................................................................................................................................................................... 1 Item 2 – Material Changes ........................................................................................................................................................... 2 Item 3 – Table of Contents .......................................................................................................................................................... 3 Item 4 – Advisory Business ......................................................................................................................................................... 4 Item 5 – Fees and Compensation ................................................................................................................................................. 7 Item 6 – Performance-Based Fees and Side-By-Side Management .......................................................................................... 11 Item 7 – Types of Clients ........................................................................................................................................................... 11 Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss .................................................................................. 11 Item 9 – Disciplinary Information ............................................................................................................................................. 17 Item 10 – Other Financial Industry Activities or Affiliations .................................................................................................... 17 Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading ............................................ 17 Item 12 – Brokerage Practices ................................................................................................................................................... 18 Item 13 – Review of Accounts .................................................................................................................................................. 21 Item 14 – Client Referrals and Other Compensation ................................................................................................................. 22 Item 15 – Custody ...................................................................................................................................................................... 22 Item 16 – Investment Discretion ................................................................................................................................................ 22 Item 17 – Voting Client Securities ............................................................................................................................................ 23 Item 18 – Financial Information ................................................................................................................................................ 23 Item 19 – Requirements for State Registered Advisors ............................................................................................................. 23 Item 20 – Additional Information .............................................................................................................................................. 23 Form ADV Part 2B: Bradley Harsch, AIF® Item 1 – Cover Page................................................................................................................................................................... 25 Item 2 – Educational Background and Business Experience ..................................................................................................... 26 Item 3 – Disciplinary Information ............................................................................................................................................. 26 Item 4 – Other Business Activities ............................................................................................................................................ 26 Item 5 – Additional Compensation ............................................................................................................................................ 27 Item 6 - Supervision ................................................................................................................................................................... 27 Item 7 – Requirements for State Registered Advisors ............................................................................................................... 27 Form ADV Part 2B: Collin E. Sinnott, AIF® Item 1 – Cover Page................................................................................................................................................................... 28 Item 2 – Educational Background and Business Experience ..................................................................................................... 29 Item 3 – Disciplinary Information ............................................................................................................................................. 29 Item 4 – Other Business Activities ............................................................................................................................................ 29 Item 5 – Additional Compensation ............................................................................................................................................ 30 Item 6 - Supervision ................................................................................................................................................................... 30 3  Item 7 – Requirements for State Registered Advisors ............................................................................................................... 30 Form ADV Part 2B: James E. Smith, III, CLU®, ChFC® Item 1 – Cover Page................................................................................................................................................................... 31 Item 2 – Educational Background and Business Experience ..................................................................................................... 32 Item 3 – Disciplinary Information ............................................................................................................................................. 33 Item 4 – Other Business Activities ............................................................................................................................................ 33 Item 5 – Additional Compensation ............................................................................................................................................ 33 Item 6 - Supervision ................................................................................................................................................................... 33 Item 7 – Requirements for State Registered Advisors ............................................................................................................... 33 Item 4 – Advisory Business Strategic Advocates, LLC (“StratiCo,” firm,” “we,” “our,” and “us”) is an investment advisor based in Sacramento, California. While we are presently registered with the SEC, on or about February 24, 2026, we applied for registration as an investment advisor with the States of California and Utah. It is our expectation that registration in both of these jurisdictions will be completed during the second calendar quarter of 2026. Upon the grant of registration in these jurisdictions, it is our intention to withdraw from registration with the United States Securities and Exchange Commission in accordance with the requirements of applicable law. We will notify client promptly upon the transition of our registration from the SEC to state level. We are a limited liability company organized under the laws of the State of Utah. We have been providing investment advisory services since 2022. Bradley R. Harsch is the sole owner and managing principal of the firm. The information contained in this firm brochure describes our investment advisory services, practices, and fees. Please refer to the description of each investment advisory service listed below for information on how we tailor our services to the needs of our clients. As used throughout this brochure, the words “you,” “your,” and “client” refer to you as either a client or prospective client of our firm. Prior to forming an investment advisor-client relationship with you, we may offer a complimentary general consultation to discuss the nature of our services and how we may assist you in the management of your financial affairs. Investment advisory services begin only after we formalize our relationship with you through the execution of a written investment advisory agreement. A description of our investment advisory service offerings is as follows: Portfolio Management Services StratiCo provides ongoing discretionary, and in limited cases, non-discretionary, portfolio management services to our clients. When you engage us for discretionary portfolio management services, you authorize us to make investment decisions and place buy or sell orders in your designated investment account(s) without contacting you or receiving your approval for each specific transaction. If you wish, you may limit our discretionary authority by, for example, setting a limit on the types of securities that can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. If you have engaged us for non-discretionary portfolio management services, StratiCo will obtain your approval prior to executing any transactions in your account(s). Our investment advice is tailored to meet each client’s unique investment needs and objectives. We will meet with you at the outset of our relationship and periodically thereafter to gather your financial information, assist you in determining an appropriate set of investment objectives, and to help you decide how much risk you should take in your portfolio. The 4  information we gather will help us implement a tailored portfolio strategy that will be specific to your goals and needs. We should be notified promptly of any change to your situation, goals, objectives, or needs. Most client accounts are invested using our proprietary asset allocation models (“Models”). Our Models are diversified among investment styles and/or asset classes and are developed and managed by us based on research conducted by our firm. Once your portfolio is constructed, StratiCo provides ongoing supervision of your holdings and will implement changes in your account based upon market conditions and changes in your financial circumstances, goals, and needs. Investments and allocations are determined based upon your predefined objectives, risk tolerance, time horizons, financial horizons, financial information, and other various suitability factors. Further restrictions and guidelines imposed by you may affect the composition and performance of your portfolio. As such, different clients of our firm may experience significant differences in their asset allocations. For these reasons, performance of one client’s portfolio might not be identical to another client’s, even if both clients have similar risk parameters and investment goals. We will review your financial circumstances and investment objectives on a periodic basis, but no less than annually, and adjust your portfolio and/or Models as may be necessary in an effort to achieve the desired results. At all times, our financial professionals will uphold their fiduciary duty by providing advice that is in your best interests. As part of our overall portfolio management strategy, we may use one or more third-party investment advisors and/or sub- advisors (collectively, “Independent Managers”) to manage all or a portion of your portfolio. All Independent Managers recommended by our firm must either be registered as investment advisors or exempt from registration requirements. These Independent Managers may specialize in traditional or alternative investments, such as private equity investments, private credit markets, or hedge funds. We will periodically monitor the Independent Manager’s performance to ensure its management and investment style remains aligned with your investment goals and objectives. Where we have been granted investment discretion, we retain the right to hire and fire Independent Managers and to reallocate client assets among model portfolios made available by the same Independent Manager. The fees charged by Independent Managers are separate and distinct from the fees charged by our firm. Such fees will be clearly listed in the portfolio management agreement you will enter with StratiCo and/or the Independent Manager. In some cases, we will debit the fee charged by the Independent Manager on behalf of the Independent Manager. In other cases, the Independent Manager will debit their fee directly for your account. At your request, portfolio management clients receive ongoing ad-hoc financial advice regarding routine financial matters and questions regarding topics such as budgeting/cash flow management or insurance coverage. This portion of our portfolio management services is entirely non-discretionary in nature – you will make all final investment decisions and be responsible for implementation and monitoring of all investments held outside of the account(s) we directly manage on your behalf at the custodian. Our ad-hoc financial advice is not intended to replace broad-based financial planning and we will not provide you with a written financial plan or report as part of our portfolio management services. Clients wishing to receive broad-based financial planning services or a written financial plan may only do so by entering a separate and distinct written financial planning agreement with our firm. A description of our offering of financial planning services is below. Financial Planning Services StratiCo offers various financial planning related services intended to assist clients in the management of their financial resources. Financial planning services are based upon an analysis of the client’s individual needs beginning with one or more information gathering consultations. Once the firm has analyzed all documentation provided during these consultations, StratiCo will provide a written financial plan designed to achieve the client’s financial goals and objectives. The plan will be updated at least annually and as otherwise necessary or requested by you during the relationship based on changes in your financial circumstances, objectives, and needs. StratiCo then assists clients in developing a strategy for the successful management of income, assets, and liabilities. In general, financial planning services include advice regarding one or more of the following financial topics/concerns, based on your specific financial circumstances: 5  • Cash Flow Analysis – Assessment of present financial situation by collecting information regarding net worth and cash flow statements, tax returns, insurance policies, investment portfolios, pension plans, employee benefit statements, etc. The firm advises on ways to reduce risk; and, to coordinate and organize records and estate information. • • Retirement Analysis – Identification of long-term financial and personal goals and objectives including advice for accumulating wealth for retirement income or appropriate distribution of assets following retirement. Tax consequences and implications are identified and evaluated. Insurance Analysis – Includes risk management associated with advisory recommendations based on a combination of insurance types to meet your needs (e.g., life, health, disability, and long-term care insurance). This will necessitate an analysis of cash needs of the client’s family at death, income needs of surviving dependents, and potential disability income needs. • Portfolio Analysis/Investment Planning – Presentation of investment alternatives, including asset allocation and its effect on the client’s portfolio; evaluation of economic and tax characteristics of existing investments as well as their suitability for the client; and identification and evaluation of tax consequences and their implications. • Education Savings Analysis – Alternatives and strategies with respect to the complete or partial funding of college or other post-secondary education. • Estate Analysis – Advising clients with respect to property ownership, distribution strategies, estate tax reduction, and tax payment techniques. • Tax Analysis and Planning – The goal of tax planning is to arrange your financial affairs so as to minimize your taxes. There are three basic ways to reduce your taxes, and each basic method might have several variations. You can reduce your income, increase your deductions, and take advantage of tax credits. The recommendations and solutions we provide are designed to achieve the client’s desired goals, subject to periodic evaluation of the financial plan, which may require revisions to meet changing circumstances. Financial plans are based on your financial situation based on the information provided to the firm. We should be notified promptly of any change to your financial situation, goals, objectives, or needs. Clients can also request financial planning services that cover a specific area, such as retirement or estate planning, asset allocation analysis, and manager due diligence. Clients may choose to accept or reject our recommendations. If you decide to proceed with our recommendations, you may do so by engaging us for portfolio management services or by using any other investment advisor, broker-dealer, insurance provider, or other third-party provider of your choice. Note: A conflict of interests exists with respect to our rendering of financial planning services, insofar as we have a financial incentive to encourage you to utilize our firm, our associated persons, and/or our affiliates to implement our financial planning recommendations. Clients have no obligation to act on any of our financial planning recommendations. Likewise, when a client chooses to implement any of our financial planning recommendations, the client has no obligation to utilize the firm, any of its associated persons, or affiliates for such purposes. Note: Information related to tax or legal consequences that is provided as part of portfolio management or financial planning services is for information purposes only. Clients are instructed to contact their independent tax professionals and attorneys for tax and legal advice. Types of Securities Recommended StratiCo does not recommend one type of securities over any others. We advise clients on a wide variety of securities, such as exchange listed equities, over-the-counter equities, foreign issues, American depository receipts, corporate debt securities, commercial paper, certificates of deposit, municipal securities, investment company securities (including mutual funds and exchange traded funds), U.S. Government securities, options contracts on securities and/or commodities, structured products, private placements, private equity instruments, and interests in partnership investing in real estate. Additionally, we will provide advice on existing investments you may hold at the inception of the advisory relationship or on other types of investments for which you seek our advice. 6  Our professionals employ a range of investment strategies to implement the advice we give to clients including: long-term purchases, short-term purchases, trading, short sales, margin transactions, option strategies including writing covered options, uncovered options and spread strategies, and taking advantage of price differentials between two or more securities (arbitrage). Quantitative analytics are also utilized in some of our investment activities, to assist in the selection of securities or the management of investment risk. We rely on all information you provide to us, whether financial or otherwise, without independent verification. We request that you promptly notify us in writing of any material change in the financial and other information provided to us, and to promptly provide any such additional information as may be reasonably requested by us. Wrap Fee Programs We do not sponsor, manage, recommend, or otherwise participate in any wrap fee programs. Assets Under Management As of December 31, 2025, our firm manages approximately $33,733,153 of client assets on a discretionary basis, and $0 of client assets on a non-discretionary basis. Item 5 – Fees and Compensation The advisory fees we charge for portfolio management and financial planning services are negotiable within the ranges described below. As a result, certain clients pay higher or lower fees for the same service. Clients are advised that our advisory fees may be higher or lower than those charged by other investment advisors offering similar services/programs. A summary of the fees we charge is as follows: Portfolio Management Service Fees and Billing Practices StratiCo charges an annual advisory fee that is calculated as a percentage of your assets under management. This fee is deducted from your account held at the qualified custodian of your assets. Unless we agree otherwise, clients are required to authorize StratiCo to debit its advisory fee directly from their custodial account(s). We may deduct our advisory fee from a single, client- designated account to facilitate billing. If requested by the client, we may invoice the client directly for the payment of fees in lieu of a direct deduction from the client’s custodial account. StratiCo’s annual advisory fee for portfolio management services typically ranges between 1.00% - 2.00% of the value of your assets under management. The advisory fee is negotiable and the exact fee to be paid by you will be stated in the portfolio management agreement you will be required to enter with StratiCo at the inception of our relationship. The annual fee is billed monthly or quarterly, in advance or in arrears, depending on the payment arrangement negotiated with the client and set forth in the written portfolio management agreement entered at the inception of our relationship. Fees will be assessed pro-rata in the event the agreement is executed at any time other than the first day of a billing period. Fees will be adjusted for any deposits or withdrawals during the billing period. At the inception of investment management services, the first billing period’s fees will be calculated on a pro-rata basis. You may terminate the client agreement upon thirty (30) days’ advance written notice to StratiCo. If your fee is payable in arrears, you will incur a pro rata charge for services rendered prior to the termination of the agreement, which means you will incur advisory fees only in proportion to the number of days in the pay period for which you are a client. Where fees are payable in advance, StratiCo will issue a pro-rated refund of any pre-paid unearned advisory fees based on the number of days remaining in the billing period after the termination date. 7  As paying agent for our firm, your custodian will deduct our advisory fee directly from your account. The fee is deducted only when you have given us written authorization permitting the fees to be paid directly from your account. In the unlikely event that insufficient cash is available to pay such fees, securities in an amount equal to the balance of unpaid fees will be liquidated to pay for the unpaid balance. We will select the securities to be liquidated in line with our fiduciary duty to you. Further, the qualified custodian will deliver an account statement to you at least quarterly. These account statements will show all disbursements from your account, including the amount of any advisory fees paid to StratiCo. We encourage you to promptly review the statement(s) you receive from the qualified custodian for accuracy. If you have questions about your statements, or if you did not receive a statement from the qualified custodian, please call StratiCo at the telephone number located on the cover page of this firm brochure. StratiCo treats cash and cash equivalents as an asset class. Accordingly, unless otherwise agreed, all cash and cash equivalent positions (e.g., money market funds, etc.) are included as part of assets under management for purposes of calculating StratiCo’s advisory fee. At any specific point in time, depending upon perceived or anticipated market conditions/events (there being no guarantee that such anticipated market conditions/events will occur), StratiCo may maintain cash and/or cash equivalent positions for defensive, liquidity, or other purposes. While assets are maintained in cash or cash equivalents, such amounts could miss market advances and, depending upon current yields, at any point in time, StratiCo’s advisory fee could exceed the interest paid by the client’s cash or cash equivalent positions. StratiCo has a fiduciary duty to provide services consistent with the client’s best interest. As part of its investment advisory services, StratiCo will review client portfolios on an ongoing basis to determine if any changes are necessary based upon various factors, including but not limited to investment performance, fund manager tenure, style drift, account additions/withdrawals, the client’s financial circumstances, and changes in the client’s investment objectives. Based upon these and other factors, there may be extended periods of time when StratiCo determines that changes to a client’s portfolio are neither necessary nor prudent. Notwithstanding, unless otherwise agreed in writing, StratiCo’s annual advisory fee will continue to apply during these periods, and there can be no assurance that investment decisions made by StratiCo will be profitable or equal any specific performance level(s). Unless otherwise agreed in writing, the gross amount of assets in the client’s account, including margin balances, are included as part of assets under management for purposes of calculating the firm’s advisory fee. Clients should note that this practice will increase total assets under management used to calculate advisory fees which will in turn increase the amount of fees collected by our firm. This practice creates a conflict of interest in that our firm has an incentive to use margin in order to increase the amount of billable assets. At all times, the firm will uphold its fiduciary duty of fair dealing with clients. Clients are free to restrict the use of margin by our firm and margin will only be used where you have authorized us to do so in writing. Clients should note that any restriction on our use of margin may negatively impact an account’s performance in a rising market. Financial Planning Service Fees and Billing Practices For stand-alone financial planning services, StratiCo typically charges a negotiable fixed fee of up to $5,000 or an hourly fee of up to $350/hour. StratiCo may charge fixed fees or hourly fees that are in excess of the amounts stated above in the event that the client’s financial planning needs are extraordinarily complex or are expected to consume an extraordinary amount of StratiCo’s resources or time. Prior to engaging StratiCo to provide financial planning services, clients will be required to enter into a written financial planning agreement. The financial planning agreement will set forth the terms and conditions of the engagement and will describe the scope of the services to be provided. StratiCo does not require the prepayment of over $500, six (6) or more months in advance. Fee payment arrangements may be negotiated with the client on a case-by-case basis. Fees are payable as invoiced and all such arrangements will be clearly set forth in the financial planning agreement signed by the client and the firm. Fees for these services may be paid to StratiCo by check, money order, ACH, or wire transfer. 8  Either party may terminate a financial planning services agreement upon written notice to the other. In the event the client terminates StratiCo’s financial planning services, any earned but unpaid fees shall be due to StratiCo at termination and a refund of any unearned fees paid in advance shall be due client. When a fixed fee engagement is terminated, the amount of any pro-rated fees or refund due shall be determined based on StratiCo’s good faith binding estimate of the value of the services provided through the date of termination. When an hourly fee engagement is terminated, the client shall pay StratiCo a fee for all hours of work provided through the date of termination. Any partially completed financial plans or reports shall be provided to the client following client’s payment of any outstanding fees due at termination. Additional Fees and Expenses The advisory fees paid to StratiCo for portfolio management and financial planning services are separate and distinct from the fees and expenses charged to shareholders by investment companies, such as unit investment trusts, mutual funds, and exchange traded funds. These fees and expenses are described in each fund’s prospectus. These fees generally include a management fee, other fund expenses, and a possible distribution fee (collectively, “Mutual Fund Fees”). If the fund also imposes sales charges, you may pay an initial or deferred sales charge. Clients should also note that money market accounts offered by the qualified custodian are subject to internal expenses that are charged to shareholders. StratiCo and its financial professionals do not receive any portion of these additional fees. Please note that you could invest in a mutual fund directly, without the services of StratiCo. In that case, you would not receive the advice provided by StratiCo, which is designed, among other things, to assist you in determining which mutual fund or funds are most appropriate to your financial situation and objectives. Although StratiCo uses its best efforts to purchase lower cost mutual fund shares when available, some mutual fund companies do not offer institutional classes to us or they do not offer funds that do not pay 12b-1 distribution fees. Separate and in addition to our advisory fees and Mutual Fund Fees, clients will also incur custodial fees, transaction charges and/or brokerage fees when purchasing or selling securities (collectively “Brokerage Charges”). These charges and fees are typically imposed by the broker-dealer or custodian through which your account transactions are executed. We do not share in any portion of the Brokerage Charges imposed by your broker-dealer or custodian. To fully understand the total costs you will incur when engaging our services, you should consider the costs of Mutual Fund Fees, Brokerage Charges, and our advisory fees. For information on our brokerage practices, please refer to the “Brokerage Practices” section of this firm brochure. Compensation for the Sale of Securities StratiCo and its financial professionals do not receive any compensation in connection with the sale of securities to clients. The firm and its financial professionals act in a fiduciary capacity and will only recommend securities to you when we believe such recommendations to be in your best interests. Compensation for the Sale of Insurance Products Certain of StratiCo’s financial professionals are licensed as independent insurance agents. These persons are eligible to earn commission-based compensation for selling insurance products, including insurance products they sell to you. Insurance commissions earned by these persons are separate and in addition to our advisory fees. This practice presents a conflict of interest because persons providing investment advice on behalf of our firm who are insurance agents have an incentive to recommend insurance products to you for the purpose of generating commissions rather than solely based on your needs. StratiCo and its insurance-licensed financial professionals will only recommend the purchase of insurance products to you when we believe such recommendations to be in your best interests. Clients are under no obligation, contractually or otherwise, to purchase insurance products through any person affiliated with our firm. [CONTINUED ON THE FOLLOWING PAGE] 9  Disclosure Regarding Rollover Recommendations As part of our investment advisory services to you, we may recommend that you roll assets from your employer’s retirement plan, such as a 401(k), 457, or ERISA 403(b) account (collectively, a “Plan Account”), to an individual retirement account, such as a SIMPLE IRA, SEP IRA, Traditional IRA, or Roth IRA (collectively, an “IRA Account”) that we will manage on your behalf. We may also recommend rollovers from IRA Accounts to Plan Accounts, from Plan Accounts to Plan Accounts, from IRA Accounts to IRA Accounts, and from brokerage accounts (i.e., commission-based) to advisory accounts (i.e., fee- based). When we provide any of the foregoing rollover recommendations we are acting as fiduciaries 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. If you elect to roll the assets to an IRA that is subject to our management, we will charge you an asset-based fee as set forth in the advisory agreement you executed with our firm. This creates a conflict of interest because it creates a financial incentive for our firm to recommend the rollover to you (i.e., receipt of additional fee- based compensation). You are under no obligation, contractually or otherwise, to complete the rollover. Moreover, if you do complete the rollover, you are under no obligation to have the assets in an IRA managed by our firm. Due to the foregoing conflict of interest, when we make rollover recommendations, we operate under a special rule that requires us to act in your best interests and not put our interests ahead of yours. Under this special rule’s provisions, we must: ➢ meet a professional standard of care when making investment recommendations (give prudent advice); ➢ never put our financial interests ahead of yours when making recommendations (give loyal advice); ➢ avoid misleading statements about conflicts of interest, fees, and investments; ➢ follow policies and procedures designed to ensure that we give advice that is in your best interests; ➢ charge no more than a reasonable fee for our services; and ➢ give you basic information about conflicts of interest. Many employers permit former employees to keep their retirement assets in their company plan. Also, current employees can sometimes move assets out of their company plan before they retire or change jobs. In determining whether to complete the rollover to an IRA, and to the extent the following options are available, you should consider the costs and benefits of a rollover. Note that an employee will typically have four options in this situation: leaving the funds in your employer’s (former employer’s) plan; 1. 2. moving the funds to a new employer’s retirement plan; 3. cashing out and taking a taxable distribution from the plan; or 4. rolling the funds into an IRA rollover account. Each of these options has positives and negatives. Because of that, along with the importance of understanding the differences between these types of accounts, we will provide you with a written explanation of the advantages and disadvantages of both account types and the basis for our belief that the rollover transaction we recommend is in your best interests. As an alternative to providing you with a rollover recommendation, we may instead take an entirely educational approach in accordance with the U.S. Department of Labor’s Interpretive Bulletin 96-1. Under this approach, our role will be limited only to providing you with general educational materials regarding the pros and cons of rollover transactions. We will make no recommendation to you regarding the prospective rollover of your assets and you are advised to speak with your trusted tax and legal advisors with respect to rollover decisions. As part of this educational approach, we may provide you with materials discussing some or all of the following topics: the general pros and cons of rollover transactions; the benefits of retirement plan participation; the impact of pre-retirement withdrawals on retirement income; the investment options available inside your Plan Account; and high level discussion of general investment concepts (e.g., risk versus return, the benefits of diversification and asset allocation, historical returns of certain asset classes, etc.). We may also provide you with questionnaires and/or interactive investment materials that may provide a means for you to independently determine your future retirement income needs and to assess the impact of different asset allocations on your retirement income. You will make the final rollover decision. 10  Item 6 – Performance-Based Fees and Side-By-Side Management Performance-based fees are based on a share of capital gains on or capital appreciation of the client’s assets. Side-by-side management refers to the practice of managing accounts that are charged performance-based fees while at the same time managing accounts that are not charged performance-based fees. We do not accept performance-based fees or participate in side-by-side management. Our fees are calculated as described in Item 5 of this firm brochure and are not charged on the basis of a share of capital gains upon, or capital appreciation of, the funds in your account(s). Item 7 – Types of Clients We generally offer investment advisory services to individuals, high-net worth individuals, trusts, estates, charitable organizations, corporations, and other business entities. StratiCo does not require any minimum account size or advisory fees to start or continue a relationship. Item 8 – Methods of Analysis, Investment Strategies, and Risk of Loss We may use one or more of the following methods of analysis when providing investment advice to you: • Fundamental Analysis – involves analyzing individual companies and their industry groups, such as a company’s financial statements, details regarding the company’s product line, the experience and expertise of the company’s management, and the outlook for the company’s industry. The resulting data is used to measure the true value of the company’s stock compared to the current market value. The primary risk of fundamental analysis is that information obtained may be incorrect and the analysis may not provide an accurate estimate of earnings, which may be the basis for a stock’s value. If securities prices adjust rapidly to new information, utilizing fundamental analysis may not result in favorable performance. • Technical Analysis – technical analysis is a technique that relies on the assumption that current market data (such as charts of price, volume, and open interest) can help predict future market trends, at least in the short term. It assumes that market psychology influences trading and can predict when stocks will rise or fall. Technical trading models are mathematically driven based upon historical data and trends of domestic and foreign market trading activity, including various industry and sector trading statistics within such markets. Technical trading models, through mathematical algorithms, attempt to identify when markets are likely to increase or decrease and identify appropriate entry and exit points. The primary risk of technical trading models is that historical trends and past performance cannot predict future trends, and there is no assurance that the mathematical algorithms employed are designed properly, updated with new data, and can accurately predict future market, industry, and sector performance. • Charting Analysis – Charting analysis involves the gathering and processing of price and volume pattern information for a particular security, sector, broad index, or commodity. This price and volume pattern information is analyzed. The resulting pattern and correlation data is used to detect departures from expected performance and diversification and predict future price movements and trends. The primary risk of charting analysis is that it may not accurately detect anomalies or predict future price movements. Current prices of securities may reflect all information known about the security and day-to-day changes in market prices of securities may follow random patterns and may not be predictable with any reliable degree of accuracy. We may use one or more of the following investment strategies when advising you on investments: • Long Term Purchases – securities purchased with the expectation that the value of those securities will grow over a relatively long period of time, generally greater than one year. Using a long-term purchase strategy generally assumes the financial markets will go up in the long-term which may not be the case. There is also the risk that the segment of the market that you are invested in or perhaps just your particular investment will go down over time even if the overall 11  financial markets advance. Purchasing investments long-term may create an opportunity cost – “locking-up” assets that may be better utilized in the short-term in other investments. • Short Term Purchases – securities purchased with the expectation that they will be sold within a relatively short period of time, generally less than one year, to take advantage of the securities’ short-term price fluctuations. Using a short- term purchase strategy generally assumes that we can predict how financial markets will perform in the short-term which may be very difficult and will incur a disproportionately higher amount of transaction costs compared to long- term trading. There are many factors that can affect financial market performance in the short-term (such as short-term interest rate changes, cyclical earnings announcements, etc.) but may have a smaller impact over longer periods of times. • Option Writing – an option is the right either to buy or sell a specified amount or value of a particular underlying investment instrument at a fixed price (i.e., the “exercise price”) by exercising the option before its specified expiration date. Options giving you the right to buy are called “call” options. Options giving you the right to sell are called “put” options. When trading options on behalf of a client, we generally use covered options. Covered options involve options trading when you own the underlying instrument on which the option is based. Investments in options contracts have the risk of losing value in a relatively short period of time. Option contracts are leveraged instruments that allow the holder of a single contract to control many shares of an underlying stock. This leverage can compound gains or losses. • Trading – the purchase of securities with the expectation that they will be sold within thirty (30) days. The principal type of risk associated with trading is market risk. There can be no assurance that a specific investment will achieve its investment objectives and past performance should not be seen as a guide to future returns. The value of investments and the income derived may fall as well as rise and investors may not recoup the original amount invested. Other factors, such as changes in exchange control regulation, tax laws, withholding taxes, international, political and economic developments, and government, economic or monetary policies, may affect investments as well. Additionally, trading is speculative. Market movements are difficult to predict and are influenced by, among other things, government trade, fiscal, monetary and exchange control programs and policies; changing supply and demand relationships; national and international political and economic events; changes in interest rates; and the inherent volatility of the marketplace. In addition, governments may, from time-to-time, intervene, directly and by regulation in certain markets, often with the intent to influence prices directly. The effects of governmental intervention may be particularly significant at certain times in the financial instrument markets and such intervention (as well as other factors) may cause these markets to move rapidly. Trading will also result in increased Brokerage Costs to the client relative to long-term purchases. • Short Sales – a securities transaction in which an investor sells securities that were borrowed in anticipation of a price decline. The principal type of risk associated with short selling is that the investor is then required to return an equal number of shares at some point in the future. A short seller will profit if the stock goes down in price, but if the price of the shares increase, the potential losses are unlimited. • Margin Transactions – margin strategies allow an investor to purchase securities on credit and to borrow on securities already in their custodial account. Interest is charged on any borrowed funds for the period that the loan is outstanding. When you purchase securities, you may pay for the securities in full or you may borrow part of the purchase price from your broker-dealer. If you intend to borrow funds in connection with your account, you will be required to open a margin account, which will be carried by the broker-dealer of your account. The securities purchased in such an account are the broker-dealer’s collateral for its loan to you. If the securities in a margin account decline in value, the value of the collateral supporting this loan also declines, and, as a result, a brokerage firm is required to take action, such as issue a margin call and/or sell securities or other assets in your accounts, in order to maintain necessary level of equity in the account. It is important that you fully understand the risks involved in trading securities on margin, which are applicable to any margin account that you may maintain, including any margin Account that may be established as a part of our advisory services and held by your broker-dealer. These risks include the following: 12  1. You can lose more funds than you deposit in your margin account; 2. The broker-dealer can force the sale of securities or other assets in your account; 3. The broker-dealer can sell your securities or other assets without contacting you; 4. You may not be able to choose which securities or other assets in your margin account are liquidated or sold to meet a margin call; 5. The broker-dealer may move securities held in your cash account to your margin account and pledge the transferred securities; and 6. You may not be entitled to an extension of time on a margin call. The investment advice provided along with the strategies suggested by StratiCo will vary depending on each client’s specific financial situation and goals. This brief summary of investment risks does not disclose all of the risks and other significant aspects of investing in financial markets. In light of the risks, you should fully understand the nature of the contractual relationship(s) into which you are entering and the extent of your exposure to risk. Certain investing strategies may not be suitable for many members of the public. You should carefully consider whether the strategies employed would be appropriate for you in light of your experience, objectives, financial resources and other relevant circumstances. You may encounter some or all of the following risks when engaging us for services: Clients are advised that they should only commit assets for management that can be invested for the long term, that volatility from investing can occur, and that all investing is subject to risk. StratiCo does not guarantee the future performance of a client’s portfolio, as investing in securities involves the risk of loss that clients should be prepared to bear. Past performance of a security or a fund is not necessarily indicative of future performance or risk of loss. • Recommendation of Particular Types of Securities – As disclosed under the Item 4 of this firm brochure, we provide advice on various types of securities and we do not necessarily recommend one particular type of security over another since each client has different needs and different tolerance for risk. Each type of security has its own unique set of risks associated with it and it would not be possible to list here all of the specific risks of every type of investment. Even within the same type of investment, risks can vary widely. However, in very general terms, the higher the anticipated return of an investment, the higher the risk of loss associated with it. • General Investment Risk – All investments come with the risk of losing money. Investing involves substantial risks, including complete possible loss of principal plus other losses and may not be suitable for many members of the public. Investments, unlike savings and checking accounts at a bank, are not insured by the government to protect against market losses. Different market instruments carry different types and degrees of risk and you should familiarize yourself with the risks involved in the particular market instruments in which you intend to invest. • Loss of Value – There can be no assurance that a specific investment will achieve its investment objectives and past performance should not be seen as a guide to future returns. The value of investments and the income derived may fall as well as rise and investors may not recoup the original amount invested. Investments may also be affected by any changes in exchange control regulation, tax laws, withholding taxes, international, political and economic developments, and governmental economic or monetary policies. • Interest Rate Risk – Fixed income securities and funds that invest in bonds and other fixed income securities may fall in value if interest rates change. Generally, the prices of debt securities rise when interest rates fall, and their prices fall when interest rates rise. Longer-term debt securities are usually more sensitive to interest rate changes. • Credit Risk – Investments in bonds and other fixed income securities are subject to the risk that the issuer(s) may not make required interest payments. An issuer suffering an adverse change in its financial condition could lower the credit quality of a security, leading to greater price volatility of the security. A lowering of the credit rating of a security may 13  also offset the security’s liquidity, making it more difficult to sell. Funds investing in lower quality debt securities are more susceptible to these problems and their value may be more volatile. • Foreign Exchange Risk – Foreign investments may be affected favorably or unfavorably by exchange control regulations or changes in the exchange rates. Changes in currency exchange rates may influence the share value, the dividends or interest earned and the gains and losses realized. Exchange rates between currencies are determined by supply and demand in the currency exchange markets, the international balance of payments, governmental intervention, speculation, and other economic and political conditions. If the currency in which a security is denominated appreciates against the U.S. Dollar, the value of the security will increase. Conversely, a decline in the exchange rate of the currency would adversely affect the value of the security. • Risks Associated with Investing in Equities – Investments in equities generally refers to buying shares of stocks by an individual or firms in return for receiving a future payment of dividends and capital gains if the value of the stock increases. There is an innate risk involved when purchasing a stock that it may decrease in value and the investment may incur a loss. • Risks Associated with Investing in Mutual Funds – Mutual funds are professionally managed collective investment systems that pool money from many investors and invest in stocks, bonds, short-term money market instruments, other mutual funds, other securities, or any combination thereof. The fund will have a manager that trades the fund's investments in accordance with the fund's investment objective. While mutual funds generally provide diversification, risks can be significantly increased if the fund is concentrated in a particular sector of the market, primarily invests in small cap or speculative companies, uses leverage (i.e., borrows money) to a significant degree, or concentrates in a particular type of security (i.e., equities) rather than balancing the fund with different types of securities. The returns on mutual funds can be reduced by the costs to manage the funds. In addition, while some mutual funds are “no load” and charge no fee to buy into, or sell out of, other types of mutual funds do charge such fees which can also reduce returns. • Risks Associated with Investing in Exchange Traded Funds (“ETFs”) – Investing in stocks and ETFs carries the risk of capital loss (sometimes up to a 100% loss in the case of a stock holding bankruptcy). Investments in these securities are not guaranteed or insured by the Federal Deposit Insurance Corporation (“FDIC”) or any other government agency. • Risks Associated with Investing in Private Funds – Private investment funds are not registered with the SEC and may not be registered with any other regulatory authority. Accordingly, they are not subject to certain regulatory restrictions and oversight to which other issuers are subject. There may be little public information available about their investments and performance. Moreover, as sales of shares of private investment companies are generally restricted to certain qualified purchasers, it could be difficult for a client to sell its shares of a private investment company at an advantageous price and time, or at all. Since shares of private investment companies are not publicly traded and from time- to-time it may be difficult to establish a fair value for the client’s investment in these companies. • Risks Associated with Investing in Options – Transactions in options carry a high degree of risk. A relatively small market movement will have a proportionately larger impact, which may work for or against the investor. The placing of certain orders, which are intended to limit losses to certain amounts, may not be effective because market conditions may make it impossible to execute such orders. Selling (“writing” or “granting”) an option generally entails considerably greater risk than purchasing options. Although the premium received by the seller is fixed, the seller may sustain a loss well in excess of that amount. The seller will also be exposed to the risk of the purchaser exercising the option and the seller will be obliged either to settle the option in cash or to acquire or deliver the underlying investment. If the option is “covered” by the seller holding a corresponding position in the underlying investment or a future on another option, the risk may be reduced. 14  • Risks Associated with Investing in Alternative Investments – We may recommend to qualified clients the use of alternative investments such as investments in real estate, private equity, or hedge funds. We may also recommend a direct investment into a private company. Investments in such “alternative assets” are generally illiquid, which will impair the ability of the client to exit such investments in times of adversity. Alternative investments may utilize highly speculative investment techniques, including leverage, highly concentrated portfolios, senior and/or subordinated securities positions, control positions and illiquid investments. In addition, they may utilize derivative instruments to attempt to hedge the risks associated with certain of their investments. Transactions in such derivative instruments may expose the assets of investment funds to the risks of material financial loss, which may in turn adversely affect the financial results of the client. • Risks Associated with Investing in Structured Products – Certain structured products enable the investor to acquire interests in a pool of securities without the brokerage and other expenses associated with individually holding the same securities, investors in structured products generally pay their share of the structured product’s administrative and other expenses. Although it is difficult to predict whether the prices of assets underlying structured products will rise or fall, these prices (and, therefore, the prices of structured products) will be influenced by the same types of political and economic events that affect issuers of securities and capital markets generally. If the issuer of a structured product uses shorter-term financing to purchase longer-term securities, the issuer may be forced to sell its securities at below-market prices if it experiences difficulty in obtaining short-term financing, which may adversely affect the value of the structured products. Certain structured products may be thinly traded or have a limited trading market. • Leveraged and Inverse ETF Risk – A leveraged ETF generally seeks to deliver multiples of the daily performance of the index or benchmark that it tracks. An inverse ETF generally seeks to deliver the opposite of the daily performance of the index or benchmark that it tracks. Inverse ETFs often are marketed as a way for investors to profit from, or at least hedge their exposure to, downward-moving markets. Some ETFs are both inverse and leveraged, meaning that they seek a return that is a multiple of the inverse performance of the underlying index. To accomplish their objectives, leveraged and inverse ETFs use a range of investment strategies, including swaps, futures contracts and other derivative instruments. Leveraged, inverse, and leveraged inverse ETFs are more volatile and riskier than traditional ETFs due to their exposure to leverage and derivatives, particularly total return swaps and futures. At times, we will recommend leveraged and/or inversed ETFs, which may amplify gains and losses. Most leveraged ETFs are typically designed to achieve their desired exposure on a daily (in a few cases, monthly) basis, and reset their leverage daily. A “single day” is measured from the time the leveraged ETF calculates its net asset value (“NAV”) to the time of the leveraged ETF’s next NAV calculation. The return of the leveraged ETF for periods longer than a single day will be the result of each day's returns compounded over the period. Due to the effect of this mathematical compounding, their performance over longer periods of time can differ significantly from the performance (or inverse performance) of their underlying index or benchmark during the same period of time. For periods longer than a single day, the leveraged ETF will lose money when the level of the Index is flat, and it is possible that the leveraged ETF will lose money even if the level of the Index rises. Longer holding periods, higher index volatility and greater leverage all exacerbate the impact of compounding on an investor's returns. During periods of higher Index volatility, the volatility of the Index may affect the leveraged ETF’s return as much as or more than the return of the Index itself. Therefore, holding leveraged, inverse, and leveraged inverse ETFs for longer periods of time increases their risk due to the effects of compounding and the inherent difficulty in market timing. Leveraged ETFs are riskier than similarly benchmarked ETFs that do not use leverage. Non-traditional ETFs are volatile and not suitable for all investors. Positions in nontraditional ETFs should be monitored closely due to their volatile nature and inability to track the underlying index over an extended period of time. • Illiquid Securities – Illiquid securities involve the risk that investments may not be readily sold at the desired time or price. Securities that are illiquid, that are not publicly traded, and/or for which no market is currently available may be difficult to purchase or sell, which may impact the price or timing of a transaction. An inability to sell securities can adversely affect an account's value or prevent an account from taking advantage of other investment opportunities. 15  Lack of liquidity may cause the value of investments to decline and illiquid investments may also be difficult to value. A client may not be able to liquidate investment in the event of an emergency or any other reason. Certain investment strategies used by our firm may invest in illiquid asset vehicles, such as private equity and real estate. Investment in an illiquid asset vehicle poses similar risks as direct investments in illiquid securities. In addition, investment in an illiquid asset vehicle will be subject to the terms and conditions of the illiquid asset vehicle’s investment policy and governing documents that often include provisions that may involve investor lock-in periods, mandatory capital calls, redemption restrictions, infrequent valuation of assets, etc. In addition, investments in illiquid securities or vehicle may normally involve investment in non-marketable securities where there is limited transparency. If obligated to sell an illiquid security prior to an expected maturity date, particularly with an infrastructure investment, they may not be able to realize fair value. Investments in illiquid securities or vehicles may include restrictions on withdrawal rights and shares may not be freely transferable. • Insurance Product Risk – There also are risks surrounding various insurance products that are recommended to StratiCo’s clients from time-to-time. Such risks include, but are not limited to loss of premiums. Prior to purchasing any insurance product, clients should carefully read the policy and applicable disclosure documents. • Independent Manager Risk – An Independent Manager’s past track record of success cannot be relied upon as a predictor of success in the future. In addition, the underlying holdings of your Independent Manager sub-account(s) (if any) will be determined solely and directly by the Independent Manager and may change over time without advance warning to us. This dynamic creates the potential for overlap with other investments held in your account. This increase in the correlation of your holdings will increase the risk of loss where the value of any overlapping holdings should decrease. There is also a risk that an Independent Manager may deviate from the stated investment model or mandate of the sub-account which could make the holding(s) less suitable for your portfolio. Our firm does not control any Independent Manager’s daily business and compliance operations, and thus our firm may be unaware of any lack of internal controls necessary to prevent business, regulatory or reputational deficiencies. • Cybersecurity Risks – We rely on the use of various electronic technologies to conduct our investment advisory business and are therefore susceptible to operational, information security, and related risks, including risks of unintentional cyber incidents and deliberate cyber-attacks. Cyber-attacks include, but are not limited to, gaining unauthorized access to digital systems (e.g., through “hacking” or malicious software coding) for purposes of corrupting data, or causing operational disruption, as well as denial-of-service attacks on websites. Cyber incidents may cause disruptions and impact on our business operations, potentially resulting in financial losses, interference with a client’s ability to value their investments, impediments to trading, violations of applicable privacy and other laws, regulatory fines, penalties, reputational damage, reimbursement or other compensation costs, or additional compliance costs. While the firm and its most significant counterparties and vendors have established business continuity plans and risk management systems to help mitigate cyber incidents, there are inherent limitations in such plans and systems that are inherently outside of our control. • Pandemic Risk – Large-scale outbreaks of infectious disease can greatly increase morbidity and mortality over a wide geographic area, crossing international boundaries, and causing significant economic, social, and political disruption. It is difficult to predict the long-term impact of such events because they are dependent on a variety of factors including the global response of regulators and governments to address and mitigate the worldwide effects of such events. Workforce reductions, travel restrictions, governmental responses and policies and macroeconomic factors may negatively impact investment returns. • Risks Related to Analysis Methods – Our analysis of securities relies in part on the assumption that the issuers whose securities we recommend for purchase and sale, the rating agencies that review these securities, and other publicly- available sources of information about these securities, are providing accurate and unbiased data. While we are alert 16  to indications that data may be incorrect, there is always a risk that our analysis may be compromised by inaccurate or misleading information. • Securities Transactions at the Direction of Clients – All assets are held at an independent qualified custodian in your name. You will typically maintain the concurrent ability to self-direct transactions within your account. We are not responsible for the consequences, costs, and fees generated by your self-directed investment transactions or transactions you instruct us to implement on your behalf where we have advised you that such transactions are not in your best interests. • Interim Changes in Client Risk Tolerance and Financial Outlook – The particular investments recommended by our firm are based solely upon the investment objectives and financial circumstances disclosed to us by the client. While we strive to meet with clients at regular intervals (at least annually, unless otherwise agreed, either in person, telephonically, or by electronic means) to discuss any changes in the client’s financial circumstances, the lack of constant and continuous communication presents a risk insofar as your liquidity, net worth, risk tolerance and/or investment goals could change abruptly, with no advance notice to our firm, resulting in a mis-aligned investment portfolio and the potential for losses or other negative financial consequences. While we will make reasonable efforts to update your suitability information and investment profile at least annually, we strongly encourage you to give us complete information and to promptly notify us of any changes in your financial circumstances, income level, investment goals or employment status. We encourage you to contact us regularly to discuss any such changes. Item 9 – Disciplinary Information StratiCo is required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm, or the integrity of our management. We have no information to disclose under this Item. Item 10 – Other Financial Industry Activities or Affiliations StratiCo and its associated persons are not registered as a futures commission merchant, a commodity trading advisor, a commodity pool operator, or an associated person of any of the foregoing. StratiCo and its associated persons do not have an application pending for the purpose of seeking registration in any of the foregoing registration categories. Except for the licensure of certain of our financial professionals as independent insurance agents as described in Item 5 of this firm brochure, StratiCo does not have any compensation relationships, industry activities, affiliations or arrangements and does not collect any additional compensation, directly or indirectly, that create a material conflict of interest with its clients. While StratiCo may recommend Independent Managers to portfolio management and financial planning clients, we do not receive any referral fees or other compensation, either directly or indirectly, in connection with such recommendations. We do not act as a solicitor for any third-party money manager. Except as described in Item 12 of this firm brochure, we do not receive additional compensation, either directly or indirectly, in connection with referrals of our clients to any broker-dealers, custodians, attorneys, tax advisors, accountants, or any other third-parties. Item 11 – Code of Ethics, Participation or Interest in Client Transactions and Personal Trading Description of Our Code of Ethics StratiCo has adopted a Code of Ethics (“Code”) to address the conduct of its associated persons. The Code focuses primarily on fiduciary duty, personal securities transactions, insider trading, gifts, and conflicts of interest. The Code includes StratiCo’s policies and procedures developed to protect client interests in relation to the following topics: 17  • The duty at all times to place the interests of clients first; • The requirement that all personal securities transactions be conducted in such a manner as to be consistent with the Code; • The responsibility to avoid any actual or potential conflict of interest or misuse of an employee’s position of trust and responsibility; • The fiduciary principle that information concerning the identity of security holdings and financial circumstances of clients is confidential; and • The principle that independence in the investment decision-making process is paramount. A copy of StratiCo’s Code will be provided to you free of charge by contacting us at the telephone number reflected on the cover page of this firm brochure or by e-mail to bharsch@strati.com. Recommendations Involving Material Financial Interests StratiCo does not recommend that clients buy or sell any security in which StratiCo or any of its associated persons has a material or proprietary financial interest. Personal Trading Practices At times, StratiCo and/or its associated persons may take positions in the same securities as clients. This is considered a conflict of interest with clients. StratiCo and its associated persons will generally be “last in” and “last out” for the trading day when trading occurs in close proximity to client trades, however, we will uphold our fiduciary responsibilities to our clients. Front running (trading shortly ahead of clients) is prohibited. Should a conflict occur because of materiality (e.g., a thinly traded stock), disclosure will be made to the client(s) at the time of trading. Alternatively, accounts owned by our firm or persons associated with our firm may participate in block trading with client accounts; however, they will not be given preferential treatment. Mutual fund purchases are not subject to these policies because the transactions are executed at net asset value at the end of the trading day. Item 12 – Brokerage Practices Recommendation of Broker-Dealers/Custodians Although clients may direct us to use a broker-dealer of their choosing, we generally recommend that clients engage the custodial and trade execution services of Charles Schwab & Co., Inc. (“Schwab”) and/or Interactive Brokers, LLC (“IB,” and collectively with Schwab, the “Recommended Custodians”), both independent SEC registered broker-dealers and members of the Financial Industry Regulatory Authority (“FINRA”) and the Securities Investor Protection Corporation (“SIPC”). We are not affiliated with the Recommended Custodians and the Recommended Custodians do not monitor or control the activities of StratiCo or its associated persons. Where you agree to engage either of the Recommended Custodians’ services, they will execute all transactions for your account in accordance with our instructions. Clients are never obligated to engage the broker-dealers or custodians we recommend. You will ultimately select the Custodian and executing broker for your account by completing the account opening documentation of your preferred service provider. We may provide you with reasonable assistance in completing such documentation. Once a broker-dealer has been selected by the client, unless we are instructed otherwise in writing, you authorize us to execute all trades within your account through such firm. [CONTINUED ON THE FOLLOWING PAGE] 18  Best Execution In recommending broker-dealers, we seek to obtain “best execution,” meaning that we seek to execute securities transactions for clients so that the total costs or proceeds in each transaction are the most favorable under the circumstances. The factors we consider when evaluating for best execution include, without limitation, the broker-dealer’s execution capability; commission rates; financial responsibility; responsiveness; custodial capabilities; the value of any research services/brokerage services provided; and any other factors that we consider relevant. Directed Brokerage If the client selects a custodian other than our Recommended Custodians (i.e., Schwab and/or IB) for custody and execution of transactions (i.e., client directed brokerage), you are advised that we may be unable to seek best execution of your transactions and your commission costs may be higher than those experienced by clients who elect to utilize our Recommended Custodians. For example, in a directed brokerage account, you may pay higher brokerage commissions and/or receive less favorable prices on the underlying securities purchased or sold for your account because we may not be able to aggregate your order with the orders of other clients. In addition, where you direct brokerage, we may place orders for your transactions after we place transactions for clients using our Recommended Custodians. We reserve the right to reject your request to use a particular custodian other than our Recommended Custodians if such selection would frustrate our management of your account or for any other reason. Soft Dollar Arrangements Soft dollar arrangements refer to arrangements under which a broker-dealer agrees to provide an investment advisor with benefits or services (other than execution of trades) contingent upon the advisor’s commitment to direct a certain number or size of brokerage transactions (and related trade commissions) to the broker-dealer. While StratiCo does not participate in any soft dollar arrangements, we do receive certain benefits and services from Schwab and IB (as described below) in connection with our recommendation of their custodial and trade execution services to our clients. These benefits and services are provided to all investment advisors who participate in Schwab and IB’s respective investment platforms and are not contingent upon the number or size of brokerage transactions we direct through Schwab or IB for our client accounts. Benefits Received from Schwab Where your account is maintained at Schwab, our firm will use Schwab as the broker to execute trades. Schwab generally does not charge a separate fee for custody services but is compensated by charging commissions or other fees to clients on trades that are executed or that settle into the client’s Schwab account. In addition to commissions, Schwab charges a flat dollar amount as a “prime broker” or “trade away” fee for each trade that our firm has executed by a different broker-dealer but where the securities bought or the funds from the securities sold are deposited (settled) into the client’s Schwab account. Since trades for accounts custodied at Schwab are expected to be executed exclusively utilizing Schwab’s execution services, we generally do not expect to incur any “trade away fees” in client accounts, although it is possible that they occur on occasion. These fees are in addition to the commissions or other compensation paid to the executing broker-dealer. Because of this, in order to minimize client trading costs, our firm has Schwab execute most, if not all, trades for the accounts. Schwab Advisor Services™ is Schwab’s business serving independent investment advisory firms like StratiCo. They provide our firm and clients with access to institutional brokerage services – trading, custody, reporting and related services – many of which are not typically available to Schwab retail customers. Schwab also makes available various support services. Some of those services help manage or administer our client accounts while others help manage and grow our business. Schwab’s support services are generally available on an unsolicited basis (our firm does not have to request them). Here is a more detailed description of Schwab’s support services: 19  Schwab’s institutional brokerage services include access to a broad range of investment products, execution of securities transactions, and custody of client assets. The investment products available through Schwab include some to which our firm might not otherwise have access or that would require a significantly higher minimum initial investment by firm clients. Schwab’s services described in this paragraph generally benefit clients and their accounts. Schwab also makes available other products and services that benefit our firm but may not directly benefit clients or their accounts. These products and services assist in managing and administering our client accounts. They include investment research, both Schwab’s and that of third parties. This research may be used to service all or some substantial number of client accounts, including accounts not maintained at Schwab. In addition to investment research, Schwab also makes available software and other technology that: facilitates trade execution and allocates aggregated trade orders for multiple client accounts; • provides access to client account data (such as duplicate trade confirmations and account statements); • • provides pricing and other market data; • • facilitates payment of our fees from our clients’ accounts; and assists with back-office functions, recordkeeping and client reporting. Schwab also offers other services intended to help manage and further develop our business enterprise. These services include: educational conferences and events; technology, compliance, legal, and business consulting; • • • publications and conferences on practice management and business succession; and • access to employee benefits providers, human capital consultants, and insurance providers. Schwab may provide some of these services itself. In other cases, Schwab will arrange for third-party vendors to provide the services to our firm. Schwab may also discount or waive fees for some of these services or pay all or a part of a third-party’s fees. Schwab also offers and provides our firm with other benefits, such as occasional business entertainment for our personnel. Irrespective of direct or indirect benefits to our clients through Schwab, our firm strives to enhance the client experience, help clients reach their goals and put client interests before that of our firm and our associated persons. While we do not believe that our receipt of the benefits and services from Schwab discussed above has any influence on our investment recommendations to clients, it creates an incentive for us to continue to recommend, use, or expand our use of Schwab’s custodial and trade execution services. Our firm examined this potential conflict of interest when we chose to enter into these arrangements with Schwab and we have determined that the relationships we have established are in the best interests of our clients and satisfies our client obligations, including our duty to seek best execution. Benefits Received from Interactive Brokers As a registered investment advisor, StratiCo is granted access to the institutional platform of IB. As such, we have access to certain research products and services from IB. These products include financial publications, information about particular companies and industries, research software, and other products or services that provide lawful and appropriate assistance to our firm in the performance of our investment decision-making responsibilities. Such research products and services are provided to all investment advisors that utilize the IB’s custodial and trading platform and are not considered to be paid for with soft dollars. However, you should be aware that the commissions charged by IB for a particular transaction or set of transactions may be greater than the amounts charged by another broker who did not provide us with such research services and products. We do not pay a fee for the products and services provided by IB and all client accounts may not be the direct or exclusive beneficiary of such products and services. It is further important to note that our receipt of such products and services creates 20  an incentive for StratiCo to continue to require that clients engage IB based upon our desire to continue to receive these items, rather than receiving best execution or purely the lowest price for client transactions. We mitigate this conflict of interest by periodically monitoring and reviewing the services provided to our clients by IB for best execution. IB does not make client brokerage commissions generated by client transactions available for our use. Referrals of Advisory Clients StratiCo does not receive referrals of advisory clients from any broker-dealer in exchange for using that broker-dealer’s services. Block Trades We combine multiple orders for shares of the same securities purchased for discretionary advisory accounts we manage (this practice is commonly referred to as “block trading”). We will then distribute a portion of the shares to participating accounts in a fair and equitable manner. Generally, accounts will pay a fixed transaction cost regardless of the number of shares transacted. In certain cases, each participating account pays an average price per share for all transactions and pays a proportionate share of all transaction costs on any given day. In the event an order is only partially filled, the shares will be allocated to participating accounts in a fair and equitable manner, typically in proportion to the size of each client’s order. Accounts owned by our firm or persons associated with our firm may participate in block trading with your accounts; however, they will not be given preferential treatment. We do not block trade for non-discretionary accounts. Accordingly, non-discretionary accounts may pay different costs than discretionary accounts pay. If you enter into non-discretionary arrangements with our firm, we may not be able to buy and sell the same quantities of securities for you and you may pay higher commissions, fees, and/or transaction costs than clients who enter into discretionary arrangements with our firm. Item 13 – Review of Accounts Account Reviews StratiCo monitors client account holdings on a periodic basis and conducts formal account reviews at least annually. Reviews are conducted to ensure alignment between the client’s investment objectives, needs, and limitations and the contents of the client’s investment portfolio. Accounts are reviewed by the associated person assigned to the account. Reviews may be conducted in person, via virtual conference, or over the phone. A written financial plan produced as a result of a financial planning engagement is a snapshot in time and no ongoing reviews are conducted, unless you have engaged us in writing for periodic updates. We recommend a plan review at least annually. Where contracted for, financial plan reviews are conducted to verify that the client’s plan continues to align with their investment objectives and financial circumstances. Financial plan reviews are conducted by the associated person assigned to the client’s account. Reviews may be conducted in person, via virtual conference, or over the phone. Additional Account Reviews Additional reviews may be offered in certain circumstances. Triggering factors that may result in additional reviews include, but are not limited to, changes in economic conditions, changes in the client’s financial situation or investment objectives, or upon client request. [CONTINUED ON THE FOLLOWING PAGE] 21  Reporting Clients will receive statements directly from their account custodian(s) at least quarterly. StratiCo may also provide performance reports as requested by the client. Item 14 – Client Referrals and Other Compensation StratiCo has a brokerage and clearing arrangement with Schwab and IB and the firm will receive additional benefits from these firms in the form of electronic delivery of client information, access to electronic trading platforms, institutional trading support, proprietary and/or third-party research, continuing education, practice management advice, and other services provided by these custodians for the benefit of our firm and/or our investment advisory clients. Please refer to Item 12 above for more information about our receipt of benefits from our Recommended Custodians. StratiCo does not directly or indirectly compensate any of its associated persons or any third-party for client referrals. Likewise, except as described above with respect to benefits received from our Recommended Custodians in Item 12 of this firm brochure, StratiCo does not directly or indirectly receive compensation from any third-party in exchange for client referrals. Item 15 – Custody We do not have physical custody of any of your funds and/or securities. However, we are deemed to have custody over your funds or securities because of the fee deduction authority granted by the client. With respect to third party standing letters of authorization (“SLOA”) where a client grants us authority to direct custodians to disburse funds to one or more third party accounts, we are deemed to have custody pursuant to Rule 206(4)-2 (the “Custody Rule”). We have taken steps to have controls and oversight in place to comply with the no-action letter issued by the SEC on February 21, 2017 (“SEC no-action letter”). We are not required to comply with the surprise examination requirements of the Custody Rule if we comply with the representations noted in the SEC no-action letter. Where our firm acts pursuant to a SLOA, we believe we are making a good faith effort to comply with the representations noted in the SEC no-action letter. Additionally, since many of the representations noted in the SEC no-action letter involve the qualified custodian’s operations, we will collaborate closely with our custodian(s) to ensure that the representations are met. Your funds and securities will be held with a bank, broker-dealer, or other independent, qualified custodian. You will receive account statements from the independent, qualified custodian(s) holding your funds and securities at least quarterly. The account statements from your custodian(s) will indicate the amount of our advisory fees deducted from your account. You should carefully review account statements for accuracy. If you have questions regarding your account or if you did not receive a statement from your custodian, please contact us at the telephone number reflected on the cover page or by email to bharsch@strati.com. Item 16 – Investment Discretion StratiCo offers portfolio management services on a discretionary or non-discretionary basis. For discretionary services, clients will grant discretionary authority to StratiCo in a written portfolio management agreement entered at the inception of the advisory relationship. Our discretionary authority extends to allow us to determine the types and amounts of securities to be bought and sold in your account(s) and the selection of Independent Managers to be utilized, if any. However, our firm does not retain discretionary authority to select the broker/dealer used for transactions or the commission rates to be paid. Apart from the ability to withdraw our investment advisory fees from your account (where you have authorized us in writing to do so), StratiCo does not have the ability to withdraw funds or securities from your account(s). You provide StratiCo discretionary authority via a limited power of attorney contained in the portfolio management agreement and in the contract entered between you and your chosen custodian. 22  If you wish, you may limit our discretionary authority, for example, by setting a limit on the type of securities that can be purchased for your account. Simply provide us with your restrictions or guidelines in writing. Please refer to the “Advisory Business” section in this Brochure for more information on our discretionary portfolio management services. If you have engaged us for non-discretionary portfolio management services, StratiCo will obtain your approval prior to executing any transactions in your account(s). Item 17 – Voting Client Securities We will not vote proxies on behalf of clients and will not provide advice to clients on how the client should vote. We do not accept authority to vote client securities. Clients are solely responsible for voting proxies. Most clients will receive proxies and other solicitations directly from the custodian (e.g., Schwab or IB) of their account. If any proxy materials are received on behalf of a client, they will be sent directly to the client or a designated representative of the client, who is responsible for voting the proxy. Item 18 – Financial Information StratiCo does not require nor solicit prepayment of more than $1,200 in fees per client, six months or more in advance of services being rendered. Therefore, we are not required to include a balance sheet with this firm brochure. As an advisory firm that maintains discretionary authority for client accounts, StratiCo is required to disclose any financial condition that is reasonably likely to impair our ability to meet our contractual obligations. We have no such financial circumstances to report. StratiCo has not been the subject of a bankruptcy petition in the last ten (10) years. Item 19 – Requirements for State Registered Advisors The education, business background, and outside business activities of all management and supervised persons of StratiCo is disclosed in separate Form ADV Part 2B brochure supplement(s) for each individual. Please contact us at the telephone number or e-mail address reflected on the cover page of this firm brochure if you have not received a copy of any Form ADV Part 2B brochure supplement regarding any of our associated persons. Neither StratiCo nor its associated persons receive any performance-based fees. We are required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of our firm, or the integrity of our management. No principal or other person associated with our firm has any such information to disclose. Neither StratiCo nor its associated persons have any relationships or arrangements with any issuers of securities. Item 20 – Additional Information StratiCo reserves the right to utilize third-party artificial intelligence-based (“AI”) notetaking software during telephonic and virtual meetings with clients (e.g., Zoom, Microsoft Teams, etc.). These tools assist us to transcribe and summarize such meetings with clients and are utilized administrative efficiency, recordkeeping, and to enhance the accuracy of our documentation of our interactions with clients. We do not utilize artificial intelligence in any manner to provide investment advice and all notes and summaries of client interactions prepared with the assistance of artificial intelligence are reviewed by the Firm’s associated persons for accuracy and adjusted as necessary before being archived in our records. 23  The use of AI-based notetaking software may, depending on the vendor, involve the transmission of client information, including non-public personal information, to the subject vendor. We conduct due diligence on all such vendors and have entered into contracts requiring data protection, confidentiality, information security procedures be in place. We also maintain our own data protection, confidentiality, and information security policies in accordance with applicable privacy laws. Despite these policies and procedures, the use of this technology involves risks, including the risk of unauthorized use or access to client information, data breaches, and errors or inaccuracies in AI-derived notes and summaries. By participating in telephonic and virtual meetings with StratiCo, clients agree to our use of AI-based notetaking software and accept the related risks described above. If you prefer that StratiCo refrain from the use AI-based notetaking software, please let us know and we will be happy to accommodate your request. We may discontinue our use of AI-based notetaking software at any time. 24  Item 1 – Cover Page Form ADV Part 2B Brochure Supplement Bradley R. Harsch, AIF® Strategic Advocates, LLC 500 N Street, Suite 30 Sacramento, California 95814 Phone: (888) 247-7753 Website: https://www.strati.co/ E-Mail: bharsch@strati.co February 25, 2026 This Form ADV Part 2B “brochure supplement” provides information about Bradley R. Harsch, AIF® that supplements Strategic Advocates, LLC’s (“StratiCo”) Form ADV Part 2A “firm brochure.” You should have received a copy of our firm brochure. If you have not received a copy of our firm brochure or if have any questions about the contents of this brochure, please contact us by phone at (888) 247-7753. Additional information about Bradley R. Harsch, AIF® is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number Bradley R. Harsch, AIF® is 1944419. 25  Item 2 – Educational Background and Business Experience Name of IAR/Year of Birth: Bradley R. Harsch, AIF® Year of Birth: 1965 Formal Education After High School: 1989 University of California, B.A. Sociology Business Background: 07/2021 – Present 01/2023 – 11/2023 01/2023 – 11/2023 02/2014 – 12/2022 02/2014 – 12/2022 09/2009 – 03/2014 09/2006 – 02/2014 Strategic Advocates, LLC, Managing Member, Chief Compliance Officer, Investment Advisor Representative Crown Capital Securities, L.P., Investment Advisor Representative Crown Capital Securities, L.P., Registered Representative Cambridge Investment Research Advisors, Inc., Investment Advisor Representative Cambridge Investment Research, Inc., Registered Representative LPL Financial, LLC, Registered Representative Strategic Wealth Advisors Group, Investment Advisor Representative Professional Designations: Professional Designations: Accredited Investment Fiduciary® (AIF®) The AIF designation certifies that the recipient has specialized knowledge of fiduciary standards of care and their application to the investment management process. To receive the AIF designation, individuals must complete a training program, successfully pass a comprehensive, closed-book final examination under the supervision of a proctor and agree to abide by the AIF Code of Ethics. In order to maintain the AIF designation, the individual must annually renew their affirmation of the AIF Code of Ethics and complete six hours of continuing education credits. The certification is administered by the Center for Fiduciary Studies, the standards-setting body of fi360. Item 3 – Disciplinary Information Mr. Harsch is required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of StratiCo or the integrity of our management. Mr. Harsch has no legal or disciplinary events to disclose under this Item 3. Item 4 – Other Business Activities StratiCo is required to disclose if Mr. Harsch is engaged in any outside investment‐related business activity or occupation, including whether any such relationship creates a material conflict of interest with clients or if he receives additional compensation of any kind related to such outside business activity or occupation. StratiCo is also required to disclose if Mr. Harsch is actively engaged in any other business that provides a substantial source of his income or involves a substantial amount of his time. Currently, Mr. Harsch has no other business activities to report under this Item 4. 26  Item 5 – Additional Compensation Mr. Harsch does not receive additional compensation or economic benefits from third party sources in connection with his advisory activities. Item 6 - Supervision Mr. Harsch is the Chief Compliance Officer of StratiCo. Accordingly, he is responsible for the supervision and implementation of the firm’s compliance program and for the supervision of the advice provided by the firm’s supervised persons to the firm’s clients. Mr. Harsch’s activities on behalf of StratiCo are not supervised by any other person. StratiCo has implemented a Code of Ethics and an internal compliance program that guides the firm and its personnel in complying with applicable state and federal securities laws and in meeting their fiduciary obligations to clients. Mr. Harsch can be reached by phone at (888) 247- 7753 or by e-mail to bharsch@strati.co. Item 7 – Requirements for State Registered Advisors Mr. Harsch is required to disclose all material facts related to certain legal or disciplinary events that would be material to your evaluation of StratiCo or the integrity of our management. In addition, Mr. Harsch is required to disclose whether he has been the subject of a bankruptcy petition. Mr. Harsch has no legal or disciplinary events or bankruptcy history to disclose under this Item 7. 27  Item 1 – Cover Page Form ADV Part 2B Brochure Supplement Collin E. Sinnott, AIF® Strategic Advocates, LLC 500 N Street, Suite 30 Sacramento, California 95814 Phone: (888) 247-7753 Website: https://www.strati.co/ E-Mail: bharsch@strati.co February 25, 2026 This Form ADV Part 2B “brochure supplement” provides information about Collin E. Sinnott, AIF® that supplements Strategic Advocates, LLC’s (“StratiCo”) Form ADV Part 2A “firm brochure.” You should have received a copy of our firm brochure. If you have not received a copy of our firm brochure or if have any questions about the contents of this brochure, please contact us by phone at (888) 247-7753. Additional information about Collin E. Sinnott, AIF® is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number Collin E. Sinnott, AIF® is 7486651. 28  Item 2 – Educational Background and Business Experience Name of IAR/Year of Birth: Collin E. Sinnott, AIF® Year of Birth: 2000 Formal Education After High School: 2022 University of California – Davis, B.S. Biological Sciences Business Background: 09/2022 – Present 02/2023 – 03/2024 06/2022 – 12/2022 01/2022 – 12/2022 09/2018 – 06/2022 Strategic Advocates, LLC, Investment Advisor Representative Crown Capital Securities, L.P., Administrative Staff Cambridge Investment Research Advisors, Inc., Investment Advisor Representative Cambridge Investment Research, Inc., Administrative Staff University of California at Davis, Student Professional Designations: Professional Designations: Accredited Investment Fiduciary® (AIF®) The AIF designation certifies that the recipient has specialized knowledge of fiduciary standards of care and their application to the investment management process. To receive the AIF designation, individuals must complete a training program, successfully pass a comprehensive, closed-book final examination under the supervision of a proctor and agree to abide by the AIF Code of Ethics. In order to maintain the AIF designation, the individual must annually renew their affirmation of the AIF Code of Ethics and complete six hours of continuing education credits. The certification is administered by the Center for Fiduciary Studies, the standards-setting body of fi360. Item 3 – Disciplinary Information Mr. Sinnott is required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of StratiCo or the integrity of our management. Mr. Sinnott has no legal or disciplinary events to disclose under this Item 3. Item 4 – Other Business Activities Mr. Sinnott is individually licensed as an insurance agent and receives commissions or fees on the sale of insurance products or services to clients and in certain instances, payments for the renewal of certain insurance products, in addition to advisory fees for advisory services. These payments vary by insurance product and company and may provide different incentives depending on the amount of the renewal payment. The receipt of insurance related commissions or fees by any individual associated with our firm presents a conflict of interest. For example, the total remuneration that may be received by Mr. Sinnott related to sales of insurance products may be greater than the compensation Mr. Sinnott may receive for providing investment advisory services related to the same products and securities to clients. As such, Mr. Sinnott’s concurrent capacity as an insurance agent creates a financial incentive to promote the sale of insurance products to clients, rather than solely providing investment advice that is based upon the client’s best 29  interests. As a fiduciary, Mr. Sinnott must act in the best interests of our investment advisory clients. Accordingly, Mr. Sinnott will only transact insurance related business with clients when his receipt of additional compensation is disclosed and the recommended insurance products are suitable and in the client’s best interests. Clients may use any insurance firm or agent they choose for the purchase of insurance products and services and are under no obligation to use any individual associated with our firm for such transactions. We encourage you to ask us about the conflicts of interest presented by Mr. Sinnott’s and insurance licensure. Except as described above, Mr. Sinnott is not involved in any other investment related or non-investment related business activities or occupation. Item 5 – Additional Compensation Except as described above in Item 4 with respect to insurance commissions and fees, Mr. Sinnott does not receive additional compensation or economic benefits from third party sources in connection with his advisory activities. Item 6 - Supervision Bradley R. Harsch, AIF® is the managing principal and Chief Compliance Officer of StratiCo. As such, he is responsible for supervising Mr. Sinnott’s activities on behalf of the firm. Mr. Sinnott’s activities on behalf of StratiCo are governed by the firm’s Code of Ethics. If you have any questions regarding Mr. Sinnott, please contact Mr. Harsch at (888) 247-7753 or by e- mail to bharsch@strati.co. Item 7 – Requirements for State Registered Advisors Mr. Sinnott is required to disclose all material facts related to certain legal or disciplinary events that would be material to your evaluation of StratiCo or the integrity of our management. In addition, Mr. Sinnott is required to disclose whether he has been the subject of a bankruptcy petition. Mr. Sinnott has no legal or disciplinary events or bankruptcy history to disclose under this Item 7. 30  Item 1 – Cover Page Form ADV Part 2B Brochure Supplement James E. Smith, III, CLU®, ChFC® Strategic Advocates, LLC 500 N Street, Suite 30 Sacramento, California 95814 Phone: (888) 247-7753 Website: https://www.strati.co/ E-Mail: bharsch@strati.co February 25, 2026 This Form ADV Part 2B “brochure supplement” provides information about James E. Smith, III, CLU®, ChFC® that supplements Strategic Advocates, LLC’s (“StratiCo”) Form ADV Part 2A “firm brochure.” You should have received a copy of our firm brochure. If you have not received a copy of our firm brochure or if have any questions about the contents of this brochure, please contact us by phone at (888) 247-7753. Additional information about James E. Smith, III, CLU®, ChFC® is available on the SEC’s website at www.adviserinfo.sec.gov. The searchable IARD/CRD number James E. Smith, III, CLU®, ChFC® is 801408. 31  Item 2 – Educational Background and Business Experience Name of IAR/Year of Birth: James E. Smith, III, CLU®, ChFC® Year of Birth: 1939 Formal Education After High School: 1971 University of California – Berkley, B.S., M.B.A, Business, Management, Marketing, and Related Support Services Business Background: 04/2023 – Present 04/2023 – 01/2024 06/2010 – 04/2023 06/2010 – 04/2023 Strategic Advocates, LLC, Investment Advisor Representative Crown Capital Securities, L.P., Registered Representative Cambridge Investment Research Advisors, Inc., Investment Advisor Representative Cambridge Investment Research, Inc., Administrative Staff Professional Designations: Chartered Financial Consultant (ChFC®) The Chartered Financial Consultant designation is a financial credential awarded by the American College to individuals who satisfy educational, work experience and ethics requirements. Recipients of the ChFC® certification have completed, and passed examinations, on at least seven mandatory college-level courses in the areas of financial, insurance, retirement and/or estate planning, as well as income taxation and/or investments. Additionally, recipients have completed at least three elective courses on the financial system, estate planning applications, executive compensation, and/or retirement decisions. In order to maintain this designation, ChFC® holders must satisfy the ongoing requirements of the Professional Achievement in Continuing Education (“PACE”), which includes at least 30 hours of continuing education every two years. The Chartered Life Underwriter (“CLU®”) The Chartered Life Underwriter® (CLU®) is a designation of insurance expertise, helping gain a significant advantage in a competitive market. This course of study helps by providing in-depth knowledge on the insurance needs of individuals, business owners and professional clients. Program Learning Objectives: • Provide guidance to clients on types and amounts of life insurance needed. • Make recommendations on aspects of risk management, including personal and business uses of a variety of insurance solutions. • Provide guidance to clients on legal aspects of life insurance contracts and beneficiaries. • Assist clients in making decisions about estate planning, including proper holding of assets and title to assets, as well as the implications of various wills and trust arrangements on financial, retirement and succession planning issues. • Provide a holistic and comprehensive approach to addressing the insurance planning needs of their clients. [CONTINUED ON THE FOLLOWING PAGE] 32  Item 3 – Disciplinary Information Mr. Smith is required to disclose all material facts regarding any legal or disciplinary event that would be material to your evaluation of StratiCo or the integrity of our management. Mr. Smith has no legal or disciplinary events to disclose under this Item 3. Item 4 – Other Business Activities Mr. Smith is individually licensed as an insurance agent and receives commissions or fees on the sale of insurance products or services to clients and in certain instances, payments for the renewal of certain insurance products, in addition to advisory fees for advisory services. These payments vary by insurance product and company and may provide different incentives depending on the amount of the renewal payment. The receipt of insurance related commissions or fees by any individual associated with our firm presents a conflict of interest. For example, the total remuneration that may be received by Mr. Smith related to sales of insurance products may be greater than the compensation Mr. Smith may receive for providing investment advisory services related to the same products and securities to clients. As such, Mr. Smith’s concurrent capacity as an insurance agent creates a financial incentive to promote the sale of insurance products to clients, rather than solely providing investment advice that is based upon the client’s best interests. As a fiduciary, Mr. Smith must act in the best interests of our investment advisory clients. Accordingly, Mr. Smith will only transact insurance related business with clients when his receipt of additional compensation is disclosed and the recommended insurance products are suitable and in the client’s best interests. Clients may use any insurance firm or agent they choose for the purchase of insurance products and services and are under no obligation to use any individual associated with our firm for such transactions. We encourage you to ask us about the conflicts of interest presented by Mr. Smith’s and insurance licensure. Except as described above, Mr. Smith is not involved in any other investment related or non-investment related business activities or occupation. Item 5 – Additional Compensation Except as described above in Item 4 with respect to insurance commissions and fees, Mr. Smith does not receive additional compensation or economic benefits from third party sources in connection with his advisory activities. Item 6 - Supervision Bradley R. Harsch, AIF® is the managing principal and Chief Compliance Officer of StratiCo. As such, he is responsible for supervising Mr. Smith’s activities on behalf of the firm. Mr. Smith’s activities on behalf of StratiCo are governed by the firm’s Code of Ethics. If you have any questions regarding Mr. Smith, please contact Mr. Harsch at (888) 247-7753 or by e-mail to bharsch@strati.co. Item 7 – Requirements for State Registered Advisors Mr. Smith is required to disclose all material facts related to certain legal or disciplinary events that would be material to your evaluation of StratiCo or the integrity of our management. In addition, Mr. Smith is required to disclose whether he has been the subject of a bankruptcy petition. Mr. Smith has no legal or disciplinary events or bankruptcy history to disclose under this Item 7. 33